General information
Estonia is implementing the EU Distance Marketing of Financial Services Directive, introducing a mandatory withdrawal button (or similar function) for all businesses selling goods or services to consumers online.
Withdrawal Button Requirement
Businesses must provide a clearly visible "I withdraw from the contract" button (or equivalent unambiguous function) in their online user interface — including websites and mobile apps — where consumers conclude distance contracts.
This obligation applies to almost all consumer distance contracts concluded via an internet-based user interface (e.g. online shops, electricity contracts), not just financial services. It does not apply to contracts concluded by phone, email, post, SMS, in person, or through third-party messaging apps (such as WhatsApp) that the trader does not control.
Exceptions include healthcare services and passenger transport services. In hybrid cases (e.g. agreement by email but signed via an online portal), qualification depends on the specific circumstances.
How the Withdrawal Button Must Work
The button or similar function must:
- Be available to the consumer throughout the entire 14-day withdrawal period.
- Allow the consumer to easily complete an online withdrawal form by entering or confirming their name, the specific contract, and preferred confirmation method.
- Include a clear confirmation step (e.g. a button labelled “I confirm my withdrawal”).
- Enable the trader to immediately send confirmation of receipt, including the content of the withdrawal and the exact date and time.
The trader is not required to create a fully automated system or link the button to a customer account. It is sufficient if pressing the button generates a message or email to the trader’s staff. A hyperlink titled “I withdraw from the contract” that leads to the required form also complies.
Key Principles
- The withdrawal button does not change existing 14-day withdrawal rights — it only makes exercising them as easy as entering the contract.
- For goods, the button must remain available even after physical receipt, until the 14-day period ends.
- Consumers who withdraw must still return the goods without delay (within 14 days). The trader must refund the payment.
- All existing exceptions to the right of withdrawal continue to apply (e.g. personalised goods, fully performed services with prior consent, opened hygiene products, digital content, perishable goods, etc.).
The exact technical implementation details remain flexible, but the button must be clearly highlighted and unambiguous. Final interpretation will develop through future practice.
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