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Guide · Online retail & obligations

Online Withdrawal Function: What Has Applied Since 19 June 2026

Which online contracts require an electronic withdrawal function and how the two-step process should work in practice.

Why this matters

Since 19 June 2026, businesses must provide an electronic withdrawal function for covered distance contracts concluded through an online interface. This is not limited to subscriptions. Goods, services, and digital offers can be covered when a consumer concludes the contract online and has a statutory right of withdrawal.

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When you need a withdrawal function

Section 356a of the German Civil Code covers distance contracts that consumers conclude through an online interface. This can include your own shop, a website, an app, or—depending on the setup—a sales process on a marketplace.

The function matters where a statutory right of withdrawal exists for the contract. If no such right exists from the outset or it has validly expired, the function does not create a new right. You should not, however, assume an exception for your entire catalogue without checking each contract type.

Pure B2B contracts do not fall under the consumer right of withdrawal. A business selling to both consumers and businesses needs a reliable way to distinguish customer and contract types.

Step one: ‘Withdraw from contract’

The first function must be clearly legible and labelled ‘Withdraw from contract’ or with an equally clear equivalent. It must remain continuously available throughout the withdrawal period, be prominently placed, and be easy for the consumer to access.

A link hidden in lengthy terms, a telephone number by itself, or a requirement to contact support first does not reflect this functional process. An unnecessarily difficult login or search path can also conflict with easy accessibility.

The function can be generally accessible and then ask for the contract details needed to identify the transaction. This also allows the process to handle guest checkouts or several orders from the same person.

Step two: details and confirmation

After activating the function, the consumer must be able to provide or confirm their name, details identifying the contract or part of the contract they wish to withdraw from, and an electronic contact method for the acknowledgement.

A separate confirmation function follows. It must be clearly legible and labelled ‘Confirm withdrawal’ or with an equally unambiguous equivalent. This second step prevents an accidental first click from immediately withdrawing from a contract.

Ask only for information needed for identification and confirmation. A reason for withdrawal is not required. For contracts containing several items, make it clear whether the consumer is withdrawing from the whole contract or only part of it.

Acknowledgement on a durable medium

After confirmed submission, you must immediately send an acknowledgement on a durable medium, usually by email. It must include at least the content of the withdrawal statement and the date and time it was received.

Internally, also record the affected contract, receipt time, acknowledgement sent, and the subsequent refund or return handling. The withdrawal is treated as received in time if the consumer sends it through the function before the deadline.

An error page, a screen-only message, or an email without enough information to identify the withdrawal is operationally weak. Test the entire chain through to the inbox, ticket system, and refund process—not just the button.

The function does not replace the other withdrawal rules

The electronic function is an additional route. Consumers may still exercise the right through another unequivocal statement, such as an email. Your withdrawal information, model withdrawal form, and correct pre-contract information therefore remain important.

The official model instructions now include wording about the online function and where it can be found. Review your legal texts, order confirmation, footer, and service area together instead of adding a button in isolation.

On a marketplace, clarify in writing which function the platform provides and which duties remain with you. A marketplace's technical involvement does not automatically mean your seller process is fully covered.

Quick checklist

  • List all B2C contracts concluded through your website, app, or marketplace.
  • Check whether and for how long a withdrawal right exists for each contract type.
  • Place the ‘Withdraw from contract’ function prominently and keep it continuously accessible.
  • Collect the name, contract identifier, and electronic acknowledgement channel.
  • Implement a clear second step labelled ‘Confirm withdrawal’.
  • Send an immediate acknowledgement with content, date, and time.
  • Test full and partial withdrawals as well as guest orders.
  • Add the online route to the withdrawal instructions and model form.
  • Connect support, returns, refunds, and recordkeeping to the new input.
  • Test mobile layouts, keyboard operation, and error cases.

Common mistakes

  • Planning the withdrawal function only for subscriptions.
  • Hiding it in the terms or deep inside a customer account.
  • Offering only a one-step button without explicit confirmation.
  • Making a reason or unnecessary personal data mandatory.
  • Failing to send an acknowledgement on a durable medium.
  • Assuming the new function replaces withdrawal information and other declaration routes.
  • Relying entirely on a marketplace feature without checking it.

Frequently asked questions

Does every online shop need a withdrawal function from June 2026?

The duty is tied to distance contracts concluded online with consumers where a statutory right of withdrawal exists. Pure B2B shops and contract types without a withdrawal right are assessed differently; a mixed shop must handle the covered cases properly.

Can the function sit inside a customer account?

It must remain continuously available, prominently placed, and easy to access. An account can be part of the route, but it must not make access unnecessarily difficult and must work with the actual ordering model, including guest orders where offered.

Must the refund happen automatically after the click?

The function first records and acknowledges the withdrawal statement. Refund timing, possible withholding until goods are returned, return costs, and compensation for lost value continue to follow the general withdrawal rules and the specific contract.

What this guide can and cannot do

This guide helps with

  • sort your sales channels and contract types for an initial relevance check
  • create a technical and operational test flow
  • show how the function connects to withdrawal information, returns, and marketplaces

This guide does not replace

  • make a binding determination of the withdrawal right for every contract
  • legally approve your shop implementation or legal texts
  • replace a platform commitment or legal review

Official sources

For binding information, always check the official bodies. The links below are starting points, not a final review of your case.

Helpful next step

Set up online sales cleanly first

For marketplaces, Etsy, eBay or your own shop, the order matters especially: activity and registration, tax data, packaging, imprint, receipts and only then tool or assortment expansion.

Sales channels can become public quickly. Check obligations before adding more listings, stock or shop tools.

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