Background to the amendment
The new EU requirement stems from amendments to the Consumer Contracts Act and the implementation of EU Directive 2023/2673. The aim is to ensure that consumers can exercise their right of withdrawal without unnecessary barriers in the digital purchasing journey, and that it should be just as easy to withdraw from a contract as it is to enter into one.
Today, many online shops handle the right of withdrawal via e-mail, contact forms, or customer service. Going forward, this will no longer be sufficient. Under the new Section 20a of the Consumer Contracts Act, businesses will be required to provide a digital withdrawal function directly on the webshop or within the digital user interface.
The purpose is to ensure a more uniform and direct digital process, where consumers can withdraw from their purchase without having to go through manual intermediaries.
Requirements for the solution
The function must be clear, easily accessible, and available throughout the 14-day withdrawal period. The consumer must be able to identify the specific order and submit their withdrawal digitally, typically via a simple form or a dedicated flow.
Once the withdrawal has been completed, an automatic confirmation must be sent to the customer.
There is also flexibility in the technical implementation, as long as the solution is intuitive and complies with the requirements for simplicity and accessibility.
Consequences of non-implementation
Failure to comply with the new act may result in injunctions and requirements to make adjustments imposed by the authorities, as well as an increased risk of consumer complaints and disputes. Although there is no fixed penalty regime, the authorities will carry out a case-by-case assessment, and the requirements are expected to be enforced.
In addition, an inadequate solution may lead to unnecessary manual handling and a poorer customer experience if the withdrawal process does not function digitally.
Less than three weeks until the deadline – what should you do now?
The requirement takes effect on 19th June 2026, and many online shops will need to have technical, design, and legal aspects in place to be ready.
So what do you do now? Here is our advice:
1. Assess your platform
Do you already have an account or customer service section where the function can be placed? And what options does your platform provide ? This will determine whether it is a minor adjustment or a larger development project.
2. Get the legal aspects in order
It’s not just the button that needs to be in place. The wording around the function, identification of the contract, and the subsequent confirmation must also comply with the requirements. Legal input can therefore be a good investment before the solution goes live.
3. Choose the right solution
For some businesses, a quick and pragmatic solution will be sufficient before the deadline. For others, it makes more sense to integrate the function into the overall customer experience and returns process. A well-designed solution can, in the long run, reduce both support requests and manual administration.
4. Not sure where you stand?
At Dwarf, we help e-commerce companies assess how best to implement the requirement on their existing platform: both technically and in terms of UX.
We can quickly review your current setup, identify any gaps, and help you build a realistic plan towards the deadline.
Contact our Client Director, Anders Drost Mickleit, på [email protected] for a free, no-obligation assessment.
