Buying online today is done in seconds. A few clicks, Apple Pay or Google Pay, done. Cancellation, on the other hand? Often hidden, cumbersome or unnecessarily complicated. This is exactly where the legislator comes in - and draws the consequences: with the introduction of a mandatory cancellation button, the cancellation process should become just as simple as the purchase itself.
This is a clear benefit for consumers. For online retailers, however, it means a new legal obligation that deeply interferes with processes, technology and user guidance. Anyone who believes that the topic can be "somehow incorporated" shortly before the deadline is underestimating the effort - and the risk.
What does the cancellation button actually regulate?
The legal basis is the EU Omnibus Directive 2023/2673, which Germany is transposing into national law. The new Section 356a BGB will come into effect on 19 June 2026. From this date, all online shops that conclude distance selling contracts with consumers must provide a digital cancellation function.
What counts as a distance contract?
A distance contract is when the contract is concluded entirely online (or generally at a distance) - i.e. without a face-to-face meeting. This includes not only traditional online shop purchases, but also many typical digital channels:
- Goods: Clothing, furniture, spare parts, cosmetics - anything that is shipped
- Services: for example, coaching, maintenance packages, setup services, consulting services (if concluded online)
- Digital content and services: Downloads, licences, templates, subscriptions, digital memberships
Means for you: As soon as a consumer can conclude a contract via your website or app, this generally falls under distance selling - and from 19 June 2026, the cancellation function must be available via a button.
Important: The legislator is not talking about an optional feature, but a mandatory function. Existing cancellation forms, PDFs or email addresses are no longer sufficient. The cancellation button must also be available and function independently.
This is how the cancellation button must work
For the cancellation button to be legally compliant, it is not enough to simply place a link somewhere. The legislator sets out fairly clear requirements - both for the placement and the procedure.
1 Visibility and accessibility
- The cancellation button must be easy to find and permanently available.
- The labelling must be clear, for example "Cancel contract".
- Placement only in the customer account or behind a login is not permitted.
- Guest buyers must also be able to trigger the cancellation without any hurdles.
2. the mandatory two-step process
Cancellation must not happen "by mistake", but should be deliberately simple. A two-stage process is therefore prescribed:
Step 1
Click on the cancellation button: The user is redirected to a page to identify the contract, for example via order number and e-mail address. A login may not be requested here.
Step 2
Active confirmation of the cancellation via a second button, for example "Confirm cancellation".
3. immediate confirmation
After sending the cancellation, the retailer must immediately provide the customer with an electronic confirmation of receipt. In practice, this is usually done by e-mail, including the date and time of the cancellation.
4. Data minimisation is mandatory
- Reasons for cancellation may be requested, but are voluntary.
- Mandatory fields may only contain data that is absolutely necessary for the cancellation.
- Anything beyond this violates the GDPR principle of data minimisation and can be legally problematic.
Who is subject to the cancellation button requirement - and where there are exceptions
As a general rule, anyone selling to consumers online will need a cancellation button from mid-June 2026.
It doesn't matter
- how big your company is,
- how much turnover you generate
- or what legal form you have.
When does the obligation apply?
The cancellation button obligation applies to all distance selling contracts that are concluded via an online user interface. This affects more shops than many people think.
In concrete terms:
Goods
Classic online shop products such as clothing, technology, furniture, spare parts or cosmetics.
services
For example, online coaching, service packages, maintenance contracts or consulting services, provided they are booked online.
Digital content and services
Downloads, software licences, templates, subscriptions, memberships or digital platform access.
In short, if a consumer can conclude the contract directly via your website or app, it is usually a distance contract - and therefore the obligation to use the cancellation button applies.
Note on marketplaces and platforms
Even if platforms such as Amazon or eBay provide (or have to provide) their own cancellation functions, this does not automatically release retailers from their responsibility.
Particularly in the case of multi-channel setups, own shop front-ends or connected marketplaces, the retailer remains responsible for ensuring that the cancellation process is correct, transparent and legally compliant. Relying solely on platform defaults can therefore be risky.
When is a cancellation button not required?
There are exceptions, but they are clearly limited. The cancellation button is only not necessary if there is no statutory right of withdrawal.
This is the case, for example, for
- Customised products (e.g. made-to-measure or personalised goods)
- Perishable goods (such as fresh food)
- Sealed hygiene or health products (if the seal has been removed after delivery)
- Digital content (if the customer has expressly waived their right of cancellation before downloading)
- Pure B2B shops (where sales are made exclusively to entrepreneurs)
Important: The exception does not automatically apply just because a product "cannot actually be cancelled". In case of doubt, you as the retailer must be able to prove why there is no right of cancellation.
Caution with mixed models
Shops that combine B2C and B2B or sell different product types are particularly critical. It is not enough to simply hide the button. If only part of your offer falls under the right of cancellation, you need to make a very clear distinction - both technically and legally.
This is exactly where most mistakes happen in practice.
Typical mistakes with the cancellation button - and why they can be really expensive
A missing or incorrectly implemented cancellation button is not a formal flaw. From a legal point of view, it is a violation of a market behaviour rule. This automatically makes the issue subject to a warning - regardless of whether the implementation was "well-intentioned" or not.
Warning letters: The classic that quickly becomes expensive
Consumer protection associations and specialised law firms systematically check online shops. Just like with the legal notice, cookie banners or GDPR notices, the cancellation button is scanned automatically sooner or later. If it is missing or incorrectly implemented, a warning will usually follow. The costs often range between 500 and 2,000 euros - including legal fees and a cease-and-desist declaration.
Experience shows that the systematic warning practice does not begin years later, but often in the year after it comes into force - i.e. from 2027.
Jochen Kernwein
CSO at elio GmbH
Fines: Particularly critical for larger retailers
In addition to warnings, there is also the threat of fines. For smaller companies, the upper limit is 50,000 euros. For companies with a higher annual turnover, the fine can be up to four per cent of the annual turnover.
This is where it becomes clear: the cancellation button is not a marginal issue, but a real compliance factor.
Typical implementation errors with legal explosive force
In practice, it is rarely gross violations but supposedly minor details that become problematic.
Our experts warn against these mistakes time and again:
Cancellation only possible after login
Many shops transfer the cancellation process to the customer account. Technically convenient, legally problematic. The cancellation process must also work without a login - especially for guest orders. A login barrier effectively renders the button ineffective.
Button is hidden or difficult to find
A link in the footer, an inconspicuous design or placement only after scrolling is not enough. The cancellation button must be easily accessible and clearly recognisable - even on mobile devices. "Available anywhere" is not enough.
Poor mobile usability
On smartphones, the cancellation button is often hard to find or difficult to use. Small click areas, low contrast or unfavourable positioning make it practically unusable. Since most orders are placed on mobile devices, a consistent mobile-first implementation is a must.
Too many mandatory fields in the form
Telephone number, address or a reason as a mandatory field are critical. Only data that is necessary to clearly assign the contract, such as order number and email address, is permitted. Anything beyond this violates the GDPR principle of data minimisation.
No or delayed confirmation of receipt
It is true that the cancellation is deemed to have been declared even without confirmation. However, if there is no immediate electronic confirmation of receipt, this is a clear violation of the law. In practice, this point is often forgotten or not properly implemented technically.
Unclear or incorrect labelling
Labels such as "Send enquiry" or "Contact us" are not clear enough. The user must clearly recognise: I am cancelling my contract here. Anything else opens the door to warning letters.
Lack of multilingualism
This is a frequent stumbling block, especially for international shops. The cancellation button and the entire process must be i18n-compliant - including linguistically correct labelling and common variants. Half-translated processes are quickly considered non-transparent.
Note for international shops
The obligation to use the cancellation function applies throughout the EU. In international setups, however, it is not enough to roll out the button once centrally. In multi-shop or multi-language structures, it should be checked at an early stage how the cancellation button is correctly displayed for each market.
Payment methods not considered
The cancellation does not end with the click. Refunds must be properly linked to connected payment methods such as PayPal or Stripe. If this logic is missing, manual processes, errors and unnecessary support tickets arise.
B2B and B2C orders not clearly separated
The cancellation button is hidden across the board, although no clear distinction is made between entrepreneurs and consumers. This can lead to consumers being de facto deprived of their right of cancellation - a classic reason for a warning.
All of these points may already be sufficient to justify a competition offence.
Practical example from our everyday work: The cancellation button was technically available in a Shopware shop, but was only visible after login. Guest buyers had no option to cancel digitally. Result: acute risk of a warning - even though the shop was "actually prepared".
Loss of trust: the silent but lasting consequence
In addition to the legal consequences, there is one aspect that is often underestimated: Trust. Consumers today expect transparency and simple processes. If the cancellation button is missing or intentionally hidden, the impression of a dubious shop is quickly created. This has a direct impact on repeat purchases, reviews and conversion rates.
Experience from previous changes to the law clearly shows that warning letters do not come at some point. They come early. And they hit the shops that "still had the issue on their list" first.
Why online retailers should act now - and what this has to do with your shop system
Many retailers are still putting off the issue of the cancellation button. "It's not until the middle of 2026." That's exactly what's risky. The cancellation button is not just a legal issue that can be ticked off shortly before the deadline. It has a profound impact on technology, data processes and user guidance.
Technology: More than just an additional button
The implementation of customised shops in particular is more complex than it appears at first glance. It's not just about a UI element, but about new logic in the background: identification of orders, clean form processes, e-mail confirmations, multilingualism and special cases such as guest orders or international shops. Depending on the system, several weeks of development time may be realistic.
Many risks associated with the cancellation button only become apparent in detail. An early check provides clarity - without time pressure. We will be happy to assess this for you without obligation!
Data protection: Old construction sites suddenly become visible
With the cancellation button, the focus automatically shifts to the data that is collected and stored in the cancellation process. Shops that still request unnecessary mandatory fields or have unclear storage periods run the risk of creating an additional GDPR construction site with the new process. Those who check and tidy up at an early stage will save time, costs and discussions later on.
User experience: mandatory with a positive side effect
A clear, transparent cancellation process is not a deterrent - on the contrary. Users perceive shops as more trustworthy if returns are easy. This can be a real differentiator, especially in highly competitive markets. Transparency pays off - also in terms of conversion.
Quick check: Does my online shop need a cancellation button?
All of this raises a key question: Does this affect me specifically - or can I relax and tick the topic off?
This is exactly where it gets confusing for many retailers, because business models, product types and shop setups vary greatly. The following quick check will help you to quickly categorise where you stand.
Answer the following questions honestly. If you say "yes" at least once, you should consider the cancellation button - at the latest now.
Result: This is how you should categorise it
- 0× Yes: Most likely not mandatory - but it still doesn't hurt to check.
- 1-2× Yes: You are probably affected. There is a need for action.
- 3× or more Yes: The cancellation button is mandatory for you. Now is the right time to tackle the issue.
Technical implementation: the effort required varies from shop system to shop system
If you have found yourself in the quick check, the next question automatically arises: How complex is the implementation in my shop system?
The short answer is: it depends.
Not every shop system is equally well prepared for the new obligation. The actual implementation effort depends heavily on the technical architecture, the plugin ecosystem and the degree of customisation of your shop.
| Shop system | Technical effort | Estimate |
| Shopware 6 | Medium | Clean implementation via custom plugin and own controller recommended |
| WooCommerce | High | Additional custom logic is often required, check carefully from a legal perspective |
| Shopify | Low | Apps available, but close examination of legal compliance required |
| Magento | High | Usually requires complete customised development |
In practice, Shopware and Magento shops in particular show that those who plan early can integrate the cancellation button cleanly into existing processes. Those who only react shortly before the deadline often have to retrofit under time pressure - with correspondingly higher costs and compromises in terms of quality and UX.
In short: the cancellation button is not a last-minute issue. It affects technology, data protection and UX at the same time. And the more complex your shop setup is, the sooner you should deal with it. We will be happy to help you!
The cancellation button is coming - we'll make it stress-free for you
The implementation of the cancellation button touches on several levels at the same time: legal, technical, data protection and user experience. Mistakes usually occur where these areas are not considered together.
As eCommerce specialists, we support online retailers at precisely this interface - especially in complex Shopware setups.
What we can do for you:
Assessment of whether and to what extent your shop is affected
Audit of existing cancellation, data and checkout processes
Technical implementation of the cancellation button (GDPR-compliant, UX-clean)
Consideration of special cases such as B2B/B2C mixed models, guest orders and mobile
Optional: Combination with Shopware migration or refactoring
Our approach is pragmatic. No overengineering, no scaremongering - just a solution that is legally sound and fits your shop. Don't wait until June 2026 - planning early saves costs, avoids time pressure and keeps you in control. Have your shop checked now without obligation - before the cancellation button becomes mandatory under time pressure. Contact us now.
Conclusion: Mandatory task with a signalling effect
The cancellation button is coming. Full stop. From June 2026, it will no longer be an option for online shops with B2C business, but a requirement. Anyone who sells must also enable simple, digital cancellation - visible, understandable and technically clean.
The law itself is less exciting than what it triggers. The cancellation button is emblematic of a development in eCommerce: more transparency, fewer hurdles, higher expectations of user guidance and processes. Shops that are properly set up in this respect benefit twice over - legally and in the perception of their customers.
It is therefore worthwhile not seeing the cancellation button as an annoying obligation, but as an opportunity to question existing processes. Because in the end, the wheat is separated from the chaff here too: between shops that react and those that design.
The information published on this page does not constitute legal advice, but is provided solely for information purposes and may no longer be up-to-date due to changes in the legal situation. No liability is accepted for the accuracy or completeness of the content.
