The European consumer protection landscape is undergoing significant change. Following the discontinuation of the European Online Dispute Resolution (ODR) Platform and the updated Alternative Dispute Resolution (ADR) Directive (Directive 2025/2647), online businesses serving EU consumers face new legal obligations and opportunities to manage disputes.
End of the ODR Platform
The ODR Platform was officially discontinued on 20 July 2025, after a review found its cost-effectiveness and performance below expectations. Businesses are no longer required to display a link to the platform on their websites or in their terms and conditions.
However, online retailers must continue to inform consumers clearly about available ADR options, tailored by country and sector.
Key changes under the updated ADR Directive
At the same time, the EU has comprehensively revised its consumer ADR framework through the adoption of Directive (EU) 2025/2647, which modernises the existing regime by amending Directive 2013/11/EU and updating the rules to reflect current market realities. The revised Directive entered into force on 19 January 2026, and Member States must adopt and publish implementing measures by mid-2028.
See below a summary of the key changes introduced by the revised ADR Directive:
Broader scope
The updated Directive extends the scope of Directive 2013/11/EU to:
• Traders from third countries who direct their activities toward one or more EU Member States;
• Disputes arising during the pre-contractual phase, including e.g. misleading advertising and failures to provide mandatory information; and
• Contracts for the supply of digital content or digital services between consumers and traders, including when the consumer provides or undertakes to provide personal data instead of making a payment.
In assessing whether a trader’s activities are directed a particular Member State, key factors include the use of a specific language or currency, the possibility for consumers to place orders, or the availability of an application in a national app store.
Mandatory Trader Response
Traders established in the EU are required to respond within 20 working days when contacted by an ADR entity, indicating whether they will participate in the procedure. This does not apply where participation is mandatory under law, required to fulfil a contractual commitment or where the ADR entity is entitled to reach a decision even in the absence of the trader’s participation.
For complex disputes, the response may be extended to a maximum of 30 working days, provided that the consumer is informed of the extension.
Failure to respond may be considered non-cooperation and lead to sanctions.
Information and transparency
Traders are also required to provide clear and easily accessible information about available ADR mechanisms. This is to ensure consumers are informed of their dispute resolution options at an early stage and can readily identify the appropriate ADR body.
Automated Decision-Making
ADR entities using automated processes must inform consumers in advance and allow review by a competent human.
Case Bundling for Mass Disputes
ADR entities can bundle multiple consumer complaints arising from the same illegal practices. This improves efficiency and aligns ADR with collective redress mechanisms.
Strengthened Institutional Cooperation
ADR entities must collaborate more closely with national consumer protection authorities, including the exchange of information on unfair commercial practices and cross-border disputes. Contact points will provide support to both consumers and traders.
Digital Tools for Consumers
By April 2026, the Commission will develop an interactive tool providing information on redress, ADR use in cross-border disputes, and links to consumer rights resources.
Need help?
If you would like tailored guidance on the ADR requirements applicable to your online business, including practical implementation steps at Member State level, please feel free to get in touch to book a free initial consultation.
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