One-click cancellation: This new rule will impact online stores from 2026

What is behind the cancellation button?

When people shop online, they can complete contracts in just a few clicks. Canceling that same contract, however, has been much more complicated until now: write an email, look for a form, wait for a response. That is changing.

Starting in June 2026, many companies that conclude contracts via an online store will be required to provide a digital cancellation function. The legislator's goal is clear: cancellation must be just as easy and fast as entering into the contract itself.

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

Cancellation button vs. termination button - not the same

The termination button has already existed since 2022 (Section 312k BGB). 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 have already implemented a termination button, you are not done yet. Both functions must be clearly separated in the store because they have different legal consequences.

Who does this apply to?

It applies to all companies that conclude b2c contracts via 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 exists
• Providers of financial services such as loans or insurance
• Stores on marketplaces such as Amazon or eBay

Chatbots and AI assistants can also fall under this requirement if a contract is concluded through them.
It does not apply to purely b2b online stores, stores offering only custom-made products without a statutory right of withdrawal, or companies where the contract is only concluded after website contact via 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 where it is easy to see, for example in the footer, but clearly highlighted and clearly labeled
• uses the label "Cancel contract" or an equivalent wording
• can be accessed without login if the purchase was also possible without a customer account
• remains available throughout the entire 14-day cancellation period
• works just as well on mobile devices as 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 create a classic warning notice 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 an email confirmation of receipt after submission, including the date and time of the cancellation

Important: as few required fields as possible. The law requires compliance with the GDPR principle of data minimization. Only data that is truly necessary for the cancellation may be requested. A required field asking for the reason for cancellation is explicitly not allowed. 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. At the same time, the following must also be updated:

• the cancellation policy (a newly required legal text element that refers to the digital cancellation option)
• the privacy policy (new data collection within the cancellation process)
• the terms and conditions

The upside: Starting in June 2026, the obligation to provide contract documents in paper form will also be removed. In the future, it will be sufficient to make all contract information permanently available in electronic form.

What happens if you do nothing?

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

This risk in particular is often 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 effectively cancel the contract and claim their money back more than a year after the purchase, without giving any reason.

What you should do right now

The deadline is getting closer. To make sure you are legally compliant by June 2026:

• Check whether your store 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 June 2026. Preparing in advance makes sense - publishing it early does not.

We are here to help you implement it 💚

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