New cancellation button: What companies must implement by June 19, 2026

With Directive (EU) 2023/2673, European legislators have introduced a new obligation to provide an electronic cancellation button for certain consumer contracts concluded online. The aim of the regulation is to make cancellation as easy as concluding a contract, thereby further strengthening consumer protection in the digital environment. Member States were required to transpose the directive into national law by December 19, 2025; this transposition deadline has not yet been met in Germany. Nevertheless, there is no question that companies must have implemented the new requirements in practice by June 19, 2026, at the latest. Against this background, the question already arises as to which companies are affected, what specific obligations are associated with the withdrawal button, and how the requirements can be implemented in a legally compliant and technically sensible manner.

I. Scope

The scope of the directive is not linked to the industry or size of a company, but to the type of contract conclusion and the existence of a statutory right of withdrawal. It covers entrepreneurs who conclude distance contracts with consumers via an online user interface and where the consumer has a right of withdrawal under EU law. The decisive factor is therefore whether the contract is concluded via a digitally designed user interface – such as a website or an app – and whether withdrawal has been possible to date without any formal requirements, but without an equivalent electronic function.

In terms of content, the directive is primarily aimed at providers of financial services, as it fundamentally restructures the Consumer Rights Directive in this area and repeals the previously separate Distance Marketing of Financial Services Directive. However, the obligation to provide a withdrawal function is not limited to financial services contracts. Rather, it applies to all distance contracts for which the Consumer Rights Directive provides a right of withdrawal, provided that the contract is concluded via an online user interface. The European legislator is thus pursuing a horizontal approach to ensure that consumers can withdraw from contracts as easily as they previously concluded them digitally.

On the other hand, contracts concluded exclusively between businesses and contracts that are not concluded at a distance or via an online user interface are not covered by the scope of application. Also outside the scope are situations in which there is no right of withdrawal by law. It is therefore crucial for the companies concerned to systematically review their digital conclusion processes and contract types to determine whether they fall under the consumer protection withdrawal regulations and must be equipped with an electronic withdrawal function in the future.

II. New obligations

1. Withdrawal button

The core element of Directive (EU) 2023/2673 is the introduction of a mandatory electronic withdrawal function for distance contracts concluded via an online user interface. The European legislator is thus adopting the principle that the procedure for exercising the right of withdrawal must not be more complicated than the digital conclusion of the contract itself. Consumers should be able to declare their decision to withdraw without additional hurdles, detours, or formal requirements directly via the same digital environment through which the contract was concluded.

The basic concept of the withdrawal button aims to achieve functional equivalence between the conclusion and withdrawal processes. The withdrawal function must therefore be permanently available, easy to find, and clearly marked throughout the entire withdrawal period. The directive requires clear labeling, for example with the words "withdraw contract," and prohibits designs that effectively impede or delay access to withdrawal. Withdrawal should be possible directly via the online user interface without the consumer having to search for additional communication channels, download forms, or go through new identification processes if they are already identified.

From a functional point of view, the withdrawal button must guide the consumer through a structured electronic withdrawal process. This includes submitting the withdrawal declaration, confirming the withdrawal decision, and immediately sending a confirmation of receipt on a durable medium. The confirmation of receipt must document the content of the withdrawal declaration and the time of its receipt and serves both consumer protection and legally secure evidence on the part of the entrepreneur.

The introduction of the revocation button regularly requires not only adjustments to the user interface, but also organizational and technical integration into existing systems. Companies must ensure that revocation declarations are automatically recorded, clearly assigned to the respective contract, and transferred to downstream processes, such as billing, service processing, or customer communication. At the same time, internal responsibilities, documentation obligations, and interfaces to customer service must be clearly defined in order to ensure that revocations are processed in a timely and proper manner.

Overall, the revocation button should therefore not be understood as a mere design element, but as a binding component of digital contract management. Companies that offer distance contracts via online user interfaces should plan implementation at an early stage and understand it as an integral part of their digital conclusion and inventory processes.

2. Adaptation of cancellation policy and privacy policy

The introduction of the mandatory withdrawal button is not limited to technical adjustments to the online user interface, but also entails changes to the content of consumer information. In particular, the withdrawal policy must be adapted to the new requirements, as consumers must in future be informed not only about the existence of the right of withdrawal, but also about the specific possibility of exercising it electronically. The directive expressly requires that the conditions, deadlines, and procedures for withdrawal also include information about the existence and location of the withdrawal function.

Companies must therefore review and supplement their cancellation policies to ensure that electronic cancellation via the cancellation button is clearly and comprehensibly described as an equivalent form of exercise. This applies both to pre-contractual information and to the instructions to be provided to the consumer on a durable medium after conclusion of the contract. Incomplete or contradictory information can not only call into question the start of the withdrawal period, but also lead to legal risks with regard to the enforceability and legal consequences of the withdrawal.

In addition, the revocation button is relevant to data protection law. The electronic revocation function necessarily requires the processing of personal data, in particular for the identification of the consumer, for the assignment of the revocation to a specific contract, and for the documentation of the time of the declaration. If this processing goes beyond existing processes or establishes new purposes, the privacy policy must be reviewed and, if necessary, adapted. Consumers must be informed transparently about which personal data is processed in the context of electronic withdrawal, for what purposes this is done, and on what legal basis the processing is based.

III. German implementation

The national implementation of Directive (EU) 2023/2673 has not yet been completed in Germany. Although the directive should have been transposed into national law by December 19, 2025, a corresponding implementation law has not yet entered into force. Currently, there is only a draft law from the federal government dated September 29, 2025, which essentially implements the requirements of the directive by amending the consumer rights provisions of the German Civil Code (BGB).

In particular, the draft bill provides for the introduction of a separate legal provision on the electronic withdrawal function, which systematically ties in with the existing provisions on the right of withdrawal in distance contracts. According to the draft, a new Section 356a BGB-E is to be introduced for this purpose, which expressly regulates the exercise of the right of withdrawal via an online user interface and thus transposes the EU legal requirements of Article 11a of the Consumer Rights Directive into national law.

In terms of content, the draft bill adopts the central requirements of the directive almost word for word. The entrepreneur shall be obliged to provide a withdrawal function for distance contracts concluded via an online user interface that is clearly marked, available throughout the entire withdrawal period, and easily accessible to the consumer. The draft also provides for a two-stage withdrawal process with submission of the withdrawal declaration, subsequent confirmation, and immediate confirmation of receipt on a durable medium.

IV. Recommendations for action for companies

Companies that conclude distance contracts via online user interfaces should use the remaining time until June 19, 2026, to implement the new requirements in a structured and legally compliant manner. The starting point should be a comprehensive inventory of the types of contracts and digital conclusion processes affected. In doing so, it is necessary to check which offers are subject to a statutory right of withdrawal and via which user interfaces the contracts are concluded.

On this basis, it is advisable to involve the technical and organizational departments at an early stage. The withdrawal button should not be viewed in isolation, but as an integral part of digital contract management. In addition to the visible placement and user-friendly design of the withdrawal function, the downstream processes in particular – from automated recording and contract assignment to confirmation and further processing of the withdrawal – must function reliably and be documented.

At the same time, the legal content should be reviewed and adapted. Cancellation policies, contract information, and privacy statements must accurately reflect the electronic exercise of the right of withdrawal and correspond to the actual technical implementation. Inconsistencies between the user interface and legal information pose considerable risks, particularly with regard to the start of the withdrawal period and possible complaints from consumers or supervisory authorities.

Finally, it is advisable to test the implementation at an early stage and to clearly define internal responsibilities. Training relevant employees, especially in customer service, can help to ensure that withdrawal notices are correctly identified and processed properly. In view of the application deadline specified by EU law, companies should not make their preparations dependent on the further course of the national legislative process.

V. Conclusion and outlook

The electronic withdrawal button supplements the existing consumer law requirements with a further, technically specified form of exercising the right of withdrawal. Even though the national implementation law in Germany is still pending , the content framework has already been clearly outlined by Directive (EU) 2023/2673 and the current draft law. Companies must therefore assume that the new requirements will be binding from June 19, 2026, at the latest.

In practice, early and structured implementation is recommended, taking technical, organizational, and legal aspects into account in equal measure. The withdrawal button should be understood less as an isolated innovation and more as a further development of existing digital contract processes. Proper integration makes it possible to implement the legal requirements while continuing existing processes in a consistent and transparent manner.

This article was created in collaboration with our student employee Emily Bernklau.