In Germany, anyone who signs a contract online has been able to cancel it online since July 2022. Since 19 June 2026, something similar applies to withdrawals: online shops and providers of distance contracts must offer an electronic withdrawal function. And in July 2026, Germany’s Federal Court of Justice (BGH) made clear just how strictly lawmakers meant the cancellation route. Many companies see this as a job for web development and legal. In practice, much of the impact lands in customer service: cancellations still arrive by phone, email and chat, confirmations have to go out immediately, and the question “Am I still allowed to make an offer?” comes up every day.
This article covers the legal situation in Germany for contracts with consumers (B2C). The button obligations do not apply to business customers. The withdrawal button is based on an EU directive, so comparable rules apply across the EU, but details differ by member state. This article is not legal advice.
Three buttons, three purposes
German e-commerce now has three legally required buttons that are often confused:
- Order button (Section 312j German Civil Code, BGB): makes clear at checkout that the customer is entering a payment obligation.
- Cancellation button (Section 312k BGB): applies to paid ongoing contracts that can be concluded via a website, such as subscriptions, maintenance or software contracts. It leads to a confirmation page with a button such as “cancel now”.
- Withdrawal button (Section 356a BGB, since 19 June 2026): lets consumers withdraw from distance contracts concluded online. It implements EU Directive 2023/2673. Clear labels such as “withdraw from contract” are required, and the withdrawal only takes effect after a second confirmation step.
The withdrawal button does not replace the cancellation button. Anyone selling subscriptions online usually needs both.
What the BGH decided in July 2026
In a case brought by the Federation of German Consumer Organisations against a fitness chain (judgment of 16 July 2026, I ZR 200/25), the issue was a prominent “pause contract” button on the confirmation page of the online cancellation. The court prohibited it: the law defines the content of the confirmation page conclusively. Apart from the information needed for the cancellation and the confirmation button, there is no room for alternative offers or additional notices.
Still open is whether providers may require a password login before cancellation. The Berlin Court of Appeal had treated this as an unlawful hurdle in two cases, saying details such as name and address are enough for identification. The BGH heard both cases (I ZR 275/25 and I ZR 272/25) on 5 November 2026. At the time of writing, we had not seen a published decision. If you currently put a login in front of cancellation, have it reviewed.
Immediate confirmation: a process, not a template
Both buttons trigger confirmation duties. After an online cancellation, the provider must immediately confirm electronically in text form the content of the notice, the date and time it was received, and the date on which the contract ends. For withdrawals, an acknowledgement of receipt on a durable medium, including content, date and time, is due without undue delay.
In practice, the confirmation has to be generated automatically, not when someone in the team happens to open the inbox. At the same time, the service team needs to keep track of the case, because the confirmation is followed by questions about remaining terms, refunds or returns. A proven approach is to create every cancellation and withdrawal as a case in the ticketing system, with a fixed contact reason, a deadline and the linked confirmation.
Cancellations by phone, email and chat
The button is an additional route, not an exclusive one. Many customers still call or send an email. Under German law, standard terms for consumers may require at most text form for cancellations (Section 309 no. 13 BGB). Whether a verbal cancellation by phone is valid therefore depends on the contract. Even so, the service team’s answer should never be “That’s not how it works”. Instead:
- document the cancellation request in the case,
- where needed, point directly to the cancellation button or an address for text form, ideally by sending a link after the call,
- route cancellations from email and chat into the same process as online cancellations, including confirmation and deadline.
With a dedicated “cancellation” or “withdrawal” contact reason in routing, these requests are bundled and reach trained agents. This reduces the risk of a cancellation sitting in a general inbox and later being considered unprocessed.
Win-back without hurdles
Talking to customers about why they cancel is not prohibited. But it must not take place on the confirmation page or delay the cancellation. A fair process accepts and confirms the cancellation first. Only then can an offer follow, for example as a voluntary note in the confirmation email or in a conversation if the customer calls anyway. Unsolicited win-back calls count as advertising and, under German unfair competition law (Section 7 UWG), require prior express consent from consumers.
For analysis, a simple look at the reasons for cancellation pays off. Asking for them voluntarily and after confirmation often tells you more than any retention loop.
Conclusion
The cancellation button, the withdrawal button and the BGH ruling share one goal: leaving a contract should be as easy as entering it. For service teams, this means clear processes instead of case-by-case decisions: immediate confirmations, a dedicated contact reason for cancellations and withdrawals across all channels, and win-back only after confirmation. With myContactCenter from ilogixx, you bring calls, emails and chats together in one ticketing system, route cancellation requests to the right agents and keep deadlines in view. We are happy to discuss what this could look like for your service team. Book a consultation directly via the online calendar at ilogixx.de.
