Alert: “Cancel Contract” button to be provided for online consumer contracts.

2025 has been a year of significant change in the EU in many aspects of the law and there are more changes on the way with changes to the way in which consumers can contract and withdraw from contracts online.

Directive EU 2023/2673: What is this about?

The changes are being made by Directive (EU) 2023/2673 which amends the EU Consumer Rights Directive (2011/83/EU) (CRD).  Since this is a Directive (and not a Regulation like GDPR) it needs each country in the EU to bring these changes into local law.

The full name of this Directive is Directive EU 2023/2673 amending Directive 2011/83/EU as regards financial services contracts concluded at a distance and repealing Directive 2002/65/EC.  The name of the Directive references the fact that much of this Directive aims to expand the scope of the CRD to apply to distance financial services contracts.

That said, this new provision on the withdrawal function is not limited only to distance financial services contracts, it will apply to all distance contracts subject to the right of withdrawal under CRD.  

What is a distance contract?

A contract for goods or services that is concluded between a trader and a consumer (as opposed to B2B) without physical or face to face contact.  

An everyday example could be when a consumer places an order for a pair of shoes using a department store’s shopping app. Distance contracts can also be concluded via means such as telephone, email, websites, or even mail catalogues.

How does this new law change consumer contracts?

One of the amendments that this Directive makes to the CRD is to insert a new article on consumers’ right of withdrawal from distance contracts online.  Basically, when selling goods or services via an online interface, traders will have to provide consumers with a withdrawal function. The function must be easily legible, prominently displayed, easily accessible, and labelled “withdraw from contract here”, or in similarly unambiguous wording. For most distance contracts, the withdrawal period is the standard 14 days. 

Something like a “cancel contract” button on a website or app is generally thought to satisfy most of the above conditions. The aim of this provision is that consumers should be able to withdraw just as easily as they can conclude a distance contract.

This cancel contract button should be provided in addition to other existing means of withdrawal from the contract, such as a withdrawal form or statement.

What’s the process after a customer hits the cancel button?

The withdrawal function should enable the consumer to easily provide information about their name and the contract from which they want to withdraw. 

As a general rule the next steps would then be:

1. The consumer should then be able to confirm that withdrawal again in an easy and unambiguous manner.
2. After that the trader should send an acknowledgement of receipt of the withdrawal to the consumer without undue delay.
3. The trader processes the cancellation (although some exemptions could apply).

When does this come in?

EU Member States have until 19 December 2025 to adopt this Directive into their national law, and the measures will apply from 19 June 2026.

What are some Practical tips to think about now?

Given the lead time to make changes to websites, ordering processes etc anyone who sells online in the EU might want to think about the likely changes now.  That could include:

1. Updating or consulting the teams responsible for web design and user experience on how this function or button might look, and how it might change the website. Consider if the withdrawal function experience should differ if the consumer concluded the contract as a “guest” shopper or via a loyalty or membership account.
2. Reviewing your standard terms of business documents or contracts given to consumers.
3. Training or updating any relevant customer service teams.
4. Updating and potentially consulting with relevant finance and accounting teams (and possibly your auditors) as easier contract withdrawals may affect how and when revenue is recognised.
5. Regular horizon scanning to monitor developments in national laws in relevant EU countries.

More information

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