Order Button Requirements for Dutch Webshops

Your checkout button probably says "Place Order" or "Bestelling plaatsen." Under Dutch law, that is not good enough. The button text must clearly show the customer is about to pay. Get it wrong and the customer may not owe you anything at all.

You can run a free compliance scan on your checkout right now to see whether your current button text meets the Dutch legal standard.

What Dutch law requires

The Dutch legal basis for order button wording is Burgerlijk Wetboek Boek 6 Article 6:230v lid 3 (BW 6:230v lid 3). It transposes Article 8(2) of the EU Consumer Rights Directive 2011/83/EU into Dutch national law.

The directive text that drives the button requirement:

The trader shall ensure that the consumer, when placing his order, explicitly acknowledges that the order implies an obligation to pay. If placing an order entails activating a button or a similar function, the button or similar function shall be labelled in an easily legible manner only with the words "order with obligation to pay" or a corresponding unambiguous formulation indicating that placing the order entails an obligation to pay to the trader.

Article 8(2) Consumer Rights Directive 2011/83/EU

The Dutch implementation in BW 6:230v lid 3 mirrors this wording directly. The phrase "corresponding unambiguous formulation" is what gives Dutch courts and the ACM room to judge button text case by case, but the safe harbour is always a label that combines the act of ordering with a clear payment reference.

Which button labels are compliant in the Netherlands

The table below shows the labels that satisfy BW 6:230v lid 3 and those that do not:

The pattern is consistent: any label that omits the word "betalen" (pay) or an equivalent payment signal fails the test. Courts and regulators read button labels the way a consumer would, not the way a developer intended.

Who enforces this in the Netherlands

The ACM (Autoriteit Consument en Markt) is the Dutch market regulator responsible for enforcing consumer contract rules, including BW 6:230v. Consumer-facing guidance is also published by ConsuWijzer, the ACM's information service for consumers.

The ACM's enforcement toolkit under the Wet handhaving consumentenbescherming (Whc) includes:

• Fines of up to EUR 900,000 per infringement
• A higher cap of 4% of global annual turnover for cross-border infringements falling under the EU Consumer Protection Cooperation (CPC) Regulation
• Orders to correct non-compliant checkout pages
• Publication of enforcement decisions

In practice the commercial risk arrives before any fine. A non-compliant button label means the consumer is not legally bound by the contract. That translates directly to lost payment claims, chargebacks you cannot defend and returns you must accept even outside the normal 14-day withdrawal window.

The ACM has named checkout transparency and dark patterns as active enforcement priorities in its consumer law programme. Button-labelling sits within that scope.

How other EU countries implement the same rule

The Article 8(2) requirement runs across every EU member state, though some national implementations are worded more strictly than others.

Germany has the largest body of published case law on this point. The Bundesgerichtshof (Federal Court of Justice) has consistently held that a button label creates a valid payment obligation only when the wording is unambiguous to an average consumer. Labels like "complete order" (Bestellung abschließen) failed that test because consumers could reasonably read them as completing a form rather than committing to pay. The Dutch legal standard carries the same underlying test from Article 8(2), even though fewer Dutch rulings are published.

What happens if you get it wrong

A non-compliant button label has two layers of consequence.

Contract validity. Under BW 6:230v lid 3 a consumer is not bound by the order if the button did not clearly indicate a payment obligation at the moment of clicking. You delivered the product. The consumer has no legal obligation to pay. Reclaiming the product or the payment becomes a civil dispute.

Regulatory exposure. A complaint to the ACM or ConsuWijzer triggers an investigation. The ACM can act on a single complaint and does not require evidence of systematic non-compliance before opening a case. The fine cap of EUR 900,000 applies per infringement, and each affected transaction can constitute a separate infringement.

What e-commerce platforms ship by default

Most platforms do not ship with compliant Dutch button text. The table below shows the defaults and where to change them:

Never assume the platform default is correct. Open your checkout in a private browser window and read the button before every platform upgrade or translation plugin update.

How to fix your button text

Shopify

1. Go to Settings > Languages in your Shopify admin
2. Click your store language
3. Search for "Place order" or "Bestelling plaatsen"
4. Replace with "Bestellen en betalen" or "Bestelling met betalingsverplichting"
5. Save and preview your checkout page

WooCommerce

Add this to your theme's functions.php or a custom plugin:

add_filter('woocommerce_order_button_text', function() {
    return 'Bestellen en betalen';
});

For multi-language shops using WPML or Polylang, set the translation for each language separately. Dutch customers must see the compliant Dutch label.

Lightspeed

1. Go to Settings > Web texts in your Lightspeed back office
2. Find the checkout button text field
3. Update to "Bestellen en betalen"
4. Save and preview your checkout page

Any other platform

Look for checkout customisation options in your platform's settings. Search for "order button text" or "checkout button" in the documentation. If your platform does not expose button text as an editable field, raise it with their support team. This is a legal requirement, not a preference.

The rest of your checkout page

The order button is one part of a compliant Dutch checkout. The full set of pre-order disclosures also requires:

• Your KVK number and registered business address. Read our guide on KVK number requirements for exactly what to display and where on the page.
• VAT-inclusive pricing and shipping costs shown before the final button, not revealed after clicking it. See our guide on shipping costs disclosure for the full requirement.
• A link to your terms and conditions that the customer can read before ordering.
• Your withdrawal policy (14-day right of withdrawal for most consumer goods) stated clearly on the checkout page.

For a complete overview of Dutch webshop legal requirements, see our webshop compliance guide for the Netherlands.

Check your checkout now

The fastest way to find out whether your button text is compliant is to test it. Open your webshop in a private browser window, add a product to your cart and go to the final checkout step. Read the button label. Does it clearly say you are committing to pay?

If you are not certain, use the free compliance scan to check your checkout button and other Dutch consumer law requirements in one pass.

Frequently asked questions

Can I just add "with payment obligation" in small text near the button instead of changing the button itself?

No. Article 8(2) of the Consumer Rights Directive and BW 6:230v lid 3 both specify that the button or similar function must carry the message. Text near the button is not the button. Some shops place a note directly above the button as an extra signal, but that does not substitute for the label on the button itself.

Does this apply to B2B sales too?

The Consumer Rights Directive applies to business-to-consumer (B2C) transactions. If you sell exclusively to other businesses, BW 6:230v lid 3 does not apply. But if your shop serves both consumers and businesses, you need compliant button text for all orders since you cannot always distinguish B2B from B2C at checkout.

What about subscription services and recurring payments?

The same rule applies to the initial order. If you are signing someone up for a subscription, the button must indicate they are committing to pay. Many subscription businesses add extra clarity with labels like "Start paid subscription" or "Subscribe and pay now." That level of clarity is good practice and consistent with what the directive requires.

My shop is in English but I sell to Dutch consumers. Which rules apply?

Dutch consumer law applies based on where the consumer is located, not the language of the shop. If your customer is in the Netherlands, BW 6:230v applies to their order. For English-language shops selling to Dutch customers, "Order with payment obligation" or "Buy and pay now" satisfy the requirement. Generic labels like "Place order" or "Confirm" do not.

Will my payment provider or platform warn me about this?

Payment providers like Mollie, Stripe and Adyen process payments but do not audit your checkout page for legal compliance. Platforms like Shopify and WooCommerce supply the tools but leave legal responsibility with the shop owner. Checking your button text is your responsibility.

Sources

• Directive 2011/83/EU — Consumer Rights Directive (Art. 8(2)) (eur-lex.europa.eu)
• Burgerlijk Wetboek Boek 6 — Art. 6:230v (wetten.overheid.nl)
• Wet handhaving consumentenbescherming (wetten.overheid.nl)
• Autoriteit Consument & Markt (acm.nl)
• Directive (EU) 2019/2161 — Omnibus / Modernisation (eur-lex.europa.eu)