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Mandatory withdrawal button for online stores: what must businesses change before 1 September 2026?

Mandatory withdrawal button for online stores: what must businesses change before 1 September 2026?

From 1 September 2026, one important requirement will change for businesses that conclude contracts with consumers online in Estonia: if a consumer has the right to withdraw from a contract, the online interface must allow the consumer to exercise this right via a dedicated withdrawal button or a similar electronic function.

This is no longer a draft law. The amendment to the Law of Obligations Act and the Consumer Protection Act was adopted by Riigikogu on 13 May 2026 and will enter into force on 1 September 2026.

In short: what will change on 1 September?

If a consumer concludes a contract with a trader through an online user interface and the contract is subject to the right of withdrawal, the trader must provide an option to submit a withdrawal declaration directly online.

This means that a situation where a purchase can be made with a few clicks, but withdrawing from the contract requires searching for a PDF form, writing a separate email, or contacting customer service, is no longer sufficient.

According to the Riigikogu's explanation, the aim of the amendment is to make withdrawing from an online purchase or another contract concluded online as easy as entering into the contract.

Is the 14-day right of withdrawal new?

No.

For many contracts concluded by means of distance communication, consumers have for years had the right to withdraw from the contract within 14 days without giving a reason.

What is new is how consumers must be able to exercise this right online.

From 1 September, in situations where the new requirement applies, it will no longer be sufficient merely to provide an email address or a link to a downloadable withdrawal form in the terms and conditions of sale.

An electronic withdrawal function must be added to the online environment.

What must the withdrawal button be like?

The Law of Obligations Act stipulates that the withdrawal button or a similar function must be prominently displayed and labelled with the words:

“Withdraw from the contract”

or other equally clear, unambiguous and easily legible wording.

This is an important detail: the law refers to a withdrawal button or a similar function. Therefore, this is not merely a matter of adding a specific button to the website design, but of ensuring that the entire electronic withdrawal process works.

The function must be available to the consumer during the period in which they have the right to withdraw from the contract.

What information must the customer be able to enter?

The withdrawal function must allow the consumer to provide at least the following information online, making it possible to determine:

  • who withdraws from the contract;
  • which contract or order the consumer wishes to withdraw from;
  • the electronic means of communication through which the consumer wishes to receive confirmation of withdrawal.

The law specifies, among other things, the consumer's name and the information required to identify the contract.

In practice, an online store may use, for example, the order number, contract number or another specific identifier for this purpose.

A single “Withdraw from the contract” button may not be enough

The new regulation essentially also provides for a second step.

After entering the required information, the consumer must be able to confirm their decision. The confirmation function must be labelled, for example, with the words:

“I confirm the withdrawal”

or other equally unambiguous wording.

Thus, the online shop process could look like this, for example:

1. “I withdraw from the contract” → 2. order and customer details → 3. “I confirm the withdrawal” → 4. confirmation to the customer.

This also reduces the risk of an accidental click and provides both the business and the consumer with a clear record of the submitted withdrawal.

After withdrawing, the customer must receive confirmation

The European Union directive on the basis of which Estonian regulations were amended stipulates that the trader must send the consumer confirmation of receipt of the withdrawal notice without undue delay on a durable medium, for example by email.

In practical terms, this means that the trader should not build a solution where the customer clicks the button and sees only the message “form submitted”.

It is advisable to send an automatic email confirming that the withdrawal notice has been received.

Does the requirement really apply to every Estonian online store?

Not exactly.

This is one of the most important nuances.

The law links the new requirement to contracts concluded via an online user interface where a right of withdrawal exists.

Therefore, the first question to ask is:

Does the consumer have a statutory right of withdrawal for this particular contract?

This right does not apply to all goods and services.

For example, the Law of Obligations Act already provides for situations in which the standard 14-day right of withdrawal does not apply. Therefore, the new law does not automatically mean that a withdrawal button must be provided next to absolutely every product or service sold online.

Consumer protection regulations also primarily apply to contracts between businesses and consumers, rather than ordinary B2B transactions between two businesses.

Service providers should also review the change

The term “withdrawal button” may give the impression that the change only concerns traditional online shops that sell clothes, electronics or other physical goods.

That would be too narrow an interpretation.

In explaining the amendment, Riigikogu has also specifically stated that terminating a service must not be made unreasonably difficult when the contract itself was concluded online. Internet and mobile communication services were cited as examples.

Therefore, companies that sell the following online, for example, should also assess the impact of the change:

  • services;
  • memberships;
  • orders;
  • digital services;
  • communications contracts or other continuing contracts;
  • certain financial services.

However, for each specific contract, it must always be assessed separately whether and to what extent the right of withdrawal applies.

But what if the order is placed by email or phone?

The requirement for the new function applies to contracts concluded via an internet-based user interface.

This means that not every contract concluded remotely automatically becomes a “withdrawal button contract”.

For example, the situation may be different in the case of a contract concluded solely by phone or email. In the case of hybrid solutions—for example, where communication takes place by email but the contract is later signed in an online environment—the assessment depends on the specific process for concluding the contract.

Does the withdrawal button automatically mean a refund?

No.

The withdrawal button and returning goods are not the same thing.

The withdrawal function allows the consumer to submit a legally significant notice to the trader stating that they wish to withdraw from the contract.

After that, the usual consequences of withdrawal apply: depending on the contract, the customer may, for example, have to return the goods to the trader, and the trader becomes obliged to issue refunds in accordance with the procedure prescribed by law.

Therefore, the button should not be programmed so that each press automatically cancels the entire order and immediately issues a refund. The system must take into account the specific order and the conditions arising from the law.

What should an online store owner do before September 1?

Now, in August 2026, it is no longer advisable to postpone the change until autumn.

1. Check which contracts are concluded on your website

Map out separately:

  • physical goods;
  • services;
  • digital products;
  • subscription-based services;
  • other contracts concluded online.

Then check in which cases the consumer has the right of withdrawal.

2. Contact the online store's developer or platform provider

If you use WooCommerce, Shopify, Magento, or another e-commerce platform, check whether your current system already supports a withdrawal process that complies with Estonia's new requirement.

Do not assume that an existing “Return” or “Cancel order” function automatically complies with the requirements of the Võlaõigusseadus.

3. Create a clearly visible withdrawal function

The customer must be able to find it without writing to customer service or reading through several pages of terms and conditions.

The function must have a clear name, for example:

I withdraw from the contract

4. Create a withdrawal form

The form should at least make it possible to identify the consumer and the specific contract or order, and to specify how the customer can receive confirmation.

Do not ask for an unreasonable amount of additional information.

5. Add final confirmation

After verifying the information, the customer must be able to clearly confirm their withdrawal request.

For example:

I confirm the withdrawal

6. Set up automatic confirmation

After the request has been submitted, the customer should automatically receive an email confirming receipt of the withdrawal request.

7. Check the mobile version

If a customer can complete a purchase by phone in two minutes, but the withdrawal button is hidden three levels deep in the mobile menu, the solution may be contrary to the purpose of the requirement.

Test the entire process on both a computer and a phone.

8. Update the terms and conditions of sale and the withdrawal instructions

If your terms and conditions currently state only:

“To withdraw, send a statement to the email address…”

then the text must be reviewed after the new function is introduced.

Clearly explain to the customer how to use the electronic withdrawal function as well.

Will just an email address be sufficient after 1 September?

If the new withdrawal function requirement applies to a trader, then publishing only an email address is not sufficient.

The purpose of the new regulation is to ensure that, after entering into a contract with just a few clicks, consumers do not have to search for the customer service address, write a separate letter or download a document.

Justiits- ja Digiministeerium has summarized the purpose of the amendment with the principle that withdrawing from an online contract must be as easy as entering into it.

Does the button have to be on the homepage?

The law does not simply state that the withdrawal button must necessarily be located at the top of the online store's home page.

It is important that the function be clearly visible and easily accessible to the consumer while the consumer has the right to withdraw from the contract.

In practice, suitable locations could include, for example:

  • in the customer's account and order details;
  • in the order details view;
  • on a separate, clearly accessible “Withdrawal from the contract” page.

When designing the solution, it is worth starting not with the question “how can the button take up as little space as possible?”, but with the question “can an ordinary customer find it quickly?”

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For traders, the change means more than adding a single button

Technically, adding a withdrawal button may seem like a minor change.

In fact, the entire process should be reviewed:

customer → withdrawal button → contract identification → confirmation of withdrawal → notification to the trader → confirmation to the customer → process for returning the goods or service → refund.

If any of these steps remain manual, it is also worth considering who in the company monitors withdrawal statements and how quickly they are handled.

Frequently asked questions

When does the withdrawal button become mandatory?

In Estonia, an amendment to the Law of Obligations Act and the Consumer Protection Act will enter into force on 1 September 2026.

Will the 14-day right of withdrawal only take effect in September?

No. For many distance contracts, the 14-day right of withdrawal already exists. What primarily changes is the ability to exercise this right online.

Does the customer have to provide a reason for withdrawal?

When exercising the standard 14-day right of withdrawal, the consumer generally does not have to give a reason for their decision.

Does the button have to display exactly the text “Withdraw from the contract”?

The law also allows other equally unambiguous and easily readable wording, but “Withdraw from the contract” is an example explicitly provided in the law.

Is a standard PDF withdrawal form sufficient?

If the requirement for the new withdrawal function applies to a specific contract, a downloadable PDF alone does not replace the online function required by law.

Does the amendment apply only to sellers of goods?

No. The regulation may also apply to service contracts and other consumer contracts concluded online. Riigikogu has specifically emphasised that consumers must also be able to terminate services concluded online easily.

Summary

1 September 2026 is an important date for Estonian e-commerce.

Businesses that enter into contracts with consumers through an online user interface should already check whether their online environment complies with the new withdrawal function requirement.

The most important questions are:

  • whether the customer has the right of withdrawal for the specific contract;
  • whether the customer can find the withdrawal function quickly;
  • whether the contract can be uniquely identified;
  • whether the customer can confirm their decision online;
  • whether the company sends them confirmation that it has received the withdrawal notice.

The worst approach would be to start checking this on 1 September. If the online store requires development work, the change should be made and tested before the law enters into force.

Official sources

The legal basis for the change is the Võlaõigusseaduse ja tarbijakaitseseaduse muutmise seadus, which was published in Riigi Teataja on 20 May 2026.

The new version of the current Võlaõigusseadus sets out the requirements for a withdrawal function for contracts concluded through an online user interface.

The amendment is based on European Union Directive (EU) 2023/2673.

Artificial intelligence was used to assist in preparing this article. Although the information has been verified using official sources, legislation and its interpretations may change. For a specific case, it may be advisable to consult a qualified specialist if necessary.

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