The law prescribes a two-step process. Both steps must be in place and working for the obligation to be met:
After clicking the withdrawal button, the consumer reaches a confirmation page. There, they enter the details needed to identify the contract – such as their name, order details and contact information – and submit the withdrawal declaration using the second button. The trader must then acknowledge receipt of the declaration on a durable medium, in practice usually by email stating the date and time of receipt.
Visibility and findability
The withdrawal button must be easily accessible and clearly recognisable. It must not be hidden in a deeply nested menu or behind a login that makes access harder for the consumer. A prominent, permanently accessible position – comparable to that of the legal notice (Impressum) or the withdrawal policy – is the safe option. What matters is that an average consumer can find the button without any particular effort.
Consequences of non-implementation: extended period and risk of warning letters
The sanction for a missing or faulty withdrawal button is significant. If the function is missing, and with it the information about this way of withdrawing, the withdrawal period is extended from 14 days to twelve months and 14 days. This legal consequence corresponds to the general rule for missing or incorrect information on the right of withdrawal and can have considerable practical consequences.
A concrete example makes this clear: if a customer buys a seasonal item such as a garden barbecue in March and the withdrawal button is missing, they can in theory withdraw from the purchase until well into the following year. By then the season is over and the goods have been used – the economic damage for the retailer is obvious. On top of that comes the risk of warning letters: the absence of the legally required function is a breach of an information duty and can be challenged under competition law by competitors or associations.
Implementation in the shop: why early planning pays off
The withdrawal button is technically more demanding than it first appears. It is not static text but an interactive process that connects several building blocks:
- a permanently visible button in the front end;
- a confirmation page with an input form that captures the necessary contract details;
- logic that assigns the declaration to the correct contract;
- an automatic acknowledgement of receipt on a durable medium;
- clean documentation of the time of receipt as evidence in the event of a dispute.
In common shop systems such as Shopware, the withdrawal button can be implemented either via a suitable extension or as a custom development. Since the function affects the ordering process and customer management, it should be planned properly rather than added as a last-minute stopgap; the obligation has applied since 19 June 2026. Anyone who builds compliance into shop development early avoids makeshift solutions and makes sure that the process is tested and live.
The withdrawal button does not replace the existing obligations; it supplements them. The withdrawal policy – i.e. the information on the existence, conditions and consequences of the right of withdrawal – remains mandatory. The model withdrawal form, which must be made available to the consumer, does not disappear either. The withdrawal button is an additional, technical way of declaring withdrawal. Alongside it, the consumer can still withdraw informally, for example by email or letter; the button is an additional option, not the only way.
The withdrawal button does not stand alone. As early as 1 July 2022, the German legislator introduced the so-called termination button (Kündigungsbutton, often called the “cancellation button” in English) with Section 312k BGB. It requires traders who allow consumers to conclude continuing contracts online – such as subscriptions or memberships – to provide an equally straightforward button for terminating them. The parallel is obvious: if you can enter into a contract with one click, you should be able to end it just as easily.
The withdrawal button transfers this principle from continuing contracts to one-off distance contracts. In e-commerce practice, this means that since June 2026 many shops have had to provide two related but legally separate functions: the termination button for ongoing contracts and the withdrawal button for orders that can be withdrawn from. Both follow the same two-step pattern of button and confirmation page, both require an acknowledgement of receipt, and both carry a risk of warning letters if implemented incorrectly. Anyone who has already implemented the termination button properly can build on that experience.
Structured preparation helps make sure the withdrawal button is legally compliant. The following points should be completed and tested, as the obligation has applied since 19 June 2026:
- Check whether the obligation applies. Do you allow consumers to conclude distance contracts via a website or app? Then the obligation applies. Pure telephone or offline ordering channels are not covered.
- Place the button. Set up an easily legible, permanently visible “Vertrag widerrufen” (withdraw from contract) button in a prominent, easy-to-find position.
- Build the confirmation page. Implement an input form for the contract details and a second button, “Widerruf bestätigen” (confirm withdrawal).
- Automate the acknowledgement of receipt. Automatically acknowledge receipt of the withdrawal on a durable medium – usually by email with a timestamp.
- Ensure correct assignment. Make sure the withdrawal declaration is assigned internally to the correct contract and customer.
- Set up documentation. Log the time of receipt in an audit-proof way so that you can prove the deadline was met in the event of a dispute.
- Align existing texts. The withdrawal policy and the model withdrawal form remain mandatory and must still be correct and up to date.
This list is no substitute for individual legal advice, but it is a good starting point for your own project planning. Since several of the points affect the ordering process and customer management, early coordination between the legal department or legal counsel and shop development makes sense.
Typical implementation mistakes
The introduction of the termination button in 2022 already showed that the devil is in the detail. The same patterns can be expected with the withdrawal button. Common sources of error are:
- Hidden button. The button is placed in a deeply nested menu or behind a customer login. That does not meet the “easily accessible” requirement.
- Missing acknowledgement of receipt. The withdrawal is accepted, but receipt is not acknowledged on a durable medium. A step required by law is therefore missing.
- Unclear labelling. Ambiguous labelling, or labelling that deviates from the statutory wording, can undermine the function.
- No record of the time. Without an audit-proof timestamp, it is impossible to prove in a dispute that the withdrawal arrived in time.
- Withdrawal policy not updated. If the button is introduced but the withdrawal policy is not adjusted, the information becomes contradictory.
These mistakes can be avoided if the withdrawal button is planned as a process in its own right, not treated as an afterthought text block, and tested thoroughly in practice.
Since 19 June 2026. On that date, Section 356a BGB entered into force. It requires traders who allow consumers to conclude distance contracts via a website or app to provide a withdrawal button.
Who does the obligation apply to?
All traders who allow consumers to conclude contracts via an online interface (website or app). Exempt are contract channels without a digital interface, such as telephone, fax or order card, and contracts for which there is no right of withdrawal under Section 312g BGB.
It consists of two steps: an easily legible, permanently visible button labelled “Vertrag widerrufen” (withdraw from contract) or equivalent, and a confirmation page with an input form and a second button (“Widerruf bestätigen”, i.e. confirm withdrawal, or equivalent). The trader must acknowledge receipt on a durable medium.
If the function is missing, the withdrawal period is extended from 14 days to twelve months and 14 days. In addition, there is a risk of a warning letter under competition law for breach of an information duty.
No. The withdrawal policy and the model withdrawal form remain mandatory. The withdrawal button is an additional technical way of declaring withdrawal. Consumers can still withdraw informally as well.
The statutory text is available in full on gesetze-im-internet.de: Section 355 BGB on the right of withdrawal and Section 356a BGB on the withdrawal function (both in German). The Wikipedia article on the right of withdrawal (in German) gives an overview of the right of withdrawal in distance selling.
