Germany has finalized the legal framework for the new “withdrawal button” (Widerrufsbutton), which will become mandatory from June 19, 2026. The rule is introduced through the new Section 356a of the German Civil Code (BGB) and will affect businesses that allow consumers to conclude distance contracts through websites, apps, or other online interfaces.

The purpose of the new rule is to make it easier for consumers to withdraw from online contracts during the legal cooling-off period. In practice, if a consumer can enter into a contract online, the trader must also provide a clear electronic way to withdraw from that contract online.

The withdrawal function must be clearly visible, easy to access, and permanently available during the withdrawal period. It must be labelled “withdraw from contract” or with another wording that is equally clear. After the consumer enters the required information, there must also be a second confirmation function labelled “confirm withdrawal” or similar.

The consumer must be able to provide basic information through this function, including their name, details identifying the contract or part of the contract they want to withdraw from, and the electronic contact method where they want to receive confirmation. Once the withdrawal is submitted, the business must promptly send a confirmation of receipt on a durable medium, including the content of the withdrawal request and the date and time it was received.

The rule applies broadly to B2C distance contracts concluded through an online user interface. This includes websites, parts of websites, and mobile apps. It also covers financial services contracts concluded at a distance, meaning there is no general exemption for this sector.

The legislative materials clarify that businesses may need to display the withdrawal function permanently, even if they cannot always determine whether a specific consumer is still within the withdrawal period. This may happen, for example, where the user is not logged in or where checking the individual withdrawal period would require disproportionate effort.

However, there is one possible exception. If a contract can only be concluded through a customer account, it may be acceptable to provide the withdrawal button only inside the login area. This is particularly relevant for businesses where the contractual process always requires account creation.

The new rules also apply where contracts are concluded through third-party platforms. In that case, the trader remains responsible for ensuring that the consumer can use the withdrawal function. The trader may need to contractually require the platform operator to support this function.

The law also allows for partial withdrawal, meaning the consumer may withdraw only from certain goods or services within a larger order. In practice, this means systems may need to allow the consumer to identify exactly which part of the contract they want to cancel.

For website design, the withdrawal button may be placed in the footer, but it must not be hidden as a simple text link. It should be visually prominent, for example through colour, contrast, or clear separation from other legal links such as terms and conditions or the imprint.

Businesses should also be careful with the wording of the automatic confirmation message. The confirmation should only confirm receipt of the withdrawal request. It should not suggest that the legal validity of the withdrawal has already been checked. A safer wording would state that the validity and scope of the withdrawal are still under review.

The practical impact is significant. Online B2C businesses must update their websites, apps, withdrawal instructions, and internal handling processes before June 19, 2026. Failure to implement the withdrawal button correctly may lead to warnings, enforcement actions, and administrative fines.