The mandatory withdrawal button for online shops – what do businesses need to consider?

Created by Mag. Sylvia Unger |
Civil Law , General Terms Of Contract

The ‘Verbraucherrechts-Änderungsgesetz 2026’ (Consumer Rights Amendment Act, (VerbRÄG 2026)), which was announced in July 2026, introduced far-reaching changes to the Distance and Off-Premises Sales Act (FAGG). The new provisions include, amongst other things, an obligation for businesses to provide a withdrawal button in online shops (§ 13a FAGG). This amendment comes into force on 1 October 2026 and applies to all contracts concluded after 30 September 2026.

 

1. What is the ‘withdrawal button’?


The withdrawal button is a feature that enables consumers to send a notice of withdrawal to the trader online. The aim is to make it just as easy to withdraw from a contract as it was to enter into it.

 

2. Which businesses are required to provide a withdrawal button?

All businesses that conclude distance contracts with consumers via an online user interface (= the visible and interactive part of a web shop, app or website).

Contracts concluded by telephone or email are not covered!.

 

3. How does the withdrawal button need to be designed?


The withdrawal button must meet the following requirements:

  • Easily accessible

  • Prominent and clearly legible (e.g. through colour or font size)

  • Clearly worded

Note: We recommend using the legally prescribed phrases ‘withdraw from contract here’ and ‘confirm withdrawal’ (see also the next question).

  • continuously available and clearly visible during the withdrawal period

 

4. How does a cancellation via the withdrawal button work?

When the button (‘withdraw from contract here’) is clicked, an online withdrawal form appears, which must contain the following details:

  • The consumer’s name,

  • Details identifying the contract from which withdrawal is to be declared,

  • Details of the electronic means of communication (e.g. email, messaging service, app) via which the confirmation of receipt is to be sent to the consumer.

Note: It is both possible to leave it to the consumer to enter this information (‘provide’) as well as to offer information that has already been pre-filled (‘confirm’).

The consumer then submits the online notice of withdrawal to the trader by clicking a confirmation button (‘Confirm withdrawal’), whereupon the trader provides the consumer with an acknowledgement of receipt on a durable medium.

 

5. What questions do companies that run an online shop need to ask themselves now?

  • How are the right of withdrawal and the associated process currently regulated, and what needs to be adjusted? 

  • Is the consumer informed about this right of withdrawal in a clear and comprehensible manner before the contract is concluded?

  • What changes are required, in particular, to the terms and conditions, the cancellation policy and the privacy policy?

  • Is the withdrawal button clearly visible, easily accessible, clearly worded and available throughout the entire withdrawal period?

  • Does the withdrawal form contain all the necessary information?

  • Is there a separate confirmation button that submits the form in a legally binding manner?

  • How is the acknowledgement of receipt sent? Is automated transmission possible? 

 

6. From when do affected businesses have to provide the withdrawal button?

The changes relating to the withdrawal button will come into force in Austria on 1 October 2026 and will apply to contracts concluded after 30 September 2026. 

Be careful with cross-border online shops! Whilst Austria was late in implementing the regulations, other countries (particularly Germany) implemented them on time, which is why the requirement to provide a withdrawal button has been in force there since June 2026!

 

7. What other changes are there?

The legal framework is being restructured by repealing the “Fern-Finanzdienstleistungs-Gesetz” (FernFinG “Distance Financial Services Act”) and incorporating a separate section on distance contracts for financial services into the FAGG (§ 18a–18d FAGG).

New regulations, such as the obligation to provide information on the durability and reparability of products, are intended to promote more sustainable consumer behaviour.

In this blog, you can find out more about the other changes.

 

About the author:
Ms Mag. Sylvia Unger has been a solicitor for over 25 years and founded her own law firm, ‘Unger Rechtsanwälte’, in 2011.

Her areas of specialism include employment law, company law, contract law and payment transactions law. She is the (co-)author of several specialist books, gives lectures on employment law, company law and payment transactions law, and advises companies across a wide range of sectors.