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Getting compliant

Withdrawal button: checklist for relevant distance contracts

By Anis Mokadym ·

In brief

Do you sell online to individuals? Your site must now display a button that lets your customers change their mind about their purchase. Complying with the withdrawal button (a European obligation, Directive (EU) 2023/2673, since 19 June 2026) comes down to three things: display on every page of your site a button that lets customers exercise their withdrawal online, send the customer an acknowledgement of receipt, and archive each request in a time-stamped way as proof. You can develop it in-house or install a turnkey solution like BackToMe, which covers these three points in a few minutes.

The seven steps below set out the full journey. Allow two to three weeks of work if you start from scratch, a few days with a ready-to-use solution. Tick as you go.

What changed on 19 June 2026

Before 19 June 2026
Since 19 June 2026
Withdrawal by post or email, at the customer's initiative
Dedicated online button, permanently accessible on the site
Optional model form provided in the terms and conditions
Mandatory technical function, in two clicks
Proof of the request borne by the consumer
Automatic acknowledgement of receipt on a durable medium
Contractual information (terms and conditions) alone
Terms and conditions information + technical device, combined

The 6 requirements of a compliant button

The button obligation (Directive (EU) 2023/2673) sets six cumulative conditions: a device that meets only some of them is not compliant.

01

Visibility and access

Easy to find and accessible throughout the withdrawal period, not only in the customer account area.

02

Entirely free

No fee or dissuasive process to exercise the right.

03

Unambiguous label

"Withdraw from contract", not "Cancel" or "Contact".

04

Two-click procedure

Pre-filled form, then "Confirm the withdrawal".

05

No account required

Usable also by guest customers (order without an account).

06

Acknowledgement on a durable medium

Time-stamped email the customer can keep, sent automatically.

The detail of the 6 requirements in the withdrawal-button guide

What you risk without a compliant button

Enforcement and penalties are set by each Member State. For widespread cross-border infringements, EU law also provides a common cooperation and enforcement framework.

Applicable national penalty

Under applicable law

The amount, competent authority and procedure depend on the Member State concerned. Widespread cross-border infringements also fall within the European cooperation framework.

Period where information is insufficient

Up to 12 months + 14 days

Insufficient information about the withdrawal right can extend the period under Directive 2011/83/EU, art. 10.

Details of penalties and enforcement

The checklist in 7 steps

1

Audit what you have

30 minutes

Identify which channels your brand uses for B2C sales: main site, subdomains, mobile app, marketplace presence. Check your current terms and conditions: do they already mention the withdrawal right? On what terms?

Run the diagnostic
2

Choose the solution (SaaS or in-house)

1 hour

Compare in-house development (3 to 6 months, 30 to 80 k€ TCO over 3 years) versus a compliant SaaS solution (5 minutes to integrate, from 25 € excl. VAT/month). The decisive criterion is not the price but the criticality of reaching the deadline with a tested device.

See the build vs buy comparison
3

Integrate the button across every interface

5 minutes to 2 days

One line of code on the main site (Shopify, WooCommerce, PrestaShop, Wix, bespoke). On the mobile app: webview, deep-link to the web page, or native screen with API. Test during the 7-day trial before deciding to subscribe.

Installation guides by CMS
4

Update your terms and conditions

1 hour

Add the mandatory pre-contractual clause on the existence and location of the button (information duties, Directive 2011/83/EU, art. 6). Specify who pays the return costs (Directive 2011/83/EU, art. 14: to be stated explicitly before purchase, otherwise borne by the merchant). Check consistency with the product pages.

Generate the terms and conditions clause
5

Calibrate the internal procedure

1 to 2 days

Designate the people responsible for handling (usually customer service). Document the full procedure: who receives the notification, within how many hours the case is opened, which response templates, how to trigger the refund (manual or automatic via PSP), how to archive.

Guide article
6

Train the support teams

half a day

Brief customer service: the legal deadlines (14 days to refund, otherwise an automatic surcharge), the illegitimate grounds for refusal that must NEVER be raised, the distinction between withdrawal / guarantee of conformity / after-sales service. Prepare an internal FAQ and pre-written email templates.

List of abusive refusals to avoid
7

Switch to legal mode without waiting

5 minutes (switch)

Activate legal mode (enforceable archiving + acknowledgement of receipt on a durable medium) as soon as the integration is tested. Since 19 June 2026, check that the function is available for the relevant distance contracts. On high-volume sites (>1000 orders/day), plan an observation phase in production.

How to install

Mistakes to avoid

  • Switching to production without a prior run-in : the first requests can arrive within the hour. Without upstream testing, exposure is guaranteed.
  • Thinking the terms and conditions are enough : the terms and conditions mention is mandatory BUT the functional button is a separate technical device, required in addition.
  • Forgetting the mobile app : the obligation covers all interfaces, mobile included. No exemption.
  • Underestimating the 14-day deadline to refund : without a well-oiled procedure, it is very short. The automatic surcharge starts on the 15th day.
  • Thinking that regularising after 19 June is enough : check the relevant contracts and the information provided. Insufficient information about the withdrawal right can extend the period under Directive 2011/83/EU, art. 10.

Recommended timeline

Period
Action
Week 1
Audit + choice of solution (steps 1-2)
Week 2
Technical integration + terms and conditions update (steps 3-4)
Week 3
Internal procedure + team training (steps 5-6)
Week 3-4
Switch to legal mode + production testing (step 7)
Before the switch
Internal communication, final check, stock status
After the switch
Heightened monitoring of the first requests, real-time adjustments

Frequently asked questions about the obligation

Is the withdrawal button really mandatory?

Yes, for distance contracts concluded through an online interface that are subject to the withdrawal right. Since 19 June 2026, the professional must provide a function enabling the consumer to exercise that right. The requirement comes from Directive (EU) 2023/2673 and applies across the 27 EU member states through national implementing rules.

Does the withdrawal button only concern financial products?

No. It covers distance contracts for goods or services concluded with consumers when they are subject to the withdrawal right, whatever the sector (Directive (EU) 2023/2673). Distance financial services follow a separate regime. Check the exceptions that apply to your own products or services.

Is a withdrawal link in the footer enough?

No. The function must be easy to find and accessible throughout the withdrawal period, including for a customer who ordered without creating an account. A link buried in the footer or in the terms and conditions, or hidden behind a "My account" area, does not meet that objective. The label must be clear ("withdraw from contract here") and the function available when managing the order.

If my products are exempt, do I still have to install the button?

Most often yes. The exceptions to the withdrawal right are conditional and assessed product by product (unsealed cosmetics, digital content with express waiver, genuinely perishable goods); they are set out in Directive 2011/83/EU (art. 16). If part of your catalogue gives rise to the right, provide the function for the relevant contracts and tell customers about any exception before purchase (art. 6). Fully exempt shops are rare.

Since what date has the withdrawal button been mandatory?

Since 19 June 2026, for online interfaces used to conclude distance contracts that are subject to the withdrawal right. Directive (EU) 2023/2673 sets the European framework; implementation is through each Member State's law.

What does a site without a compliant withdrawal button risk?

Enforcement and penalties are set by each Member State. For widespread cross-border infringements, EU law also provides a common cooperation and enforcement framework. Separately, insufficient information about the withdrawal right can extend the period by up to an additional 12 months (Directive 2011/83/EU, art. 10). The precise risk depends on the failure found and the applicable national law.

Is mentioning the withdrawal right in the terms and conditions enough?

No. A mention in the terms and conditions does not replace the function: for relevant contracts, it must be functional and easy to access, alongside the contractual information. The two aspects complement each other (Directive (EU) 2023/2673).

Who is concerned by the withdrawal button obligation?

Any professional concluding, through an online interface, B2C distance contracts that are subject to the withdrawal right, whatever the company's size or the platform used (site, marketplace, mobile app, etc.). Strictly B2B sales are not concerned.

Start the 7-day free trial

Five minutes to integrate the button. 7-day free trial: 0 € today, satisfied or your money back within 30 days. Switch to legal mode whenever you like, without waiting: the obligation is already in force.

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