The withdrawal-button obligation in all 27 EU member states: laws, status, exceptions

One directive, 27 national transpositions. This overview collects the transposition measures each member state notified to the EU (source: EUR-Lex, as at 17 August 2026) and names separately where dates or rules diverge.

Last reviewed: August 2026 · Guide

How to read this overview

The basis is the list of national transposition measures that member states reported to the Commission for Directive (EU) 2023/2673 (EUR-Lex, CELEX 32023L2673, retrieved 17 August 2026). The transposition deadline was 19 December 2025; the directive applies from 19 June 2026. "Not notified" means no measure is (yet) recorded at EUR-Lex – not necessarily that none exists.

Divergences and exceptions

What "not notified" means – and what it does not

The EUR-Lex database records only what a member state has reported to the Commission. That is not the same as "there is no law". The Netherlands are the clearest example: the obligation is in force there through art. 6:230oa BW since 19 June 2026, yet EUR-Lex lists no measure. Anyone relying on the database alone would wrongly treat a Dutch store as unaffected.

The reverse also holds: in Spain and Poland the transposition really is still missing – in Poland the draft had not even reached parliament. That is no licence to wait: courts must read existing national law in the light of the directive, and cross-border sales into transposed states are already covered there.

Seven member states have not transposed the directive yet – but they are at very different stages. Bulgaria has a bill approved by the Council of Ministers on 08.06.2026 (decision no. 441); Poland has draft UC82, which has not left the government stage; Slovenia has draft ZVPot-1A from the February 2025 consultation. Spain has no transposition into the LGDCU, and neither has Portugal – where the withdrawal right itself sits in Decreto-Lei 24/2014. For Luxembourg and Latvia no draft is traceable.

That this delay is not an isolated case is on record from the Commission itself: on 30.01.2026 it opened infringement proceedings against 21 member states that had not communicated complete transposition. That brings traders no comfort: a directive that has not been transposed binds the state, not private parties directly – but courts must interpret existing national law in its light as far as possible, and anyone selling into states that have transposed it is already bound there.

Dates

• Germany and France have applied the obligation since 19 June 2026. It follows from Art. 11a of Directive 2011/83/EU, which itself covers all distance contracts concluded online that carry a right of withdrawal – not only financial services.
• Two states have an expressly later start date. In Estonia the duty bites only from 1 September 2026; in Austria § 13a FAGG applies only from 1 October 2026 (contracts after 30 September 2026). Selling from Austria into Germany or France does not extend that grace.
• For the remaining states the directive's timetable applies; what governs is the respective national publication.

What is the same in every member state

The labelling is not a national peculiarity. Art. 11a of Directive 2011/83/EU requires the withdrawal function to be legibly labelled "withdraw from contract here" or with a corresponding unambiguous formulation. Germany copied that verbatim into § 356a (1) sentence 2 BGB. A button reading "start a return" or "cancel order" does not obviously satisfy it.

Equally harmonised are the two-step flow – withdrawal function, then a separate confirmation function – and the content of the acknowledgement: the content of the declaration, date and time, on a durable medium.

National transpositions restate the same requirement in their own language: France "renoncer au contrat ici", Italy "recedere dal contratto qui", Slovakia "odstúpiť od zmluvy tu", Sweden "ångra avtalet här", Lithuania "atsisakyti sutarties čia", Estonia "Taganen lepingust". The difference is linguistic, not substantive.

Enforcement styles

• Germany: the main exposure is the competition-law warning; on top, a fine of up to €50,000 and the extended withdrawal period.
• Italy: the transposing decree (D.Lgs. 209/2025) names €7,500 to €75,000 per infringement and a nullity the judge may raise of their own motion – both located in the section on distance financial services (artt. 59-bis ff. Cod. cons.). Which regime applies to breaches of art. 54-bis for ordinary goods and services we will only state after professional review.
• France: administrative fines from the DGCCRF – up to €15,000 (natural person) and €75,000 (legal person), art. L242-13 Code de la consommation.

For the remaining states we still name no amounts. A wrong figure in a compliance text is worse than none.

Who enforces – the difference that really matters

With sanctions the eye goes to the amounts first. What matters more is who imposes them, because that is where Germany differs from almost every other member state.

• Germany takes its own path: enforcement lies largely in private hands. Competitors and qualified consumer associations have an injunction claim – that is where the cease-and-desist warning comes from. There is no general consumer protection authority for this field.
• Most other states rely on an authority that often combines consumer and competition protection: the DGCCRF in France, the AGCM in Italy, the ACM in the Netherlands, the ANPC in Romania, the KKV in Finland, the VVTAT in Lithuania.
• The Modernisation Directive (EU) 2019/2161 strengthened this administrative model across the Union.

In practice: in Germany a competitor's lawyer writes; elsewhere an authority opens a file. Anyone selling across borders can meet both – the bodies cooperate through the CPC network (Regulation (EU) 2017/2394).

Which authority is competent for the withdrawal function in detail we have not researched state by state. The six named are documented, the others are not.

Careful with the titles of the measures

Several notified acts carry "financial services" in the title (Ireland, Slovakia, Hungary among them) – that matches the core of the directive, but the withdrawal function applies to all consumer contracts concluded online that carry a right of withdrawal. How completely a national act implements that horizontal part cannot be read off the title; in case of doubt that belongs in a legal review.

For two of those states we looked, and the suspicion does not hold: in Ireland the Regulations insert a section 115A into the Consumer Rights Act 2022 – a general consumer statute, not financial services law. In Slovakia the financial-services act adds, through its Article III, a § 20a to the general Consumer Protection Act 108/2024. The title misleads; the transposition does not. Several states (Czechia, Slovakia, Hungary, Lithuania, Finland) also notify whole lists of existing statutes – the actual transposition core sits in the most recent acts.