Germany is working on introducing a click-to-cancel button to facilitate the cancellation of online (purchase) agreements. For this purpose, the Bundestag passed into law on December 19, 2025.

The bill was early September Already approved by the German cabinet. With parliamentary approval, Germany is shaping European legislation aimed at consumer protection.

The new law stems from EU Directive 2023/2673 of 22 November 2023, which amends the existing Consumer Rights Directive (2011/83/EU). One of the changes is the introduction of a cancellation button, known in Germany as the "Widerrufsbutton."

Three-stage rocket for cancellations

According to German law, the electronic withdrawal procedure must consist of three steps. First, there must be an online button, which must be prominently displayed, permanently available, and easily accessible. There are requirements regarding the text on the button: "Cancel contract" or equivalent wording is mandatory. The button may not be hidden or linked to a login page.

In addition, a confirmation page must be presented to the customer (after clicking the button). There, the consumer can fill in or confirm mandatory information. This page, too, must include a button for submitting or confirming the cancellation. The company must then immediately confirm receipt of the cancellation on a durable medium, such as an email, stating the date, time, and content of the statement.

Penalties

The German legislature also immediately implemented sanctions for cases where the button is missing or malfunctioning. This is considered an administrative offense, subject to fines of up to €50.000. Companies with an annual turnover of more than €1,25 million can be fined up to four percent of their annual turnover.

For consumers, inadequate withdrawal policies from companies mean that the right of withdrawal can be extended or reactivated. The German E-commerce Magazine points out that even incorrect placement, unclear labeling, or a prematurely deactivated button can pose risks to businesses.

Status of implementation of EU Directive 2023/2673 in the Netherlands – Ziptone already wrote about this in October 2023 new European rulesMember states had until 19 December 2025 at the latest to transpose the EU directive into national law; EU member states are obliged to apply the new rules from 19 June 2026. In our country, the Council of State on September 29, 2025 It is recommended that the bill be submitted to the House of Representatives unchanged. It is not yet clear when the bill will be submitted and debated. It can still be amended, and then the bill must be approved by the Senate.

According to E-commerce Magazine, implementation still requires considerable effort. For example, the button must only be visible during the cancellation period. Systems must therefore recognize whether and when a right of cancellation exists. This is particularly challenging for guest orders without a customer account, as the button must be accessible without prior login. A permanently visible button can be misleading once the deadline has passed and may have consequences under competition law. Conversely, a button that disappears prematurely can lead to fines.

(zip tone)

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