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A revolution in online returns: the „Cancel the contract” button becomes a reality 

Significant changes are coming for the e-commerce and online financial services sector. New EU Directive 2023/2673 aims to simplify the processes of cancelling online purchases and services. The most important novelty is the obligation to introduce a visible and easy-to-use withdrawal button, which is to be as accessible as the „Buy Now” button.

 

What does EU Directive 2023/2673 cover? 

Directive 2023/2673, sometimes referred to by experts as „Omnibus 2.0”, amends the rules on distance contracts. Although its main focus is financial services, it introduces key changes to the general Consumer Rights Directive (2011/83/EU) that will affect the broad e-commerce market. 

The main idea is to fight against the so-called 'old'. dark patterns (dark design patterns) - i.e. deliberately making it difficult for the consumer to find an option to cancel the service or return the goods. 

 

Key changes for e-shops and consumers 

  1. Mandatory „Withdraw from contract” button” According to the new Article 11a of the Directive, if the trader makes it possible to conclude a contract via an online interface (website, application), he must also provide a function allowing the contract to be terminated in the same way. This function must be: 
  • Permanently available within the withdrawal period of 14 days. 
  • Highly visible and clearly marked (e.g. with the words „Withdraw from the contract here”). 
  • Easily accessible - The consumer must not be forced to dig through multi-page regulations or download PDF files. 
  1. No more „hiding” of forms Currently, many shops require an email or a printed paper statement. Once the new regulations come into force, this process is to be simplified as much as possible - just a few clicks inside the customer's account or on a special returns subpage. 
  1. Immediate confirmation The trader will have to immediately acknowledge receipt of the declaration of withdrawal sent via the said function (e.g. by automatic email). 
  2. Protection in financial services The directive strengthens protection when taking out loans online, insurance or investments. Among other things, the consumer gains the right to „human intervention” (i.e. talking to a consultant instead of just a chatbot) if they want to better understand the impact of a contract on their financial situation. 

 

Does Polish law need to be changed? 

Yes. EU directives require implementation in the national legal order. Poland, like other member states, must amend the Consumer Rights Act. 

On schedule: 

  • Member States had until May 2024. 
  • The rules will become fully applicable from 19 June 2026. 

 

What are the risks for not implementing the changes? 

Ignoring the new rules can be costly. Traders who fail to provide an easy path to withdrawal expose themselves to: 

  • Extension of the right of return: If the consumer is not properly informed of the right of withdrawal or if the procedure cannot be carried out online, the time limit for the return may extend up to 12 months. 
  • Financial penalties: The President of UOKiK can impose a penalty of up to 10% of turnover for practices that violate the collective interests of consumers. 

 

Summary 

For e-shop owners, June (both the current implementation period and the final deadline in 2026) is the time to audit the purchase path. This change, although technically demanding, can benefit from greater customer confidence - after all, easy return is one of the key factors in choosing a particular online shop. 

 

 

Author of the blog: Adrian Smigiel
Date of publication: 21.04.2026r.

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