Since June 19, 2026, online shops in Germany need a withdrawal function wherever consumers have a right of withdrawal for the contract. Directive (EU) 2023/2673 requires merchants to provide a simple digital way to exercise that right; in Germany it is implemented in Section 356a of the Civil Code (BGB). Those who fail to meet the requirements risk warnings.
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 withdrawal period remains unchanged.
Section 356a BGB prescribes a two-stage process: through the withdrawal function the customer makes the declaration and provides the required information. The customer then sends it via a separate confirmation function. After that, the customer receives an acknowledgement of receipt on a durable medium without undue delay, in practice by email.
Legal Basis and Timeline
The basis is Directive (EU) 2023/2673, which came into force on December 18, 2023. The deadline for transposition into national law ended on December 19, 2025. Germany implemented the rules with the Act of 3 February 2026 (BGBl. 2026 I No. 28), which rewrites Section 356a BGB. For online retailers, the obligation to provide the withdrawal function has applied since June 19, 2026.
- December 18, 2023: Entry into force of the EU Directive
- December 19, 2025: End of the national transposition period
- June 19, 2026: Start of the obligation for online retailers under Section 356a BGB
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
Section 356a(1) BGB requires the withdrawal function to be permanently available, prominently placed and easily accessible throughout the withdrawal period, with a clearly legible label. A fixed spot in the footer or main navigation makes it reachable on every page of the shop. Whether it is also prominent enough there depends on the design.
- Prominently placed, not hidden among equal-ranking text links
- Clearly legible: sufficiently large and high contrast
- Reachable on every page, for example in the footer or main navigation
- Available throughout the withdrawal period
- Accessible without login, including for guest orders
Button Labeling
The law names a label for each stage: "Vertrag widerrufen" (withdraw contract) for the withdrawal function and "Widerruf bestätigen" (confirm withdrawal) for the confirmation function. Another equivalent unambiguous wording is also permitted in each case. Using the words of the law avoids any dispute about equivalence.
Terms like "Cancel", "Abort" or "Service Request" are not readily equivalent to "withdraw contract". Such a label does not reliably meet the requirement and can be grounds for a warning letter.
The Withdrawal Form
Through the withdrawal function, the customer must be able to make the withdrawal declaration and provide or confirm the following information (Section 356a(2) BGB):
- Customer name
- Information identifying the contract, for example the order number
- Electronic means of communication for the acknowledgement of receipt, usually the email address
- Reason for withdrawal at most as a voluntary field, no justification is needed
Mobile Optimization
The function must work on all devices. During PageSpeed optimization, care should be taken to ensure that the button is clearly visible and usable on smartphones and tablets. A link that disappears into a collapsed menu on mobile should be checked against the "prominently placed" requirement.
The Withdrawal Workflow
The entire process must be simple and comprehensible for the consumer. This is the flow under Section 356a BGB:
1. Withdraw
Customer selects "Vertrag widerrufen"
2. Details
Name, contract, email address for the acknowledgement
3. Confirm
Customer sends via "Widerruf bestätigen"
4. Acknowledgement
Without undue delay by email, with date and time
The acknowledgement of receipt must arrive without undue delay on a durable medium and contain at least the content of the withdrawal declaration as well as the date and time of its receipt. In practice this is an automatic email directly after submission. For the deadline, what counts is sending: whoever sends via the function before the period ends has withdrawn in time.
Implementation by Shop System
How the withdrawal button gets into the shop depends on the shop system. The overview shows the implementation route and what you should check for each solution:
| Shop System | Implementation Route | What to Check |
|---|---|---|
| Shopware 6 | Core feature since 6.7.9.0, backport to 6.6 | Integration in your own theme, labels, acknowledgement of receipt |
| WooCommerce | Extension or custom development | Both stages, required details, email with date and time |
| Magento | Extension or custom development | Placement in the theme, guest orders, acknowledgement of receipt |
| Shopify | App or theme adaptation | German labels, accessibility without login |
For Shopware shops, the withdrawal function has been part of the core system since version 6.7.9.0 from April 2026, was backported to Shopware 6.6 and is also available in the Community Edition. Like the contact form, the revocation form can be placed via Shopping Experiences. In the standard storefront the button is integrated; with custom templates and third-party or headless frontends, the visible integration has to be implemented project-specifically. For WooCommerce (WooCommerce agency) and other systems: check every extension against Section 356a BGB before use, especially both labels and the acknowledgement of receipt. What this looks like in Shopware in practice is covered in the article on the technical setup of the withdrawal button in Shopware.
If the standard solution does not fit the theme, a custom frontend is in use or special processes exist, the withdrawal function 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?
The law itself asks for less than one might expect: Section 356a(2) BGB only names the name, information identifying the contract and the electronic means of communication for the acknowledgement of receipt. The provision does not provide for an identity check before sending. Matching the withdrawal to the order, for example via order number and email address, therefore belongs in processing after receipt. Additional hurdles before sending, such as a login or a confirmation link, should be checked against the requirement that the function be easily accessible.
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: Art. 246e § 1(2) No. 14a EGBGB covers a missing or non-compliant withdrawal function and a missing acknowledgement of receipt. It is prohibited and subject to fines as a widespread infringement within the meaning of Regulation (EU) 2017/2394.
- Fines: Under Art. 246e § 2 EGBGB the range reaches up to 50,000 euros, and above 1.25 million euros in annual turnover up to 4 percent of annual turnover. Fines are imposed only within a coordinated enforcement action by several authorities in the EU.
- Cease and desist declarations: With contractual penalties for repetition
New legal obligations in e-commerce are watched by specialized law firms and competitors. A missing or incorrectly labeled withdrawal function is easy to spot from the outside: it is either on the page or it is not.
Implementation Checklist
For the implementation and for checking an existing solution we recommend the following steps:
- Add the reference to the online function to the withdrawal policy (design note 33)
- Define the button position in the template: prominent and reachable on every page
- Define form fields under Section 356a(2) BGB, reason only voluntary
- Set up the acknowledgement of receipt with content, date and time
- Document internal workflows for withdrawal processing
- Inform employees about new process
- Perform mobile test on various devices
- Run through a test order with withdrawal and check both labels
Other Legal Changes in 2026
The withdrawal button is not the only change for online retailers. These obligations also affect the shop template:
- BFSG (since June 28, 2025): Accessibility is mandatory for many online shops
- EmpCo transposition in competition law (start of application 27 September 2026): Stricter rules for sustainability claims and eco-labels
If you need to make adjustments to the shop anyway, it may make sense to implement several legal requirements in one project.
Check the Implementation Instead of Waiting
The withdrawal button is not a complex technical challenge, but it requires careful planning and implementation. Risks arise mainly from:
- Acting only after the first warning letter
- Incorrect labeling or placement
- Poor mobile support
- Missing automatic confirmation
Checking your own solution against the requirements of Section 356a BGB reveals gaps before a warning letter does. A technical review as part of a consultation uncovers typical errors in placement, labeling and acknowledgement of receipt; the legal assessment of individual wordings belongs with a lawyer.
Section 356a(2) BGB only requires the name, information identifying the contract and the electronic means of communication for the acknowledgement of receipt. The provision does not presuppose a customer account. Matching the withdrawal to the order, for example via order number and email address, belongs in processing after receipt.
The law requires the withdrawal function to be permanently available, prominently placed and easily accessible throughout the withdrawal period. A fixed spot in the footer or main navigation makes it reachable on every page. Whether it is prominent enough there depends on the design; an inconspicuous text link among equal-ranking links should be checked against the requirement.
Yes, the obligation also applies to digital content such as e-books, online courses or streaming services, as long as a right of withdrawal exists. For digital content not supplied on a tangible medium, the right of withdrawal can expire early under certain conditions, for example after the customer has expressly consented to immediate supply.
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 model withdrawal form in Annex 2 to the EGBGB remains part of the information obligations. The Act of 3 February 2026 did, however, amend the model withdrawal policy: anyone who must provide a withdrawal function adds, under the new design note 33, where the function can be found and that an acknowledgement of receipt follows.
The obligation has applied since June 19, 2026. For the period before that, a warning letter for a missing button was not an option. Since then, a missing or incorrectly labeled withdrawal function can be grounds for a warning letter.
This article is based on Directive (EU) 2023/2673, Section 356a BGB and Art. 246e EGBGB as amended by the Act of 3 February 2026 (BGBl. 2026 I No. 28), and on the Shopware release notes and information on version 6.7.9.0. Status: September 2026.