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Widerrufsbutton: What Your Online Shop Must Do by June 19, 2026

·Rechtsanwalt··2 min read

The new withdrawal button is not the existing Kuendigungsbutton under § 312k BGB. From June 19, 2026, every B2C distance contract concluded via an online interface must offer a Widerrufsfunktion for the 14-day withdrawal right.

The legal basis is Directive (EU) 2023/2673, which amends the Consumer Rights Directive (2011/83/EU). Germany's Referentenentwurf of 9 July 2025 proposes a new § 356a BGB; the final section number may still shift. Member States had to transpose by 19 December 2025; traders must comply from 19 June 2026 regardless.

The button works in two steps. First, a clearly labelled button ("Vertrag widerrufen" or equivalent) opens a form where the consumer enters contract details. Second, a "Widerruf bestätigen" button submits the declaration. The trader must then immediately send an Eingangsbestätigung on a durable medium with content, date, and exact time of receipt.

Scope turns on § 13 BGB: a consumer is a natural person acting for purposes outside their trade or profession. A freelancer using a B2B tool for work is not a consumer. But if any signup path is genuinely open to private users, audit it as the same edge case that catches founders on GDPR scoping for B2B SaaS. In the startups I talk to, that private-user flow is what most often slips through; the Widerrufsrecht follows the contract purpose, not the billing plan.

Non-compliance is an Ordnungswidrigkeit. Commentary cites fines up to 4% of turnover (above EUR 1.25M revenue) or EUR 50,000 for smaller firms, but that ceiling tracks the CPC Regulation; the domestic range lands with the enacted bill. Competitors can send UWG-Abmahnungen; qualified consumer associations act under the UKlaG.

What to do by mid-June: audit signup, checkout, and account flows for consumer contracts, add the two-step button with Eingangsbestätigung email, and keep the function available throughout the withdrawal period.

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