What the new rules require
Businesses concluding consumer contracts through a website or mobile application will be required to provide consumers with a dedicated “withdrawal function”. The purpose of this requirement is to ensure that consumers can exercise their right of withdrawal in a simple and user-friendly manner and for withdrawing from a contract to be as easy as concluding it.
The requirement stems from Directive 2023/2673 (the Directive), which primarily concerns financial services contracts. While the Directive is focused on financial services, it also introduces significant amendments to the right of withdrawal, applicable to all distance contracts concluded via an online interface.
The term “online interface” should be interpreted broadly and in accordance with the Digital Services Act; it includes any software, including websites or parts thereof, or applications, including mobile applications. Consequently, the new requirements will apply to all distance contracts concluded online.
It should be noted that consumers already have a statutory right of withdrawal in respect of distance contracts. Under the existing framework, consumers may withdraw from such contracts within 14 days without providing any reason. To exercise this right, consumers typically submit a withdrawal form or another unequivocal statement of withdrawal. Many traders have already introduced digital tools to facilitate this process.
The new rules are intended to further simplify the exercise of the right of withdrawal by requiring traders to provide a dedicated withdrawal function through their online interface. The aim is to ensure that consumers can withdraw from a contract as easily as they entered into it.
According to the Directive, the following obligations apply in relation to the implementation of the withdrawal function:
- the withdrawal function must be clearly labelled with the words “withdraw from contract here” or another unambiguous equivalent formulation, in a clearly legible form
- the withdrawal function must be continuously available throughout the withdrawal period and prominently displayed on the online interface, in a manner that makes it easily accessible to the consumer
- the withdrawal function must enable the consumer to submit an online withdrawal statement informing the trader of the consumer’s decision to withdraw from the contract
- the online withdrawal statement must enable the consumer to easily provide or confirm their name, details identifying the contract from which they wish to withdraw, and details of the electronic means by which confirmation of the withdrawal will be sent to the consumer
- the confirmation function must be clearly labelled with the words “confirm withdrawal” or another unambiguous equivalent formulation, in a clearly legible manner
Once the consumer has activated the confirmation function, the trader must, without undue delay, send the consumer an acknowledgement of receipt of the withdrawal via a durable medium (e.g. by email). The acknowledgement must include the content of the withdrawal and the date and time of its submission. The consumer shall be considered to have exercised the right of withdrawal within the withdrawal period if the online withdrawal statement is submitted before the expiry of the 14-day withdrawal period.
Accordingly, businesses that conclude contracts with consumers online, whether through a website or a mobile application, should assess whether their existing practices comply with the forthcoming requirements and, where necessary, plan and implement the required changes in a timely manner.
Member states are required to apply the implementing measures from today, 19 June 2026.
Country-specific implementation
Lithuania
Next steps
In Lithuania, the Directive has been transposed through amendments to the Civil Code and the Law on Consumer Protection. As of 19 June 2026, the relevant amendments apply, including the requirement to provide an online withdrawal function. Businesses concluding distance contracts with consumers in Lithuania through an online interface should therefore ensure that the withdrawal function is fully implemented and operational.
Failure to comply with the requirements
In Lithuania, compliance with the online withdrawal function requirements is supervised by the State Consumer Rights Protection Authority. If a trader fails to comply with these requirements, the Authority may require the infringement to be remedied and may impose a fine ranging from EUR 500 to EUR 5,000. However, where the infringement does not cause substantial harm to the consumer interests protected by law, the Authority may, having regard to all relevant circumstances and the principles of fairness and reasonableness, issue a warning instead of imposing a fine.
Latvia
Next steps
Amendments to the Consumer Rights Protection Law (CRPL) are currently under review by the Parliament (Saeima) and are intended to implement the requirements of the Directive. The new requirements will be transposed through amendments to the CRPL and the Cabinet of Ministers’ Regulations Regarding Distance Contracts.
Although member states have been required to implement the relevant provisions of the Directive from today, 19 June 2026, it is expected that the Latvian amendments will enter into force at a later date. Nevertheless, businesses should begin preparing for compliance now, as no transition period is currently envisaged.
Failure to comply with the requirements
Under the CRPL, a legal person may be fined up to EUR 1,400 for violations of the rules governing the sale of goods or the provision of services. In addition, non-compliant practices could potentially be qualified as unfair commercial practices under the Unfair Commercial Practices Prohibition Law. For violations committed on a widespread or national scale, the maximum fine for unfair commercial practices may amount to up to 4% of the company’s turnover in the preceding financial year, or, where turnover information is unavailable, up to EUR 300,000.
In addition to imposing fines, the Consumer Rights Protection Centre may also order other corrective measures necessary to ensure compliance with the applicable legal requirements.
Estonia
Next steps
The Directive has been transposed into Estonian law through the Act Amending the Law of Obligations Act and the Consumer Protection Act, which will enter into force on 1 September 2026. Although the Directive provides for an earlier date of application at EU level, businesses operating in Estonia should ensure that the withdrawal button requirement is implemented and operational by 1 September 2026.
Failure to comply with the requirements
The competent supervisory authority in Estonia is the Consumer Protection and Technical Regulatory Authority. Where a business fails to comply with the withdrawal button requirements, the Consumer Protection and Technical Regulatory Authority may issue a precept requiring the trader to bring its practices into compliance. If the trader fails to comply with this precept, a non-compliance fine may be imposed. The fine may be imposed repeatedly until compliance is achieved. Under the new amendment, the maximum single non-compliance levy for failure to include a withdrawal button is EUR 9,600.
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Contact our experts:
Partner in Lithuania, Head of the firm’s Trade and Consumer Goods sector group
vaiva.masidlauskiene@sorainen.com
Partner in Latvia, Head of Competition and Regulatory practice in Latvia
linda.reneslace@sorainen.com
Partner in Estonia, Co-head of the firm’s Technology, Media & Telecommunications sector group
mihkel.miidla@sorainen.com
