Internet & Social Media Law Blog
A recent update to EU consumer law will require many businesses selling online to offer a simpler, more accessible way for customers to cancel contracts within the standard 14-day cooling-off period.
Under Directive (EU) 2023/2673, which amends the EU Consumer Rights Directive (2011/83/EU), traders who enter into “distance contracts” via online interfaces such as websites or apps—will need to provide a dedicated “withdrawal function.” This means consumers must be able to exercise their right of withdrawal through a clear, user-friendly mechanism, like a button or prominently labelled link (e.g. “Cancel my contract” or “Withdraw from contract here”).
When does it apply?
EU Member States must transpose the new rules into national law by Dec. 19, 2025. The obligation itself will apply from June 19, 2026.
Who is affected?
This requirement applies to any business selling goods, services, or digital content to EU consumers online—including one-off sales, subscriptions, and other remote or distance contracts.
Importantly, the new requirement does not change which contracts are covered by the 14-day withdrawal right—it only introduces a new way for consumers to exercise that right more easily. Contracts that are already excluded from the right of withdrawal remain unaffected. These include (among others):
- Fully-performed services, where the consumer gave prior consent and acknowledged they’d lose their right once performance was complete;
- Digital content (not supplied on a tangible medium) if performance has begun and the consumer gave clear consent and acknowledgment;
- Customized or perishable goods, like personalized items or fresh food;
- Sealed goods unsealed after delivery for hygiene or health reasons (e.g. cosmetics, certain medical products);
- Newspapers and periodicals (except subscriptions);
- Urgent home repairs, if specifically requested by the consumer;
- Public auction purchases; and
- Certain time-specific services, such as hotel bookings, car hire, catering or leisure activities.
The full list is found in Article 16 of Directive 2011/83/EU and remains unchanged by this new amendment.
What does the new rule require?
In essence, the law introduces a procedural requirement. Consumers must be able to withdraw using the same online interface where the contract was entered into—not just via email, post or downloadable forms. A compliant setup might include:
- A webpage hosting a digital withdrawal form, accessible through a clearly labelled link;
- The ability for consumers to submit their request online;
- An automated confirmation of receipt, including a timestamp and a copy of the submitted form.
While there’s no single “market standard” yet, these elements are likely to reflect regulatory expectations once Member States finalize implementation.
Why this matters
The right of withdrawal has been a core part of EU consumer law for a number of years, but this new rule makes it easier for consumers to exercise it without friction. For businesses, the key takeaway is that this isn’t a new right, but a new obligation to support that right digitally.
There’s no need to act immediately—but product, UX, and legal teams should start preparing now, particularly if your business:
- Operates in multiple EU markets;
- Sells through its own digital platforms; or
- Offers services or digital content where nuanced withdrawal rules already apply.
By building this requirement into long-term development plans, businesses can avoid last-minute compliance pressure and improve customer experience in the process.