Businesses in Germany can sell products or services through their own online stores. However, there are a number of requirements these online stores must meet to be legally compliant. A new requirement, obligating operators of online stores to provide customers with a contract withdrawal button, comes into force June 19, 2026.

In this article, you’ll learn what a withdrawal button is, what legal requirements it must meet, and how these requirements impact the design of online stores. We’ll also highlight common compliance mistakes and explain how to technically integrate a withdrawal button into your online store.

Key takeaways

• Starting June 19, 2026, online stores must provide electronic functionality enabling customers to withdraw from distance sales contracts entered into online.
  
• The withdrawal button is intended to make it just as easy for customers to withdraw from contracts online as it is to enter into them.
  
• This requirement is based on an EU directive and is implemented in German law through a revision of Section 356a of the German Civil Code (BGB).
  
• The withdrawal button must be clearly labeled, easily visible, and available throughout the contract withdrawal period (i.e., “cooling-off period”).
  
• It must be possible to withdraw from a contract directly via electronic means, and this withdrawal must be confirmed by the online store.
  
• This functionality must be integrated into existing store and backend systems so that contract withdrawals can be processed and assigned correctly.
  

What is a withdrawal button?

A withdrawal button is an electronic feature on websites or in apps that allows customers to withdraw from distance selling contracts entered into online. There is no explicit legal definition of a withdrawal button; the relevant legal regulations only talk more generally of a “withdrawal function.” Since this function is typically triggered by a clearly marked button, it has come to be known more generally as a “withdrawal button.”

The introduction of this functionality is intended to make it just as easy to withdraw from a contract as it is to enter into one—and in the case of online commerce, that usually takes only a few clicks. The withdrawal button represents an additional way in which customers can withdraw from a contract directly through the online interface, without having to resort to other means of communication. It’s not intended to replace other options—such as the ability to withdraw from a contract via email, mail, or withdrawal form—which will remain available.

Legal basis for mandatory withdrawal buttons

The obligation to provide a withdrawal button is based on Directive (EU) 2023/2673 which revises and updates the EU’s existing Consumer Rights Directive 2011/83/EU.

The aim is to achieve a consistently high level of consumer protection across all EU member states, and to improve user-friendliness in online commerce. At the same time, the requirement to provide a withdrawal button will help better align the processes involved in entering into and withdrawing from contracts.

Member states were obligated to pass the necessary national legislation by December 19, 2025. The regulations will come into force June 19, 2026.

Implementation in German law

In Germany, the new requirements were implemented through a revision to Section 356a of the German Civil Code (BGB). This provision obligates businesses to provide an electronic withdrawal function for distance sales contracts entered into through online interfaces. The previous wording of Section 356a of the BGB has been revised, and new regulations have been added concerning the electronic withdrawal function.

What requirements must a withdrawal button meet starting in 2026?

Starting June 19, 2026, the withdrawal button must fulfill certain basic requirements to enable customers to withdraw from a contract directly. The primary aim of the legal requirements is to ensure that this button has a clear design and is easy to use.

General visual requirements

• The withdrawal button must be easy to read and clearly labeled, for example with “Withdraw from contract” or equivalent wording.
  
• It must be available at all times throughout the entire withdrawal period (i.e., “cooling-off period”).
  
• It must be prominently positioned and easily accessible.
  

Functional requirements

• The withdrawal function must allow direct electronic submission of the notice of withdrawal.
  
• It should be relatively easy for customers to provide or confirm the following details: their name, the information required to identify the contract, and a method of communication for confirming receipt, e.g., an email address.
  

Two-click withdrawal

• After entering their information, customers must confirm their intent to withdraw by clicking a second button.
  
• This confirmation button must be clearly labeled, for example, with “Confirm withdrawal.”
  

Confirmation by the business

• Once a notice of withdrawal has been submitted, the business must confirm receipt immediately.
  
• This confirmation must be provided on a permanent medium, such as an email.
  
• It must contain at least the contents of the notice of withdrawal, as well as the date and time of receipt.
  
• If the notice of withdrawal is submitted in a timely manner using the withdrawal function, it’s deemed to have been received on time.
  

What requirements must an order button fulfill?

Withdrawal buttons and order buttons follow the same basic principle: customers should be able to clearly identify, at all times, the legal consequences of their actions. While the withdrawal button makes it easier to withdraw from a contract, the order button ensures that the contract is entered into consciously and with full awareness.

In Germany, the key legal requirements governing order buttons are set forth in Section 312j of the BGB. The “button solution” requires businesses to make the final step in the ordering process unambiguous. If an order is placed using a button, this requirement is only met if the button is clearly legible and explicitly indicates an obligation to pay—for example, by displaying “Order with obligation to pay,” “Order subject to payment,” or similarly clear wording. Ambiguous wording such as “Order” or “Continue” does not meet the legal requirements.

In addition to labeling requirements, the law sets forth further guidelines for the ordering process and order forms. Immediately before the order is submitted, all essential contractual information must be clearly summarized. This includes, in particular, the key features of the products or services, the total price, and the contract terms. This is intended to give customers the opportunity to review their information before they make a binding purchase. A clear button design—for example, through highlighting and a direct call to action—further enhances the transparency and clarity of the ordering process.

How will the withdrawal button impact the design of online stores starting in 2026?

The introduction of the withdrawal button in 2026 will require online stores to adapt their existing systems beyond the actual ordering process. While the legal requirements for the order button primarily concern the moment the contract is entered into, the withdrawal button extends the scope to include the cooling-off period following the purchase.

Integration into existing user areas

In practice, this primarily concerns the placement and visibility of the withdrawal function. It must be integrated into areas that users intuitively associate with their contracts. These include, in particular, customer accounts, order overviews, or individual order detail pages. Confirmation pages or emails can also be used to make access to the withdrawal function as simple as possible. Contract withdrawal must not be hampered by unnecessary obstacles, such as requiring additional registration if the contract was originally entered into without logging in. Hidden or hard-to-access solutions run counter to the statutory aim of easy access.

Impact on user navigation and structure

The withdrawal button also impacts how users are guided through the online store and how information is organized. Businesses must ensure that customers can easily find all essential contract details and that this information is straightforward and clear. In addition, it must be easy to identify which contract withdrawal corresponds to which order. This can be achieved, among other ways, by clearly labeling orders—for example, with order numbers or explicit details regarding the respective contract.

Holistic view of the order process

Overall, the integration of a withdrawal button underscores the growing importance of a consistent and transparent design throughout the entire lifecycle of a contract. Rather than ending once an order has been submitted, the payment process is expanded to include an easily accessible option to withdraw from the contract. In practical terms, this means that legal requirements and user experience must be aligned even more closely.

Common compliance issues with the withdrawal button in online stores

The introduction of the withdrawal button from 2026 onward means greater legal and technical requirements for operators of online stores. Even small errors in design or integration can result in noncompliance with legal requirements. In practice, there are several common problem areas that companies should address early on.

• Unclear or incorrect button labels
  Clear wording is necessary for compliance on both the order button and the withdrawal button. While the order button must clearly indicate an obligation to pay, the withdrawal button must be clearly recognizable as a means of withdrawing from the contract. Vague or overly general terms could call into question the legal validity of a contract.

• Hard-to-find withdrawal function
  The withdrawal functionality must be easy for customers to access and must not be “hidden.” Forcing users to search for a long time or making the function difficult to find runs counter to the fundamental principle of the legal regulation.

• Missing or incomplete process design
  In practice, businesses often overlook the fact that withdrawal must follow a structured flow. This includes, in particular, requesting or confirming relevant information, as well as providing explicit confirmation of receipt on a permanent medium.

• Inadequate technical implementation and system integration
  Technical shortcomings are also among the typical compliance risks. For example, contract withdrawals might not be transmitted correctly to internal systems, or confirmations might not be sent reliably. Issues can also arise if contract data can’t be clearly matched to an order or customer, resulting in errors in processing withdrawals.

• Insufficient traceability or improper documentation
  Finally, documentation is also an important consideration. Businesses must ensure that contract withdrawals can be clearly traced, in particular with regard to the timing and content of the notice of withdrawal. A lack of traceability could result in serious legal issues in the event of a dispute.

How is the withdrawal button integrated into an online store?

Complying with the new regulations requires integrating a withdrawal button into existing store and backend systems. This involves not only the visible frontend button but, above all, the processing of the withdrawal notice in the background. Online stores must ensure that the notice of withdrawal can be matched to a specific contract, securely stored, and reliably processed. At the same time, confirmations must be automatically generated and sent to customers.

In practice, the withdrawal function is typically integrated into existing user areas, such as customer accounts or order overviews. From a technical perspective, the process must be designed in such a way that, when the customer clicks the withdrawal button, the necessary data is captured, validated, and forwarded to internal systems. In particular, the process must be linked to order or contract databases and trigger the legally mandated confirmation of receipt. A robust interface architecture based on application programming interfaces (APIs) is key to avoiding media discontinuities and data loss.

How Stripe can help you implement compliant payment workflows

The introduction of the withdrawal button in 2026 affects not just the design of online stores, but also the underlying payment, billing, and order processes. Of particular relevance is the question of how legally compliant workflows can be efficiently integrated into existing payment and checkout structures.

Flexible billing models

Stripe offers payment, billing, and order processing features. With Stripe Billing, you can adapt payment and billing processes to various business models. These include recurring billing, usage-based models, and custom pricing structures.

With Billing, you can customize payment models, serve international markets, and optimize sales processes. Processes can be managed centrally and efficiently thanks to automated functions for payments, taxes, and billing. At the same time, revenue recovery and retention features help reduce failed payments and abandoned carts.

Checkout optimization

Meanwhile, Stripe Checkout adds a readymade, customizable payment interface that can integrate directly into websites or apps. Checkout enables an optimized, mobile-friendly payment process, simplifies implementation, and supports international payment methods as well as over 100 currencies. It also makes it easier to process sensitive payment data, helping you comply with security and regulatory requirements.

Marketplaces and platforms

If you process orders via marketplaces or platform models, contract withdrawals must be properly sorted and processed on those platforms as well—for example, using unique order IDs and automated confirmations. Stripe Connect helps platforms manage marketplace payments and payouts.

In combination, these solutions enable you to design checkout, payment, and order processes that are both user-friendly and scalable. At the same time, they help you comply with legal regulations in digital commerce and make it easier to implement new requirements, such as the mandatory withdrawal button.

FAQs

Below, we provide answers to frequently asked questions about the requirement to include a withdrawal button starting in 2026.