To strengthen protections for consumers buying online, the EU has introduced new requirements that make it simpler to cancel (withdraw from) online consumer contracts. This arises from the requirements of Directive (EU) 2023/2673, and its key change is a mandatory electronic withdrawal feature or a “withdrawal button”.
Any retailer selling online to EU consumers, whether established inside or outside the EU, should be preparing to update its contracting and cancellation flows ahead of 19 June 2026.
What the “three-click” withdrawal process must look like
The directive effectively requires a straightforward, visible, step-by-step withdrawal route at any time during the withdrawal period.
i) A clearly visible withdrawal button
Consumers must be able to select a button labelled:
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“withdraw from the contract here”
or similar wording that is equally clear and unambiguous.
The button must be easy to find and available on the retailer’s online interface, and and remain available at all times during the entire withdrawal period (typically 14 days, though the length can differ depending on the contract, what is being sold, especially for financial services).
ii) A clear confirmation step
After selecting the withdrawal button, the consumer must be able to confirm their intention via a second, clearly identified feature using wording such as:
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“confirm withdrawal here”
(or another similarly unambiguous phrase).
The confirmation step must allow the customer to check and complete key details easily, such as:
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name (surname/first name), and
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which contract/order is being cancelled, and other relevant information.
The confirmation step should only collect the information strictly necessary for the withdrawal and must be implemented in a GDPR-compliant manner.
iii) Confirmation on a durable medium
The consumer must then receive an acknowledgment of the withdrawal on a durable medium (for example, a message that can be stored and reproduced, such as email). The confirmation must include the content of the withdrawal declaration, along with the date and time it was received. A withdrawal is treated as having been exercised in time if the consumer submits the online withdrawal declaration before the withdrawal period expires.
The full withdrawal journey should also be logged and provable so the retailer can evidence compliance if challenged.
Why non-EU retailers are also affected
EU consumer rules often apply beyond EU borders, as protections typically cover not only EU-established traders, but also non-EU businesses that direct their online activity at EU consumers. Indicators that a retailer is targeting the EU market can include, for example:
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offering delivery to EU countries,
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operating a website in an EU Member State language, or
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allowing payment in EUR.
So, if you sell online and your website is set up to target EU consumers, you should assume these requirements apply to you as well.
Implementation across Member States
Because this is an EU directive, each Member State implements it through its own national legislation. That can result in local variations and additional country-specific requirements, so retailers should also review the relevant rules in each market where they operate.
Key dates and current status
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Member States were expected to adopt implementing measures by 19 Dec 2025.
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The new national rules should apply from 19 June 2026.
If you’d like tailored guidance on the requirements and practical implementation steps (including local rules by Member States), please get in touch to arrange a free initial consultation.
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