UK Order-Button Labels: 'Order and Pay' Rules in 2026

The button that places an order on a UK e-commerce checkout has a specific legal job. Under Regulation 14(3) and (4) of the Consumer Contracts Regulations 2013, the button must clearly communicate that placing the order obliges the consumer to pay. Get the labelling wrong and Regulation 14(5) makes the contract unenforceable, the consumer is not bound by the order. This guide covers what the rule actually says, what passes and what fails and how DMCCA 2024 changes the surrounding disclosures without changing the button rule itself.

For a scan of how your checkout flow actually meets UK consumer law, run a free check at /uk/en/scan.

What Regulation 14 actually requires

The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 implement the EU Consumer Rights Directive 2011/83/EU into UK law. The Regulations are retained EU law and remain in force after Brexit.

Regulation 14(3) says: "The trader must ensure that the consumer, when placing the order, explicitly acknowledges that the order implies an obligation to pay."

Regulation 14(4) says: "If placing an order entails activating a button or a similar function, the button or similar function must 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 the trader."

Regulation 14(5) is the consequence: "If the trader has not complied with paragraph (3) or (4), the consumer is not bound by the contract or order."

Three elements matter: the words must indicate payment obligation, the words must be easily legible and any equivalent UI element (a button, a tap target, a confirmation step) must satisfy the same requirement.

What passes and what fails

The Department for Business interpretation and Trading Standards practice across the UK have settled on a clear pass/fail line.

The German Bestellbutton-Lösung (order-button solution) under §312j BGB is stricter and effectively requires the literal words "zahlungspflichtig bestellen" or close variants. UK practice is more flexible but the underlying principle is the same: the consumer must understand at the moment of clicking that they are committing to pay.

What the price next to the button must show

Reg 6 and Reg 7 of the CCRs cover the pre-contract information that must be given before the order. The price information must reach the consumer before the button is clicked. The Regulations require:

The total price of the goods or services inclusive of taxes (the headline price the consumer sees) or where the price cannot be reasonably calculated in advance, the manner in which the price will be calculated. All additional delivery charges and any other costs. Where these cannot be reasonably calculated in advance, the fact that such additional charges may be payable.

The standard UK checkout pattern places this information on the order summary panel adjacent to the order button. The price total shown next to the button must match what the customer's card will actually be charged. Hidden fees added after the button click breach Reg 6 and trigger consumer remedies.

DMCCA 2024 codified drip pricing as a banned commercial practice. Mandatory charges that are added during the checkout flow rather than included in the headline price are now expressly prohibited. See DMCCA 2024 dark patterns enforcement for the broader CMA enforcement framework.

What about subscription contracts after DMCCA 2024

DMCCA 2024 introduced specific statutory rules on subscription contracts in Part 4. The rules apply from April 2025 and add three checkout-flow obligations on top of the existing Reg 14 button rule.

The pre-contract information must include the duration of the subscription, the price for each billing cycle, the consumer's right to cancel during the cooling-off period, the consequences of failing to cancel before the end of any free or discounted period and the reminder schedule the trader must follow before each renewal.

The cooling-off period is 14 days for most subscription contracts (matching the general distance-selling cooling-off right) and 30 days for renewal events that the consumer did not actively initiate.

The cancellation mechanism must be at least as easy as the signup mechanism. A signup that took two clicks cannot be paired with a cancellation that requires phoning during business hours.

For the broader DMCCA picture see DMCCA fines and enforcement in the UK and consumer cancellation rights under DMCCA 2024.

Sequence of disclosures around the button

The compliant sequence on a UK checkout, in order from top to bottom of the final page before the button, is:

1. Itemised list of goods or services being ordered, with quantity, unit price and line total per item.
2. Subtotal of goods or services.
3. Delivery and any other charges, itemised separately.
4. The total price the customer's card will be charged, in a font weight that is at least equal to the surrounding labels.
5. The button labelled with payment-obligation wording.

For digital content, additional pre-contract disclosures from CRA 2015 section 36 sit before the button: functionality of the digital content, technical protection measures and any interoperability information the trader knows about.

For services that the trader will start performing during the cooling-off period, the consumer must explicitly request that performance begin and acknowledge that the cancellation right will be lost once the service is fully performed. This sits adjacent to the button as a separate unticked checkbox.

What happens when the button label is wrong

Regulation 14(5) makes the contract unenforceable. The trader cannot demand payment from a consumer who clicked a button that did not communicate payment obligation. The practical consequences are:

The trader must refund any payment already taken without recouping it. The consumer can keep the goods if delivered (although the trader has separate property-law remedies for return of goods supplied without enforceable contract). Trading Standards can investigate as a Reg 14 breach and as a misleading-action breach under the Consumer Protection from Unfair Trading Regulations 2008.

Trading Standards investigations rarely escalate to fines for an isolated button-labelling failing if the trader corrects on notice. The risk is amplified where the labelling is paired with other failings (drip pricing, missing cancellation right disclosures, fake reviews). The CMA can take enforcement action under DMCCA 2024 for combined patterns and now has direct fining power up to £300,000 or 10% of global turnover.

How to audit your checkout

Open the final page before the order is placed in an incognito browser. Note exactly what the button says. If the wording is in the borderline or fail column above, change it before any other compliance work.

Inspect the price shown adjacent to the button. Confirm it includes all mandatory delivery, handling and tax. Compare with the amount actually charged at confirmation. Any difference is a Reg 6 issue.

For subscription contracts, check the disclosures match DMCCA 2024 requirements: clear billing-cycle price, free-trial-end date, cancellation route at least as easy as the signup route.

For digital content, confirm the section-36 CRA 2015 disclosures appear before the button.

For the broader UK e-commerce posture, see Consumer Rights Act 2015 disclosures and E-Commerce Regulations 2002 obligations.

---

This is technical analysis, not legal advice. For complex checkout architectures, subscription products or live Trading Standards engagement, take advice from a UK consumer-law specialist.

Sources

• Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (legislation.gov.uk)
• CCRs 2013 Regulation 14: additional payments under a contract (legislation.gov.uk)
• Consumer Rights Act 2015 (legislation.gov.uk)
• Consumer Rights Act 2015 section 36: information about digital content (legislation.gov.uk)
• Digital Markets, Competition and Consumers Act 2024 (legislation.gov.uk)