From June 2026, the revocation button will be mandatory
The background is an EU consumer protection reform, which is being implemented in Germany through the new Section 356a of the German Civil Code (BGB). The aim of this regulation is to make contract cancellation just as simple for consumers as concluding an online contract itself. In future, contracts must be capable of being cancelled directly via the respective online user interface – without detours via emails, contact forms, or hard-to-find content.
For many online shops, this represents a clear change: the previous cancellation policy or a simple link in the footer will no longer be sufficient in future.
Content
Who the new regulation applies to
The new obligation to provide an online cancellation option applies wherever consumers conclude contracts online and a statutory right of withdrawal exists. This affects online shops selling goods as well as providers of digital content or services – regardless of company size or legal form.
Pure B2B offerings and services without a right of withdrawal, such as custom-made products, are excluded. However, for shops with a mixed assortment the following applies: as soon as even a single product is offered that can be cancelled, the electronic cancellation function must generally be made available.
"Cancelling a contract should be just as easy as ordering online – with a single click."
Requirements for placement and visibility
The cancellation button must be clearly visible, easy to access, and easy to read. A hidden link in a long list of footer links is generally not sufficient. While placement in the footer is not completely excluded, it is subject to higher requirements in terms of design and visual distinction. What matters is that users can actually find it without difficulty.
Cancellation in practice: two-step and unambiguous
A key element of the new requirements is the two-step cancellation process. The cancellation must not be triggered by the first click alone.
Typical process
- Click on “Cancel contract”
- Redirect to a dedicated page with a form
- Completion via a second button, e.g. “Confirm cancellation”
Only this second click transmits the cancellation notice with legal effect.
Which details are permitted
- Name of the consumer
- Contract or order number
- Contact details for the confirmation of receipt (e.g. email)
A reason for the cancellation must not be requested as a mandatory field.
What needs to happen after submission
After clicking “Confirm cancellation”, an acknowledgement of receipt must be sent without delay on a durable medium, typically via automated email. This confirmation must not create the impression that the cancellation has already been reviewed or accepted.
Availability, access, and accessibility
The cancellation function must be available throughout the entire statutory withdrawal period. Permanent display is permitted, provided that the applicable deadlines are clearly communicated. Accessibility requirements (contrast, readability, usability) should also be taken into account. In addition, cancellation must be possible for guest orders without requiring registration.
What this means for online retailers
The cancellation button is not just a legal issue. It affects UX, technology, and processes equally.
Conclusion
Even though the obligation will not apply until 2026, online retailers should start addressing the cancellation button early. The requirements are clear, but implementation is demanding. Those who plan now avoid last‑minute pressure and can align legal compliance with a user-friendly experience.
When does the obligation to withdraw button apply?
The obligation applies from June 2026. From that point on, online retailers who conclude contracts with consumers via an online user interface must provide an electronic cancellation function.
Who is the rule – and are there exceptions?
All B2C offerings with a statutory right of withdrawal are affected (regardless of company size or revenue). Excluded are pure B2B contracts and constellations without a right of withdrawal (e.g. custom-made products, perishable goods).
Does it have to be a button?
No. Legally, what is required is a “cancellation function”. In practice, this is usually implemented as a button, but a clearly highlighted link can also be sufficient – the decisive factors are visibility and ease of access.
How must the revocation be technically?
Two-step: the first click (“Cancel contract”) leads to a separate page with a form. Only the second click (“Confirm cancellation” or an equivalently clear label) actually submits the cancellation notice.
What has to happen after the send?
The retailer must send an acknowledgement of receipt without delay on a durable medium (typically email). This confirms receipt of the cancellation, not its substantive review.