From June 19, 2026, all online shops in Germany must offer a withdrawal button. EU Directive 2023/2673 requires merchants to provide consumers with a simple digital way to exercise their right of withdrawal. Those who miss the deadline or fail to meet the requirements risk warnings and fines of up to 50,000 euros.
What is the Withdrawal Button?
The withdrawal button is a digital function that enables consumers to exercise their 14-day right of withdrawal directly in the online shop - without having to write emails, print forms or make phone calls.
The button does not replace the existing right of withdrawal. It merely facilitates its exercise. The 14-day period and all other regulations remain unchanged.
The process works in two steps: First, the customer clicks on the button, then a form opens for entering the relevant data. After submission, the customer automatically receives a confirmation by email.
Legal Basis and Timeline
The basis is EU Directive (EU) 2023/2673, which came into force on December 18, 2023. The national implementation deadline for Germany ended on December 19, 2025. For online retailers themselves, however, the obligation to provide the button only becomes effective from June 19, 2026.
- December 18, 2023: EU Directive comes into force
- December 19, 2025: National implementation deadline ends
- June 19, 2026: Obligation for online retailers begins
Who is Affected?
The obligation applies to all entrepreneurs who conclude contracts with consumers in electronic commerce. This affects the vast majority of all e-commerce merchants in Germany.
| Affected | Not Affected |
|---|---|
| B2C shops selling goods | Pure B2B shops |
| Digital content (e-books, courses, streaming) | Contracts concluded offline |
| Marketplace sellers | Telephone sales, fax |
| Services booked online | On-site services |
If your B2B shop sells exclusively to business customers, you are not affected. However, as soon as private customers can also buy, the obligation applies.
Technical Requirements in Detail
The EU directive and German implementation set specific requirements for technical implementation. When programming the button, the following points must be observed:
Placement and Visibility
The button must be permanently visible, easily readable and clearly labeled. A global placement in the footer or main navigation is recommended - i.e. accessible on every page of the shop.
- Prominently placed (not hidden)
- Sufficiently large and high contrast
- Clearly distinguished from the rest of the design
- Also visible in the footer
- Accessible without login
Button Labeling
The labeling must be unambiguous. The recommended text is "Withdraw Contract" or similar wording that leaves no doubt.
Terms like "Cancel", "Abort" or "Service Request" are not permitted. They could be considered misleading and result in warnings.
The Withdrawal Form
After clicking the button, a form must open that enables withdrawal in simple steps. The following fields are typically required:
- Customer name
- Email address
- Order number or contract number
- Optional: Reason for withdrawal (not mandatory)
Mobile Optimization
The function must work flawlessly on all devices. During PageSpeed optimization, care should be taken to ensure that the button is clearly visible and clickable on smartphones and tablets. Technical barriers are not permitted.
The Withdrawal Workflow
The entire process must be simple and comprehensible for the consumer. Here is the ideal flow:
1. Click
Customer clicks "Withdraw Contract"
2. Form
Enter name, email, order number
3. Submit
Customer confirms withdrawal
4. Confirmation
Automatic email to customer
Confirmation must be provided immediately on a durable medium - in practice this means an automatic email directly after submitting the form.
Implementation by Shop System
The specific implementation depends on the shop system used. Here is an overview of the most common systems:
| Shop System | Status | Recommendation |
|---|---|---|
| Shopware 6 | Plugins expected Q1/Q2 2026 | Test early, check theme adaptation |
| WooCommerce | Plugins in development | Ensure theme compatibility |
| Magento | Custom development needed | Commission in time |
| Shopify | App solution expected | Monitor German market |
For Shopware shops, we expect official plugins or extensions in the first half of 2026. For WooCommerce, integration will likely be via plugins, with theme compatibility needing to be checked.
If no suitable plugin is available or special requirements exist, the withdrawal button can also be developed individually. Contact us for an assessment.
The Guest Checkout Problem
Guest purchases present a particular challenge. When customers order without a customer account, verification during withdrawal is difficult: How do you ensure that the person submitting the withdrawal is actually the buyer?
Possible solutions include querying the order number in combination with the email address or a confirmation link by email. The exact requirements for identity verification will become clearer in practice.
Consequences of Violations
Non-implementation or faulty implementation of the withdrawal button can have significant consequences:
- Warnings: Competitors and warning associations can issue costly warnings
- Administrative offense: Violations are classified as administrative offenses
- Fines: For merchants with at least 1.25 million euros annual turnover, fines of up to 50,000 euros are possible
- Cease and desist declarations: With contractual penalties for repetition
Experience shows that new legal obligations in e-commerce are intensively monitored by specialized law firms and competitors. A wave of warnings is to be expected in the first weeks after the deadline.
Preparation Checklist
To be prepared in time, we recommend the following steps - ideally several months before the deadline:
- Check withdrawal policy for currency and adjust if necessary
- Define button position in template (footer recommended)
- Define form fields and validation
- Set up automatic confirmation email
- Document internal workflows for withdrawal processing
- Inform employees about new process
- Perform mobile test on various devices
- Run through test order with withdrawal
Other Legal Changes in 2026
The withdrawal button is not the only change facing online retailers. 2026 brings further relevant innovations:
- BFSG (June 28, 2025):Accessibility becomes mandatory for many online shops
- Green Claims Directive (June 2026): Stricter rules for sustainability claims
- Temu regulations (July 1, 2026): End of grace period for direct shipping from China
If you need to make adjustments to the shop anyway, it may make sense to implement several legal requirements in one project.
Conclusion: Plan Now, Not in June
The withdrawal button is not a complex technical challenge, but it requires careful planning and implementation. The biggest risks arise from:
- Acting too late just before the deadline
- Incorrect labeling or placement
- Poor mobile support
- Missing automatic confirmation
Those who start planning now have enough time for testing and adjustments. Consulting by experienced e-commerce experts can help avoid typical mistakes and implement legally compliant.
For guest purchases, identity must be verified via alternative features, such as the combination of order number and email address. The exact requirements will develop in practice.
The button must be "permanently visible". A placement in the footer, which appears on every page, meets this requirement. It does not have to be placed above the fold.
Yes, the obligation also applies to digital content such as e-books, online courses or streaming services, provided there is a right of withdrawal. For immediately provided digital content, however, the right of withdrawal can be excluded.
Withdrawal is a statutory consumer right (14 days), cancellation refers to termination before contract fulfillment. The button must be clearly recognizable as a withdrawal option.
The existing model withdrawal form remains valid. The button is an additional digital way to declare withdrawal. However, the withdrawal policy should be supplemented with a reference to the button.
The obligation only applies from June 19, 2026. Before this date, no warnings are possible due to missing button. However, you should be prepared in time, as warnings typically come quickly after entry into force.
This article is based on EU Directive (EU) 2023/2673 and information from IT-Recht Kanzlei, Händlerbund and e-recht24.de. Fine information according to für-gründer.de. Status: January 2026.
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