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authorLukas Ziegler
E-Commerce

Cancel in one click: This new rule hits online stores in 2026

Starting in 2026, online retailers must comply with new rules for digital cancellations. What the mandatory cancellation button means for your online store, which requirements apply, and what you should prepare now for a legally compliant implementation.

What’s behind the cancellation button?

Anyone shopping online can complete a contract in just a few clicks today. Cancelling that same contract, however, has been much more of a hassle so far: write an email, look for a form, wait for a reply. That’s changing.

Starting in Juni 2026, many companies that conclude contracts through an online shop will have to provide a digital cancellation function. The legislator’s goal is clear: cancellation must be just as easy and fast as completing the contract itself.

The legal basis is EU Directive 2023/2673. The German implementation act was passed by the Bundestag on 19. Dezember 2025 and published in the Federal Law Gazette on 5. Februar 2026. The new requirement is regulated in Section 356a of the German Civil Code and applies uniformly across the EU.

Cancellation button vs. termination button: Not the same

The termination button has already been around since 2022 (Section 312k of the German Civil Code). It applies to ongoing contracts such as subscriptions and memberships. The new cancellation button, by contrast, applies to one-time purchases and orders with a statutory right of withdrawal.

Heads up: If you’ve already implemented a termination button, you’re not done yet. Both functions must be clearly separated in the shop, because they have different legal consequences.

Who does this apply to?

It affects all companies that conclude b2c contracts through an online user interface. Specifically, this includes:
  • Online stores that sell goods to consumers
  • Providers of digital content such as e-books, online courses, or streaming services
  • Platforms with subscriptions, if a right of withdrawal applies
  • Providers of financial services such as loans or insurance
  • Shops on marketplaces such as Amazon or eBay
Chatbots and AI assistants may also fall under this requirement if contracts can be concluded through them.
It does not apply to purely b2b online stores, shops that exclusively sell custom-made products without a statutory right of withdrawal, or companies where the contract is only concluded after website contact by email, phone, or in person.

What implementation looks like in practice

In practice, the cancellation function consists of two consecutive elements: the cancellation button as the entry point and a dedicated cancellation form as the actual cancellation process.

The cancellation button

The cancellation button is the first step. Technically, it does not have to be a classic button - a clearly labeled and highlighted link also meets the legal requirement. What matters is that it:
  • is placed prominently, for example in the footer, but clearly highlighted and unmistakably labeled
  • uses the label "Cancel contract" or an equivalent wording
  • is accessible without login if the purchase was also possible without a customer account
  • remains available throughout the full 14-day cancellation period
  • works just as well on mobile devices as it does on desktop
  • is not obscured by pop-ups or other elements
Important: Vague or hidden labels such as "Contact" or "Service request" are not sufficient and are a classic legal warning risk.

The cancellation form

Clicking the cancellation button must take users directly to a cancellation form. Many online stores will use an adapted contact form for this. That is legally permissible, but it must be designed as a dedicated cancellation form and cannot simply be the existing general contact form with a new label. The form must:
  • make it possible to identify the contract, for example via name, order number, and email address
  • include a clearly labeled submit button, for example "Confirm cancellation"
  • automatically send a confirmation of receipt by email after submission, including the date and time of the cancellation
Important: Keep required fields to a minimum. The law requires compliance with the GDPR principle of data minimization. Only data that is truly necessary for the cancellation may be collected. A required field for the reason for cancellation is explicitly not permitted. A free-text message field as a required field is also problematic because it effectively creates a hidden obligation to justify the cancellation. The goal: a form with three to four fields and one confirmation button.

What else needs to be updated

The cancellation button itself is only one part of the task. In parallel, the following also need to be updated:
  • the cancellation policy (a legally required new text module that points out the digital cancellation option)
  • the privacy policy (new data collection in the cancellation process)
  • the terms and conditions
The upside: Starting in Juni 2026, the obligation to provide contract documents in paper form will also be removed at the same time. In the future, it will be sufficient to provide all contract information permanently in electronic form.

What happens if you do nothing?

The consequences of a missing or faulty cancellation function are significant. In addition to legal warnings from competitors and consumer protection associations - which experience shows tend to start shortly after the deadline - fines from supervisory authorities may also apply.

One risk is especially underestimated: if the cancellation function is missing or implemented unclearly, the cancellation period is automatically extended to 12 months and 14 days. Customers can then still validly cancel the contract more than a year after purchase without giving any reason and claim their money back.

What you should do now

The deadline is getting closer. To make sure you’re legally compliant by Juni 2026:
  • Check whether your shop is affected by the requirement (for b2c with a statutory right of withdrawal: almost always)
  • Implement the cancellation function technically, including a two-step process and automatic confirmation email
  • Have your cancellation policy, privacy policy, and terms and conditions updated by a legal expert
  • Test the function on desktop and mobile
  • Prepare internal processes for incoming cancellations
Note: The new cancellation function should only go live starting in Juni 2026. Preparing early makes sense - publishing it early does not.

We’re here to support your implementation 💚

Whether it’s an online store, digital platform, or ERP-side process updates: we at dc support you from requirements analysis to technical implementation. With experience from countless e-commerce projects, we help you implement the new requirements cleanly and on time. Feel free to reach out!
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