WILL AN ONLINE CANCELATION BUTTON BE MANDATORY FOR ONLINE STORES?
2026.06.25.
Starting June 19, 2026, a new consumer protection requirement will apply to businesses that facilitate online contract formation. It will no longer be sufficient for online stores to simply publish a cancellation notice or a downloadable sample cancellation form; they must also provide consumers with an online cancellation function.
In the world of online shopping, consumers typically conclude a contract with just a few clicks. The legislature’s goal is to ensure that exercising the right of withdrawal is not disproportionately more complicated than the purchase itself. This objective is served by the amendment to Government Decree No. 45/2014 (II. 26.), which introduces the requirement for an online withdrawal function—commonly referred to as the “withdrawal button”—for contracts concluded between parties not in the same location.
What does the right of withdrawal mean in the case of online purchases?
As a general rule, consumers have the right to withdraw from contracts concluded outside of business premises and between parties not present at the same time without giving a reason. For contracts for the sale of goods, this period is generally fourteen days from the date of receipt of the goods; for contracts for the provision of services, it is fourteen days from the date the contract is concluded.
The right of withdrawal is therefore not a new legal concept. What is changing is the manner in which it is exercised: the legislation now not only specifies the option of using a model withdrawal form or making an unambiguous statement but also explicitly requires that an online withdrawal function be made available.
What will change as of June 19, 2026?
Under the previous regulations, a business could provide the option to exercise the right of withdrawal on its website; however, this did not entail a specifically defined, mandatory online process. In contrast, the new regulations set forth specific requirements.
Under the amendment, the withdrawal function must allow consumers to submit an online declaration in which they notify the business that they are withdrawing from the contract. The consumer must be able to provide their name, the identifying details of the contract or order subject to withdrawal, and the electronic contact information through which they will receive confirmation of the withdrawal.
The legislation also specifies the name of the feature: the withdrawal feature must be made available in a clearly visible and easily accessible manner with the text “withdrawal from the contract” during the withdrawal period. Sending the notice requires a separate confirmation feature labeled “confirmation of withdrawal.”
A PDF or a customer service email address is not sufficient
It is important to emphasize that the new requirement is not the same as an online store including detailed withdrawal information in its Terms and Conditions or publishing a downloadable PDF template for the notice. These may still be important documents, but they do not, on their own, replace the online cancellation feature.
Likewise, simply providing a customer service email address is not necessarily sufficient. The new regulation does not require a general means of contact, but specifically mandates an online feature designed for submitting a withdrawal notice, which is clearly visible and guides the consumer through the withdrawal process.
The button is just the beginning: a complete process is required
Implementing the online withdrawal feature goes beyond simply placing a single button on the site. Compliance requires the development of a complete, documented, and verifiable process.
This could include, for example, allowing the consumer to access the “Withdraw from the Contract” feature directly within their user account, among their order details. The system then allows the consumer to fill out the withdrawal notice, identify the order, and submit it by clicking the “Confirm Withdrawal” button.
Upon receipt of the withdrawal notice, the business must send the consumer an acknowledgment of receipt on a durable medium without undue delay. In practice, the most obvious way to do this is through an automatic email confirmation that includes the content of the withdrawal notice, as well as the date and time it was sent.
What should online stores pay attention to?
As a first step, online stores should check whether their current platform includes a feature that complies with the new rules. It is not sufficient for a consumer to have to navigate through multiple menu items and search extensively to find a contact form. The feature must be easy to find and continuously available throughout the withdrawal period.
Special attention must also be paid to the handling of guest shoppers. If the online store allows purchases without registration, the withdrawal function must be made effectively accessible to them as well. In such cases, one solution could be a separate withdrawal subpage where the consumer can identify the relevant contract by entering their order ID and email address.
In addition to technical improvements, it may also be advisable to review the General Terms and Conditions, the withdrawal notice, the model withdrawal form, and the privacy policy.
It is advisable for the business to establish an internal administrative process to properly record and manage withdrawal notices received online and to initiate the related refund, return, or customer service procedures in a timely manner.
Does the right of withdrawal apply to all products?
Online retailers must also bear in mind that the law specifies certain exceptions to the consumer’s right of withdrawal. These may include, for example, certain hygiene products, perishable goods, custom-made products, or other products and services defined by law. Therefore, implementing an online cancellation feature does not mean that the right of cancellation can be exercised without restriction for all products; however, when designing the feature, the business must consistently apply consumer protection rules and handle these exceptions appropriately.
Summary
For online stores, implementing the online cancellation feature is not merely a technical task but also a legal compliance requirement. The goal is to enable consumers to cancel a contract concluded online in a simple, direct, and verifiable manner.
From a compliance perspective, the safest solution is for the business not only to formally place a cancellation button on the website but also to establish a comprehensive, transparent, documented, and permanently recorded online cancellation process.
Applicable legislation:
- Government Decree No. 45/2014 (II. 26.) on the Detailed Rules Governing Contracts Between Consumers and Businesses
- Directive (EU) 2023/2673 of the European Parliament and of the Council
- Directive 2011/83/EU of the European Parliament and of the Council
Author: Dr. Kitti Fodor
The above text is intended solely for general informational purposes and does not constitute legal advice.
The assessment of individual cases always depends on the specific facts and circumstances.
Our firm provides legal opinions and personalized advice exclusively on a retainer basis.
Please note the date of publication of this article, as the legal environment may have changed since then, and the information contained herein may no longer be current.
