Cancellation button for online contracts becomes mandatory
From June 19, 2026: Electronic cancellation function becomes mandatory
As of June 19, 2026, many companies entering into consumer contracts online through websites, apps, or other digital interfaces, must provide an easily accessible electronic cancellation function (colloquially known as the “cancellation button”).
The legal basis is the implementation of the EU Directive (EU) 2023/2673 into German law, particularly the new § 356a BGB. The goal is for consumers to be able to cancel a contract just as easily as they enter into it online. Companies should adjust their digital completion processes and internal procedures early, as violations can lead to competition law risks (e.g., warnings and injunctive claims).
Which contracts and providers are affected?
The obligation generally applies to distance contracts between companies and consumers, as long as there is a statutory right of withdrawal. This includes, among others:
- Online shops and direct-to-consumer offers
- Booking and intermediary platforms (e.g., for travel, tickets, services)
- Digital services and apps (e.g., subscriptions, memberships, digital content)
- Contracts via online marketplaces (e.g., through major platforms)
- Financial services and insurance products, insofar as a right of withdrawal exists
Not covered are, according to the regulation, particularly scenarios where the contract is concluded solely by phone or email – meaning without a digital user interface through which the contract was made.
“Button” is not to be understood literally: What is decisive is clarity and findability
The term “withdrawal button” can be misunderstood: Legally, a graphical button is not mandatory. What is required is a clearly recognizable electronic withdrawal function, which can also be implemented as a distinctly labeled link.
It is essential that the function:
- is easily accessible,
- clearly understood as a withdrawal option and
- remains usable without unnecessary obstacles..
Permissible labels include, for example, “Cancel contract” or “Declare withdrawal”. Unclear terms such as “Contact”, “Service” or “Help” are regularly insufficient because they do not clearly name the withdrawal function.
Withdrawal in two steps: This is how the process must typically look
The exercise of withdrawal is structured as a two-step procedure:
- Initiating the withdrawal via the withdrawal function (button/link). Afterward, consumers reach a page where they can assign the specific contract (for example, using order number or email address).
- Final declaration of the withdrawal via a second button, for example, “Confirm withdrawal”.
Upon receipt of the withdrawal, the company must provide an electronic confirmation of receipt that documents the time and is made available to the consumer on a durable medium (typically by email).
Technical and organizational obligations for companies
The introduction often requires adjustments to websites, apps, CRM/ticket systems, and internal processes. The withdrawal function must be available throughout the entire withdrawal period:
- continuously available be,
- clearly visible, be placed and
- be accessible without additional difficulties.
Designs that effectively complicate revocation, such as functionalities that are hidden or only accessible after additional, unnecessary steps, are particularly impermissible or risky. Moreover, the possibility of revocation should not depend on consumers having to establish additional technical requirements beyond the usual scope.
Legal Consequences of Violations: Competition Law and Withdrawal Periods
Violations of the obligation to provide the electronic revocation function can be relevant under competition law. Possible consequences include:
- Warnings (e.g. by competitors or qualified associations),
- claims for injunctions and
- in the case of escalation,court proceedings..
In addition, a missing or incorrectly designed revocation option can affect the duration of the withdrawal period. In consumer law, the withdrawal period generally only begins to run properly if the statutory information and design obligations are complied with. If requirements are not met, the risk may arise that the withdrawal period extends (typically up to one year and 14 days), which can cause economic disadvantages – for example, through reversals, refunds, or the loss of already calculated profits.
Privacy: Only request necessary data
In designing the revocation process, data protection requirements must be taken into account. When requesting an electronic revocation, companies should only ask for data that is necessary for the identification of the contract (e.g. order number, email address, or name in combination with other minimal details).
Important:
- No excessive mandatory fields (data minimization).
- A reason for revocation must not be mandatorily required.
- Privacy notices should transparently accompany the process (purpose, legal basis, storage duration).
More convenience for consumers – companies need to take action
For consumers, revocation will become significantly easier and more standardized: Instead of searching extensively for contact channels or overcoming formal hurdles, the revocation should be possible with just a few clicks in the future. For companies, this means: Those who want to avoid the risk of warnings and economic disadvantages should promptly check whether their digital interfaces and internal processes meet the new requirements.
MTR Legal Attorneys advises on IT law.
Feel free to contact us.
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