Ecommerce Checkout Compliance: Netherlands Webshop Rules

Your checkout page is the most regulated page on your website. Ecommerce checkout compliance under Dutch consumer law covers what your order button says, how you display prices, what information you must provide before the sale and how consent checkboxes work. Get any of it wrong and your orders may not be legally binding under Dutch law.

This guide covers every requirement that applies to your Dutch webshop checkout. Not sure whether your checkout currently passes? Run a free scan and find out in 30 seconds.

The Dutch legal framework for checkout pages

The Netherlands transposes the EU Consumer Rights Directive (2011/83/EU) through the Burgerlijk Wetboek Boek 6, specifically through Articles 6:230l to 6:230v. These provisions govern the full lifecycle of a distance contract: what you must disclose before the sale, how the order must be confirmed and what rights the consumer retains after purchase.

The key enforcement body is the ACM (Autoriteit Consument en Markt), the Dutch authority for consumers and markets. Consumer information is published via ConsuWijzer, the ACM's public-facing guidance service. For any checkout elements that involve personal data, the Autoriteit Persoonsgegevens (AP) is the relevant authority under the AVG (GDPR).

Order button text: what Dutch law requires

Article 6:230v lid 3 of the Burgerlijk Wetboek transposes Article 8(2) of the Consumer Rights Directive into Dutch national law. The provision requires that the order button or equivalent mechanism clearly states that placing the order creates a payment obligation.

The Dutch legislator did not mandate one fixed phrase. Any formulation that unambiguously communicates "by clicking this button you are committing to pay" satisfies the requirement. In practice, certain labels are reliably safe and others are reliably non-compliant:

The ACM applies a plain-language test: a typical Dutch consumer reading the button label must immediately understand that clicking means paying. Vague labels that only imply a next step without referencing payment fail this test.

For the full breakdown including Dutch and cross-border examples, read our order button requirements guide.

Price display: BTW-inclusive totals are mandatory

Dutch consumer law and the Prijzenwet require that every price shown to a B2C customer includes BTW. Displaying a price excluding VAT and revealing the gross total only at the payment screen is not permitted.

The final checkout screen must show:

• Product price including BTW. The displayed price is the actual price. No footnotes reading "excl. BTW."
• Shipping and handling costs. All delivery charges must be visible before the customer reaches the order button. If the shipping cost depends on the chosen method, show each option with its price before checkout.
• All additional fees. Payment surcharges, gift wrapping, insurance, customs handling. Any amount that increases the total must be disclosed before the order is placed.

The rule is straightforward: the number the customer sees before clicking the order button must match the amount charged to their payment method. No surprises after the click.

Discount reference prices: the 30-day rule

If your checkout page shows a price reduction, the Omnibus Directive (2019/2161) applies. The reference price you show alongside any discount must be the lowest price you charged for that product in the 30 days before the discount period started. This rule has been part of Dutch law since January 2023.

The ACM enforces this actively. Dutch webshops caught using artificial reference prices face public enforcement decisions alongside financial penalties. For a full explanation including how progressive reductions work and exceptions for perishable goods, see our webshop compliance checklist for the Netherlands.

Pre-contractual information: what to show before the order button

Before the customer clicks the order button, BW 6:230l to 6:230n require you to make available a specific set of information. The checkout page is where most of this appears, either directly on screen or through clearly accessible links. Missing items have consequences that range from unenforceable contracts to an extended withdrawal window.

The required information:

1. Your business identity. Legal name, registered address and a contact method (phone number or email address). A contact form alone is not sufficient.
2. Main characteristics of the product or service. The order summary must describe what the customer is buying clearly enough to confirm the purchase without needing to navigate away.
3. Total price including all taxes and charges. As covered above.
4. Payment, delivery and performance details. Which payment methods you accept, expected delivery date or timeframe, and any performance deadline for services.
5. The 14-day withdrawal right. Customers must know they can cancel before they complete the purchase. Details follow in the next section.
6. Return shipping costs. If the customer bears the cost of returning goods after withdrawal, you must state this before the sale.
7. Contract duration and termination conditions. For subscriptions or recurring orders, the minimum commitment and the cancellation procedure.
8. Digital content functionality and compatibility. For downloads, streaming access or software, describe what the content does, which devices or operating systems it supports and any DRM restrictions.
9. KVK number and BTW-number. Dutch law requires your KVK registration number and BTW identification number to be visible throughout the checkout process. These must also appear on the order confirmation screen.

If you fail to inform the customer about the withdrawal right (item 5), the cancellation window extends automatically from 14 days to 12 months under BW 6:230o. This applies from the moment the contract is formed.

For KVK and BTW number placement requirements, see our KVK number requirements guide and VAT number display rules guide.

The 14-day withdrawal right disclosure

Dutch consumers can cancel any online purchase within 14 calendar days of receiving goods. No reason is required. This right derives from the Consumer Rights Directive and is non-negotiable for most categories.

Your checkout page must inform the customer of this right before the order is placed. A link to your returns policy is acceptable if the policy genuinely contains the required information, is easy to find and uses plain language. A clause buried in general terms and conditions does not satisfy the requirement.

What you must communicate at checkout:

• The customer has 14 days to withdraw from the contract
• How to exercise the right (email, online form or letter)
• Who pays return shipping costs
• The refund timeline: you must refund within 14 days of receiving the returned goods or proof of shipment, whichever is earlier
• A model withdrawal form or a direct link to one

Products exempt from the withdrawal right

Some categories are excluded. If you sell these, state the exclusion clearly on the product page and at checkout:

• Perishable goods (food, flowers, fresh products)
• Sealed hygiene products that have been opened (cosmetics, earbuds, personal care items)
• Custom-made or personalised items (engraved products, made-to-measure clothing)
• Sealed audio, video or software once the seal has been broken
• Hotel bookings, event tickets and transport tied to a specific date

If you are affected by the June 2026 rule introducing a mandatory digital withdrawal button for online services, see our webshop withdrawal button guide.

Digital products: waiving the withdrawal right at checkout

If you sell downloads, streaming access, software licences or other digital content, you can ask the customer to waive the withdrawal right, but only through a specific two-step process.

Before the customer clicks the order button, you must:

1. Obtain explicit consent for delivery starting immediately. A checkbox stating "I agree that delivery starts immediately" satisfies this step.
2. Obtain explicit acknowledgment that immediate delivery cancels the 14-day withdrawal right. A separate checkbox or a single combined checkbox with clear language works, provided both points are stated.
3. Confirm by email on a durable medium, repeating both the consent and the acknowledgment.

All three steps are required. Skipping one means the customer retains the full withdrawal right. In practice that means a customer can download your product and then claim a full refund within 14 days. Use two checkboxes with clear language at checkout or one combined checkbox that covers both points explicitly.

Consent checkboxes: what to keep separate

Terms and conditions

You must give customers a genuine opportunity to read your terms before they agree. A checkbox with a link to the full text is the standard approach. Pre-checking the box is illegal under Dutch consumer law. The customer must tick it actively.

Marketing and newsletter consent

Under the AVG and the Telecommunicatiewet, marketing consent at checkout must meet four conditions:

• Freely given. Newsletter signup cannot be a condition of completing the purchase. The customer must be able to buy without subscribing.
• Separate from other consents. The marketing checkbox must stand alone. Bundling it with the terms acceptance checkbox violates the AVG requirement for unbundled consent.
• Not pre-ticked. The checkbox must be empty by default. Active opt-in only.
• Specific. "We may contact you about our products" is too broad. "Receive our weekly offers by email" is specific enough to meet AVG standards.

If you collect consent for multiple channels (email, SMS, WhatsApp), each channel needs its own checkbox. A single checkbox covering all channels is not granular enough under the AVG.

The ODR platform link: remove it

Until July 2025, EU law required every webshop to include a link to the EU Online Dispute Resolution platform. That platform has been abolished under Regulation (EU) 2024/3228. If your checkout page, terms or footer still contains this link, remove it.

See our ODR platform removal guide for background and what to replace it with.

Checkout compliance checklist for Dutch webshops

Group your audit by category. Work through each section and note what needs fixing.

Order button and payment

• Order button contains a payment-obligation label ("Bestellen en betalen", "Kopen en betalen")
• Button text is not ambiguous ("Volgende", "Bevestigen" are not compliant)
• Order summary is visible on the same screen as the order button

Price display

• All prices shown to consumers include BTW
• Shipping costs visible before the order button
• No fees appear for the first time on the payment screen
• Discount prices show the 30-day prior lowest price

Pre-contractual disclosures

• Legal business name, registered address and direct contact method (phone or email) accessible during checkout
• KVK number visible throughout checkout
• BTW number visible throughout checkout
• 14-day withdrawal right communicated before purchase
• Model withdrawal form available via link or download
• Return shipping cost responsibility stated
• Subscription terms and cancellation procedure disclosed

Consent and data

• Terms and conditions checkbox is not pre-ticked
• Marketing signup is a separate, unchecked checkbox
• Digital content: consent to immediate delivery plus withdrawal waiver
• ODR platform link removed

If you are unsure whether your checkout page meets all of these requirements, run a free scan. Our website compliance scanner checks your checkout for button text, price display issues, consent problems and missing legal disclosures. It takes about 30 seconds and tells you what needs fixing.

For the complete Dutch webshop compliance picture beyond checkout, see our Dutch webshop compliance checklist and shipping costs disclosure guide.

Sources

• Burgerlijk Wetboek Boek 6 (wetten.overheid.nl)
• Prijzenwet (wetten.overheid.nl)
• Wet handhaving consumentenbescherming (wetten.overheid.nl)
• Directive 2011/83/EU - Consumer Rights Directive (eur-lex.europa.eu)
• Directive (EU) 2019/2161 - Omnibus Directive (eur-lex.europa.eu)
• Regulation (EU) 2024/3228 - repeal of ODR Regulation (eur-lex.europa.eu)
• Regulation (EU) 2016/679 - General Data Protection Regulation (eur-lex.europa.eu)
• Autoriteit Consument en Markt (acm.nl)
• ConsuWijzer - ACM consumer guidance (consuwijzer.nl)