Widerrufsbutton § 356a BGB: the new withdrawal button binding for German online shops from 19 June 2026
From 19 June 2026 every German consumer contract concluded online for a continuous obligation has to expose a one-click withdrawal button. Section 356a of the German Civil Code, transposing Directive (EU) 2023/2673, requires the button to be permanently accessible, labelled with statutory wording, and reachable without a login. Here is what is in scope, what the button must do, and where Shopify and WooCommerce stores are most exposed.
From 19 June 2026 every German online shop selling a contract that creates a continuous payment obligation has to display a withdrawal button. The rule lives in the new Section 356a of the Bürgerliches Gesetzbuch and transposes Article 4 of Directive (EU) 2023/2673 on the modernisation of consumer rights through digital tools. Germany was the first member state to legislate, with neighbouring member states expected to follow during 2026 and 2027.
If your store sells anything that resembles a subscription to a consumer (a monthly box, a streaming pass, a coaching programme, a SaaS plan), the button applies to you.
What does the law say?
Bei Verträgen im elektronischen Geschäftsverkehr, durch die ein Verbraucher eine entgeltliche Dauerverpflichtung eingeht, hat der Unternehmer dem Verbraucher eine Funktion zur Verfügung zu stellen, mit der dieser den Widerruf des Vertrags ohne Weiteres mit einer eindeutigen Erklärung erklären kann.
The button has to be permanently visible while the contract is active and reachable without a login on the same online interface where the contract was concluded. The label is prescribed: "Verträge hier widerrufen" or a comparable, equally unambiguous wording. The click leads to a confirmation page that captures the withdrawal declaration and triggers an automatic receipt to the consumer on a durable medium (Section 356a paragraph 3 BGB).
EnforcementFederal Court of Justice, judgment of 9 November 2023, case III ZR 105/22: the parallel Kündigungsbutton under § 312k BGB is interpreted strictly. A button labelled "Mein Konto kündigen" instead of the statutory "Verträge hier kündigen" was held insufficient. The decision is widely expected to map across to § 356a.
Who is in scope?
Section 356a covers every contract concluded over an electronic interface, with a consumer, that creates a continuous payment obligation. The Bundesministerium der Justiz explanatory memorandum gives examples: subscription boxes, music and video streaming, fitness apps, dating apps, magazine subscriptions, energy contracts, mobile contracts, and SaaS plans sold to consumers. One-off purchases are outside the scope.
Crucially, the rule applies to traders established outside Germany if they direct their offer to German consumers. A Shopify store based in Ireland that sells a monthly tea-of-the-month box to German addresses is subject to § 356a from 19 June 2026.
Why the button matters even more than it sounds
If the button is missing or defective, the consumer's 14-day withdrawal period under § 355 BGB does not start to run. The Federal Court of Justice has already held under § 312k that a missing or wrongly-labelled cancellation button means the consumer can cancel at any time, not within a window. The same reading is expected to extend to § 356a. In effect, a missing button converts a 14-day withdrawal window into an indefinite one, exposing the trader to refunds months or years after delivery.
Where Shopify and WooCommerce subscriptions break
Most subscription apps for Shopify and WooCommerce expose a customer-portal cancellation path behind login. That solves the parallel § 312k requirement, but § 356a is stricter. The withdrawal button must be reachable on the public interface without a login. The current Recharge, Bold Subscriptions, and WooCommerce Subscriptions defaults do not include a public withdrawal entry point. German stores running these apps therefore need to add a permanent button to a public page (the home page header, the footer, or a dedicated /widerruf URL) that opens the statutory withdrawal flow.
How we test thisComplianceGuardHQ does not assume your storefront violates § 356a yet. We assume your subscription stack was not designed around a public, login-free withdrawal entry point. A scan from 1 May 2026 onwards checks for the presence of the button on every page of a German storefront, its label, its accessibility without a session, and the existence of a confirmation step that captures a durable-medium receipt.
What to do this week
If your store sells continuous-obligation contracts to German consumers, the working clock is short. Add a permanent button labelled "Verträge hier widerrufen" to the public footer linking to a /widerruf URL. The URL should expose a simple form (contract identifier, email, optional reason) that submits a withdrawal declaration and immediately emails a confirmation to the consumer in machine-readable format. Wire the same page into the customer portal so authenticated users see it too.
Run a free scan of your live storefront and ComplianceGuardHQ will flag whether a withdrawal button is present, whether its label matches the statutory wording, and whether the linked flow returns a confirmation page on submission. The scan takes about 60 seconds and requires no install.
Frequently asked questions
When does the Widerrufsbutton § 356a BGB take effect?
Section 356a BGB takes effect on 19 June 2026 for all consumer contracts concluded online that create a continuous payment obligation. The rule transposes Article 4 of Directive (EU) 2023/2673 on the modernisation of consumer rights through digital tools.
What label is required for the withdrawal button?
The statute prescribes the wording "Verträge hier widerrufen" or a comparable, equally unambiguous label. Federal Court of Justice case law on the parallel Kündigungsbutton (§ 312k BGB), judgment of 9 November 2023 in III ZR 105/22, applies strict interpretation: paraphrases such as "Mein Konto kündigen" have been held insufficient.
Does the Widerrufsbutton apply to one-off purchases?
No. Section 356a BGB applies only to consumer contracts that create a continuous payment obligation, such as subscriptions, streaming, magazine deliveries, energy contracts, mobile contracts, and SaaS plans. One-off product purchases on a Shopify or WooCommerce store remain outside the scope, although the general 14-day withdrawal right under § 355 BGB still applies.
Does the button apply to non-German traders selling to German consumers?
Yes. The rule follows the German conflict-of-laws regime for consumer contracts. A trader established outside Germany who directs their offer to German consumers (German-language storefront, prices in euros, German delivery options) is bound by § 356a BGB from 19 June 2026.
What happens if my store does not provide the button?
The 14-day withdrawal period under § 355 BGB does not start to run until the trader complies. Federal Court of Justice case law on the parallel § 312k expects the same reading. A missing button therefore converts a 14-day withdrawal window into a potentially indefinite one, exposing the trader to refunds months or years after delivery, plus separate liability under the UCPD for the omission.
Run the check on your store
ComplianceGuardHQ runs 37 automated checks across 8 EU frameworks against your live storefront in about 60 seconds. Free baseline scan, no install.
Run a Free ScanComplianceGuardHQ runs an automated technical scan. Findings cite the directive text and enforcement precedent. They are not legal advice. Consult a qualified lawyer or Data Protection Officer for binding interpretation in your jurisdiction.