Does your online shop have the EU withdrawal button?

The EU wording: Article 11a of Directive 2011/83/EU

Directive (EU) 2023/2673 inserted Article 11a into the Consumer Rights Directive 2011/83/EU, under the heading “Exercise of the right of withdrawal from distance contracts concluded by the means of an online interface”. All five paragraphs, word for word:

The amending directive’s title is about financial services, but Article 11a covers distance contracts concluded online in general. Recital 37, which is not binding, says: “This obligation should apply not only to distance contracts for financial services, but to all distance contracts that are subject to the right of withdrawal under Directive 2011/83/EU.”

What your withdrawal instructions must say

The same directive changed the information given before the contract is concluded. Article 6(1)(h) of Directive 2011/83/EU now reads:

For the model instructions on withdrawal, Annex I to Directive (EU) 2023/2673 gives a sentence to insert when you must provide the function:

National rules and start dates

A directive binds the Member States. The trader’s duty and its start date come from the national law that transposes it, and both the dates and the words differ. The directive set the timetable:

The six national laws we have read, in order of their start date:

Where the dates come from: Germany, Article 10(1) of the amending act (BGBl. 2026 I No. 28); Malta, regulation 1(3) of L.N. 145 of 2026; Slovakia, § 53b of Act No. 108/2024 Coll.; Ireland, the commencement date in the Irish Statute Book, because S.I. No. 309 of 2026 has no commencement clause of its own; Austria, § 20(5) FAGG (§ 13a in force since 1 October 2026, for contracts concluded after 30 September 2026); Czechia, Article XII of Act No. 159/2026 Coll.

Ireland uses different words

Ireland transposed Article 11a with the verb “cancel”, not “withdraw”. Under section 115A(1) of the Consumer Rights Act 2022, the online cancellation function must be:

Our check knows the Irish wording: a shop whose function is labelled “cancel contract here”, or whose confirmation step is labelled “confirm cancellation”, gets “Label found” (see the next sections). Malta’s regulation 13A keeps the directive’s words “withdraw from contract here” and “confirm withdrawal”.

Other Member States

We have read only the six laws above; for any other country, check its national law. On 30 January 2026 the European Commission sent letters of formal notice to 21 Member States for failing to communicate complete transposition of Directive (EU) 2023/2673. Germany, Malta, Ireland, Austria and Czechia were on that list and adopted the laws in the table later. What the Commission did next, we have not verified.

Source: European Commission, January infringements package, 30 January 2026 (INF/26/115)

Who it applies to

• Distance contracts concluded through an online interface, such as a website or an app (Art. 11a(1)). The article does not speak of contracts concluded by phone or in a shop.
• Contracts with a right of withdrawal. Recital 37 speaks of distance contracts “subject to the right of withdrawal”. The exceptions to that right (Article 16 of Directive 2011/83/EU and national law) are not listed here.
• An extra way, not a replacement. The consumer can “also” withdraw by using the function (Art. 11a(1)). The existing ways, such as the model withdrawal form, stay available (recital 37).

If you sell from outside the EU, or to consumers in several Member States, which national law applies to your contracts is a legal question that this page does not answer. The table above covers the six laws we have read.

What our check reports

The check looks for the directive’s two labels, “withdraw from contract here” and “confirm withdrawal”, in nine language versions: English, German, Slovak, Czech, Polish, French, Italian, Spanish and Dutch, and the Irish statutory labels “cancel contract here” and “confirm cancellation”. The words must come in this order; capitals and accents do not matter, and up to two other words may be added, so “Withdraw from the contract here” counts. It reads the text of links and buttons, including form buttons, and their aria-label and title. Labels about consent or cookies, such as “Withdraw consent”, never count.

Ireland: a shop that follows section 115A with the label “cancel contract here” gets “Label found”, as for the directive’s words. A link labelled “cancel contract here” may also cancel a subscription or an order; check by hand with the steps below that it opens the withdrawal function.

On the Czech page of this check, “Odstoupit od smlouvy” counts as the label of the Czech law, and the Slovak page points out “Odstúpiť od zmluvy” as a similar wording. This English page shows both as “Check the link”.

The confirmation step usually comes after the online statement is filled in, often on a page the check does not read. Its absence from our result says nothing about it.

How to add it on your platform

Only what each platform’s own documentation, release notes or source code says, read on 23 October 2026. Even where the function is built in, you often have to switch it on or add the link yourself. Where a platform has a default or suggested English label, we say what our check reports for it.

Common mistakes

• A link only to the terms or to the model withdrawal form. The function must let the consumer send an online withdrawal statement (Art. 11a(2)). The model form stays available as an additional way (recital 37) but does not replace the function.
• The function only after signing in. Article 11a does not mention logging in; it requires the function to be “easily accessible to the consumer”. Recital 37, which is not binding, says the consumer “should not have to undertake procedures to find or access the function, such as downloading an application if the contract was not concluded via that application”, and mentions logging in only for a consumer “who has already identified himself or herself, for example by logging in”, who should not have to identify again. A customer who ordered as a guest has no account. The explanatory memorandum of the German government bill says the function “muss grundsätzlich auch ohne Login erreichbar sein” (must in principle be reachable without login); that is not the text of the law.
• A footer link that looks like every other legal link. The function must be “prominently displayed”. For a footer link, the same German memorandum asks for measures such as colour, contrast and a prominent placement that clearly set it apart from the terms and conditions or the legal notice.
• No confirmation step, or no acknowledgement. The statement is sent with a separate confirmation function (Art. 11a(3)), and the trader sends an acknowledgement of receipt with its content and the date and time of submission, without undue delay (Art. 11a(4)).
• A button that disappears after a few days. The function must be “continuously available throughout the withdrawal period” (Art. 11a(1)).
• Withdrawal instructions that do not mention the function. Where applicable, the information on the right of withdrawal includes “the existence and placement of the withdrawal function” (Art. 6(1)(h)).
• One date for the whole EU. 19 June 2026 is the date from which Member States had to apply their rules. Austria applies its rule to contracts concluded after 30 September 2026, Czechia from 1 January 2027.
• A label about returns, such as “Return items”. It does not say withdrawal, and our check does not count it.

Source: Bundestag printed paper 21/1856, explanatory memorandum to § 356a BGB (German)

What our check found in 4 German shops

On 23 October 2026 we ran this check on 4 public German online shops that we picked ourselves. We do not name them. Germany has applied § 356a BGB, with the label “Vertrag widerrufen”, since 19 June 2026.

• 2 of 4: Label found. Both had a link or button labelled “Vertrag widerrufen” on the home page. Whether it opens a working form, we did not test.
• 1 of 4: Check the link. It had only links labelled “Widerrufsbelehrung” (withdrawal instructions), “Widerrufsformular” (withdrawal form) and “Widerruf” (withdrawal). Whether one of them opens an online form, the check cannot tell.
• 1 of 4: Could not read. The check could not read any page of the shop.

One measurement of 4 shops chosen by us, not a representative sample. We have no sample of shops from Ireland, Malta or other English-speaking markets, so these numbers say nothing about them. The check read 4 to 6 pages of each readable shop. Findings are not a legal assessment.

How to check it yourself

1. Open your shop in a private window without signing in, on a computer and on a phone, and look for the withdrawal link without using search, for example in the footer.
2. Click it as a customer who ordered as a guest. Note whether it asks you to sign in.
3. Fill in a name, the number of a test order and an email address. Check that nothing has been sent yet.
4. Click the confirmation button: “Confirm withdrawal” or the wording of your national law.
5. Open the email: it should contain the content of your statement and the date and time of submission (Art. 11a(4)).
6. Repeat the test a few days after delivery: the function must work throughout the withdrawal period.
7. Check that your withdrawal instructions say that the function exists and where it is (Art. 6(1)(h)).

If you sell goods, also check the EU legal guarantee notice, which Slovakia and Germany have required since 27 September 2026. The same withdrawal check also exists in German, Slovak and Czech.

Enforcement: what the laws allow

Penalties are set by each Member State. Directive 2011/83/EU requires effective, proportionate and dissuasive penalties and, where fines are imposed in a coordinated action under Article 21 of Regulation (EU) 2017/2394, a maximum of at least 4% of the trader’s annual turnover in the Member States concerned, or at least EUR 2 million where turnover information is not available (Article 24(1), (3) and (4)); it sets no other amounts. Below are the maximums written in the national laws we read, not typical fines. We found no published fine for this duty in the sources we read.

• Slovakia: for breaches of § 20a(1) to (5), a fine from EUR 200 to 2% of the previous accounting period’s turnover, at most EUR 200,000 (§ 43(1)(a) of Act No. 108/2024 Coll.); higher ranges apply to repeated breaches (§ 43(3): from EUR 300 to 3%, at most EUR 400,000) and in coordinated actions against widespread infringements (§ 43(2): from EUR 500 to 4%). Supervision: the Slovak Trade Inspection, in some sectors another authority.
• Czechia, from 1 January 2027: not enabling withdrawal by the button (§ 1830a(1)) or not confirming receipt (§ 1830a(5)) is an offence with a fine of up to CZK 5,000,000 (§ 24(16)(q) and (r) and § 24(24)(e) of Act No. 634/1992 Coll.); only in proceedings under Article 21 of Regulation (EU) 2017/2394, up to 4% of total annual turnover, or up to CZK 50,000,000 where turnover information is not available (§ 24(25)). Supervision: the Czech Trade Inspection Authority.
• Germany: a fine of up to EUR 50,000, or up to 4% of annual turnover for traders with more than EUR 1.25 million, but only for widespread infringements and only within a coordinated enforcement action under Article 21 of Regulation (EU) 2017/2394 (Art. 246e § 1(1) and § 2(2), (3) and (5) EGBGB). Authority: the Federal Office of Justice.
• Austria: an administrative offence with a fine of up to EUR 1,450, unless the act is a criminal offence or another administrative provision sets a stricter penalty (§ 19(1) no. 6a FAGG); up to 4% of annual turnover only in proceedings under Article 21 of Regulation (EU) 2017/2394 (§ 19(3) FAGG).
• Ireland: a trader who contravenes section 115A(1), (2), (3) or (4) commits an offence (section 115A(6)). We have not verified the penalty.

Source: Directive 2011/83/EU, Article 24, consolidated text of 27 September 2026 (EUR-Lex); Act No. 108/2024 Coll., § 43 (Slov-Lex); Act No. 634/1992 Coll. from 1 January 2027 (zakonyprolidi.cz); Art. 246e § 1 EGBGB (gesetze-im-internet.de); Art. 246e § 2 EGBGB (gesetze-im-internet.de); § 19 FAGG (RIS); S.I. No. 309 of 2026 (Irish Statute Book)