The implementation of EU Directives (EU) 2023/2673 and (EU) 2024/825 into German law will bring about significant changes for operators of B2C online shops. The key point is the mandatory introduction of an electronic withdrawal function – often referred to as a "withdrawal button."
From June 19, 2026, consumers must be able to cancel contracts concluded online just as easily as they concluded them. For shop operators, this means not only technical adjustments, but also a comprehensive review of processes, legal texts, and internal procedures.
1. Legal background
Directive (EU) 2023/2673 requires Member States to introduce an electronic withdrawal option for distance contracts concluded online. The aim is to simplify the practical exercise of the right of withdrawal and to remove "barriers" in the digital space.
Directive (EU) 2024/825 complements this development with stricter transparency and information requirements, particularly with regard to:
- statutory warranty rights,
- commercial warranties,
- Durability and repairability of products,
- Spare part availability,
- Updates for goods with digital elements.
The German implementation includes the introduction of a new Section 356a BGB (new version), which regulates the electronic revocation function.
2. Temporal scope of application
Revocation function mandatory from: June 19, 2026
Additional information requirements (including from Directive 2024/825): from September 27, 2026
Shop operators should consider both issues together and integrate them into their compliance planning at an early stage.
3. What is the electronic revocation function?
The term "cancel button" is not literally standardized by law, but it clearly describes the technical implementation.
Essential requirements:
- The cancellation notice must be possible electronically via the website.
- The function must be easily accessible, clearly recognizable, and clearly labeled.
- It must be available throughout the entire statutory withdrawal period.
Important:
The electronic cancellation function does not replace the previous cancellation options (e.g., email or sample cancellation form), but supplements them.
4. Technical design: The two-stage model
The legal concept provides for a two-stage solution.
First stage: Initiate revocation
A clearly labeled button, for example with
- "Cancel contract" or
- "Declare revocation"
Unclear or convoluted terms should be avoided.
Step two: Confirm cancellation
After clicking, the consumer is redirected to an input mask. There, the declaration is made via a second button, for example:
"Confirm cancellation"
finally transmitted.
Only when this second button is clicked is the revocation considered to have been submitted electronically.
5. What information may be requested?
The legislator aims to make it as easy as possible to exercise the right of withdrawal. Accordingly, data collection must be limited.
Only the following are permitted:
- Name of the person revoking consent
- Information for the unique identification of the contract (e.g., order number)
- Contact details for sending the confirmation of receipt (e.g., email address)
It is not permissible to make it mandatory to state a reason for withdrawal. Voluntary disclosure must not be made a prerequisite for the declaration.
6. Obligation to confirm receipt
Upon receipt of the revocation, the entrepreneur must immediately send confirmation on a durable medium—usually by email.
This should include:
- the content of the cancellation policy,
- Date and time of receipt,
- clear confirmation of receipt.
The confirmation of receipt is not a legal assessment of validity, but merely an acknowledgment of receipt.
7. Placement and accessibility
The requirements for visibility and accessibility must be taken seriously. Experience with the cancel button shows that there is considerable potential for warnings in this area.
Please note in particular:
- The cancellation function must be easy to find.
- It must not be "hidden" behind login requirements (especially for guest orders).
- She must remain available throughout the entire withdrawal period.
- It should be designed to be accessible (contrast, readability, usability).
8. Adaptation of legal texts
In addition to technical implementation, legal texts must also be adapted:
- Update to the cancellation policy
- Reference to the electronic revocation option
- Review of consumer information
In the course of implementing Directive (EU) 2024/825, product information, warranty notices, and information on shelf life should also be systematically reviewed.
9. Typical sources of error
In practice, the following are particularly risky:
- Missing or insufficiently visible cancel button
- ambiguous or unclear button labels
- Mandatory request for a reason for cancellation
- missing or delayed confirmation of receipt
- Technical limitations for guest orders
- outdated or contradictory cancellation policies
10. To-do list for shop operators
Strategic
- Plan implementation early, i.e. starting today at the latest.
- Integrate IT, legal, and UX together.
Technical
- Implement a two-step process.
- Ensure automated confirmation of receipt.
- Enable documentation in the backend.
- Also make the function available for guest orders.
Legal
- Update the cancellation policy.
- Check information requirements under (EU) 2024/825.
- Consider data protection aspects of data collection.
Organizational
- Train customer service.
- Standardize reversal processes.
- Display deadline monitoring in the system.
Once again, briefly:
The introduction of the cancel button is not purely a technical adjustment, but rather a compliance-related project with interfaces to IT, legal, UX, and customer service. Taking a structured approach early on not only reduces the risk of warnings, but also increases transparency and consumer-friendliness in your own shop.
Support with implementation
We regularly assist companies in the legally compliant design of e-commerce processes—from the analysis of existing shop structures and legal conception to coordination with IT and product managers.
If you would like to implement the new requirements in a structured and practical manner, we would be happy to assist you with expert advice.
