Webshop Withdrawal Button Requirement: What Changed on June 19, 2026

EU Regulation 2023/2673, which amends the Consumer Rights Directive (2011/83/EU), introduces a new requirement for online service providers: a digital button through which consumers can exercise their right of withdrawal (herroepingsrecht). The deadline for implementation is June 19, 2026.

The Background: The Right of Withdrawal

Under Dutch consumer law (implementing the Consumer Rights Directive), consumers who purchase online have a 14-day cooling-off period during which they can withdraw from the contract without giving a reason. This applies to:

• Distance contracts (purchases made online, by phone, or by catalogue)
• Off-premises contracts
• Most B2C purchases of goods and services

For digital services and subscriptions specifically, the right of withdrawal exists for 14 days from the date the contract is concluded — unless the consumer has explicitly consented to immediate delivery and acknowledged that the right of withdrawal is lost upon commencement.

The withdrawal right does not apply to:

• Custom-made goods
• Perishable goods
• Goods that cannot be returned for hygiene reasons after opening
• Fully delivered digital content where the consumer consented to immediate delivery
• Some service contracts fully performed before the withdrawal period ends

What Regulation 2023/2673 Adds

Before this regulation, exercising the right of withdrawal typically required consumers to:

• Find the withdrawal form in the seller's terms and conditions
• Send an email or letter
• Fill out a paper withdrawal form

Many consumers did not exercise their rights because the process was deliberately or accidentally made complicated.

Regulation 2023/2673 (Article 11a of the amended Consumer Rights Directive) requires that if a trader provides an online interface (website or app) through which the consumer concluded the contract, the trader must provide a button or equivalent function allowing the consumer to exercise the right of withdrawal online.

Technical Requirements for the Withdrawal Button

The regulation requires:

1. A clearly labelled button — must be labelled something equivalent to "Cancel contract here" or "Withdraw here" (Dutch: "Herroep hier" or "Opzeggen"). Generic buttons like "Contact us" are not sufficient.

2. Single-step access — the consumer must be able to reach the withdrawal function in no more than two navigation steps from the interface where the contract was concluded (typically their account or order history page).

3. Electronic confirmation — upon using the button, the consumer must immediately receive an electronic acknowledgement of their withdrawal on a durable medium (email confirmation is standard).

4. No additional hurdles — the button must actually process the withdrawal. You cannot require consumers to also call, email, or wait for a response before the withdrawal is confirmed. A "request to cancel" that requires your approval is not compliant.

5. Availability — the button must be available during the entire withdrawal period (14 days from contract conclusion).

Who This Affects

Primarily affected:

• SaaS products with consumer subscriptions (software, streaming, cloud storage)
• Digital content providers (e-books, music, video — if withdrawal still applies)
• Online course and education platforms
• Gym membership apps
• Any subscription-based online service sold directly to consumers

Also affected:

• Webshops where consumers can initiate returns online (the button facilitates withdrawal for goods too, though goods returns via post remain valid)

Less directly affected:

• Physical product webshops where the return process is entirely by post (the existing written/email withdrawal process remains valid for goods if consumers can also use it electronically)

The ACM (Autoriteit Consument & Markt) is expected to clarify scope in guidance. The safest interpretation: any platform through which a consumer concluded a contract that carries a withdrawal right should implement the button.

Implementation: What You Need to Build

For a typical subscription service:

1. In the user account dashboard: A clearly labelled button "Cancel subscription" or "Withdraw from contract" — positioned prominently, not buried in settings.

2. The button triggers: A confirmation screen that explains what withdrawal means (contract ends, refund if applicable, data deletion timeline).

3. After confirmation: An immediate email confirmation to the consumer stating that their withdrawal has been received and the cancellation date.

4. Record keeping: Log the withdrawal with timestamp, for your own records and for ACM audit purposes.

Example flow:

1. Consumer logs into account → Account page has "Cancel subscription" button (one click)
2. Consumer clicks → Confirmation screen: "Are you sure? Your subscription ends on [date]. You will not be charged further. Click 'Confirm withdrawal' to proceed."
3. Consumer clicks "Confirm" → Subscription cancelled immediately, email sent
4. Consumer is on "Subscription cancelled" page with details

The entire process: 2–3 clicks maximum, no contact with a human required, immediate effect.

Shipping Cost Disclosure (Related Requirement)

Also effective from July 2025 (ACM enforcement), webshops must clearly display the full shipping cost before the consumer enters checkout. This came into force earlier but is sometimes missed:

• Shipping costs must appear on the product page or category page, not just in the cart
• "Calculate in cart" is not compliant if the consumer has no indication of shipping costs before adding to cart
• Country-based shipping rates must be selectable before checkout

The ACM has issued guidance and begun enforcement on shipping cost transparency as part of its broader e-commerce consumer rights focus.

ACM Enforcement

The ACM is the enforcement authority for consumer rights law in the Netherlands under the Wet handhaving consumentenbescherming (WHC). Since 2024, the ACM has increased enforcement in e-commerce:

• In 2024–2025, the ACM focused on hidden fees, fake countdown timers, and subscriptions that are difficult to cancel
• The "subscription trap" problem (moeilijk opzegbare abonnementen) has been a priority — services that make cancellation deliberately difficult
• The withdrawal button requirement directly addresses this — it is a response to widespread non-compliance with the right of withdrawal

Maximum fine under WHC: €900,000. For consumer rights violations in e-commerce, the ACM typically starts with a compliance order (last-uiting) before imposing a fine.

Checklist: Preparing for June 19, 2026

• Identify every online service you offer where the right of withdrawal applies
• For each: locate where in your account/portal the consumer concluded the contract
• Design and implement a clearly labelled withdrawal button accessible from that area
• Implement immediate email confirmation of withdrawal
• Test the entire flow end-to-end as a consumer
• Update your terms and conditions to reference the digital withdrawal mechanism
• Update your privacy policy if withdrawal triggers data deletion

For broader e-commerce compliance, read our webshop compliance guide for the Netherlands and the shipping costs disclosure requirements.

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This article is technical analysis, not legal advice. Consult a lawyer for advice specific to your situation.