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E-learning and training sector

Withdrawal button for online courses

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MOOCs, e-learning, B2C coaching, video platforms: if you sell courses to consumers in the EU, the withdrawal-button obligation applies to you and has done since 19 June 2026. Specifics, classic pitfalls, and how it fits with CPF funding.

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Three types of course, three treatments

Course performed immediately (on-demand videos, ebooks)

The content is accessible as soon as it is bought. Without explicit consent and acknowledgement of the loss of their right of withdrawal, the customer can withdraw within 14 days after accessing all or part of the content. The digital-content exception (Directive 2011/83/EU, art. 16) extinguishes this right, provided you have two separate tick boxes at the point of purchase.

Course performed progressively (weekly modules, cohorts)

The content unfolds over several weeks or months. The 14-day period runs from the point of subscription. If the programme starts before the end of the 14 days, it is explicit consent that extinguishes the right. Otherwise, the customer can withdraw before the start and obtain a full refund.

One-to-one coaching by session

Each session is a distinct service. The exception for a fully performed service (Directive 2011/83/EU, art. 16) may apply if the session takes place within the 14 days following subscription, with the customer's explicit consent. Without that consent, the customer can withdraw even after a session, and you must refund.

The CPF-funding trap

Many training providers think that CPF-eligible or Qualiopi-certified courses escape the right of withdrawal. That is wrong for the B2C part. The contract is formed between you and the consumer who draws on their CPF rights. The Caisse des Dépôts (via Mon Compte Formation) is an intermediary payer, not a party to the training contract.

In practice, a learner who enrols on the 1st via Mon Compte Formation can withdraw up to the 15th. The refund follows the same route: you return the funds to the Caisse des Dépôts, which re-credits the learner's CPF account.

Without a compliant withdrawal button on your platform since 19 June 2026, the withdrawal period automatically extends to 12 months and 14 days. A course sold in July 2026 remains contestable until July 2027, CPF funding included.

Free and freemium courses

A 100% free course does not trigger the right of withdrawal: there is no contract for consideration. The button is therefore not mandatory on the free part. However, as soon as a premium module is offered as an in-app purchase, or a paid certificate is charged for, the 14-day period opens on the date of that purchase.

For mixed platforms (free + premium content), the withdrawal button must be accessible from any page of the site, not only from the premium purchase funnel. A permanent footer is the simplest solution.

Your sector has its own rules

The right of withdrawal applies differently depending on what you sell. See also:

Your sector is concerned: the proof that protects you, in place in five minutes

The withdrawal button is a European obligation (Directive (EU) 2023/2673) since 19 June 2026. BackToMe puts it in place, proves every request and applies the law of each EU country. 7-day free trial, 0 € today.