The “withdrawal button” is coming: what’s really changing?

The Consumer Rights Directive (2011/83/EU) has long been the backbone of EU consumer law: clear pre-contractual information, the now familiar right of withdrawal of at least fourteen days for distance contracts, etc. The EU has recently tuned that framework with Directive (EU) 2023/2673, which covers, according to the title, financial services contracts concluded at a distance. Although the title suggests that the Directive solely covers financial contracts, it goes further than that: modernising rules for distance contracts (albeit with a focus on financial services) and a mandatory “withdrawal function” on e-commerce interfaces. 

What does the withdrawal function involve?

Do you sell online to consumers? Whenever a right of withdrawal exists, you must offer a simple, clearly visible feature that allows the consumer to exercise that right in just a few clicks (think “Withdraw here” / “Cancel my contract”). The idea is that withdrawing must be at least as easy as concluding a contract. This obligation applies to all distance contracts concluded via an online interface (so not only to financial services).

This does not itself expand the material scope of the right of withdrawal. The familiar exceptions (e.g., personalised goods or goods with a limited shelf life) continue to apply. The novelty lies in how the consumer can withdraw: clearer, easier to find, and more user-friendly.

What about financial services?

For financial services at a distance (insurance, brokers, credit, investment services, etc.), the Directive 2023/2673 also introduces additional rules: enhanced information duties, a ban on misleading interface patterns (“dark patterns”), and the right to human intervention in digital journeys. This modernisation goes hand in hand with the withdrawal function.

Timing: when must the “withdrawal button” be operational?

Member States must transpose the rules by 19 December 2025. The new provisions apply from 19 June 2026. Businesses would therefore be wise to review their web flows and internal processes now and plan accordingly.

In Belgium, the Code of Economic Law (WER) will need amending. The Belgian Data Protection Authority has already published its advice on the implementing act, amending article VI.61/1 of the Code of Economic Law, but the draft itself has not yet been made public. 

Practical checklist for your webshop or app:

• Provide a prominent button or link to withdraw that is always easy to find in the customer area/order overview. The flow should send a (pre-filled but adaptable) form and give the consumer a confirmation.
• Legal: update your pre-contractual information and terms (refer to the withdrawal function and how it works).
• Process: ensure customer support/CRM automatically receives withdrawal notices and handles them on time.
• Offering any financial services? Also check the additional information duties, dark-pattern prohibitions, and human-in-the-loop requirements.