SaaS plans sold to EU consumers need a "withdraw from contract here" button

Somebody in Hamburg pays 12 euros on a Tuesday for a month of your note-taking app's Pro plan. They are buying it for themselves. On Friday they decide it was a mistake. Since 19 June 2026, the law there says your app must give them a button labelled "withdraw from contract here" (in German, "Vertrag widerrufen"), and that button must let them send the withdrawal on the spot: a short form with their name, the contract and an email address, a second button labelled "confirm withdrawal", and a receipt by email 1 3. The rule comes from EU law, so the same applies across the EU. On the plain text of that law, if your terms never say where the button is, the 14 days they had to change their mind can stretch to more than a year, and you may not be able to charge them for the weeks they used. In Germany, trade associations are already sending warning letters to shops whose button falls short.

I spend most of my working week on interface design, and it is rare for a law to dictate the label on a button and the step after it. This one does. If you think of your product as B2B, read on anyway: a self-serve checkout that takes any credit card cannot tell a founder from a hobbyist, so most products with a card checkout and a personal-sized plan sell to some consumers. For those buyers, a paid SaaS plan is covered.

What does the withdrawal button rule require?

For a contract concluded through a website or app, the business has to provide a "withdrawal function" with five properties 1:

• The label. It reads "withdraw from contract here" or an equally unambiguous phrase, in an easily legible way.
• Availability. It is available for the whole withdrawal period, prominently displayed and easy to reach.
• The form behind it. It lets the consumer send a withdrawal statement in which they give or confirm their name, which contract they are withdrawing from, and where the receipt should go.
• A confirmation step. The statement is sent with a second button labelled only "confirm withdrawal" or an unambiguous equivalent.
• A receipt. After the confirmation, the business sends an acknowledgement "without undue delay" on a durable medium (an email works), with the content of the withdrawal and the date and time it was submitted.

The explanatory paragraphs at the start of the law (its recitals) add three practical points 1. A consumer who is already logged in should not have to identify themselves or the contract again. A consumer who bought on your website should not have to download your app to withdraw. And you may use hyperlinks that lead the consumer to the function.

Your terms change too. Before a consumer is bound, you already had to tell them about their right of withdrawal: the conditions, the time limit and how to use it. That same item now also has to cover "the existence and placement of the withdrawal function" 1, and Germany's rules copy that wording almost word for word 4. So your terms, or the withdrawal instructions you show at checkout, have to say where the button is.

Is my "cancel subscription" button enough?

No. A cancel button stops the next renewal. The withdrawal button undoes the contract, and you pay back what the customer paid within 14 days 2, minus the days used if they asked for the service to start straight away. A cancel button does not meet the rule, because the label, the form and the confirmation step are all set by the law. Germany also has a separate cancellation button for consumer subscriptions sold through a website 6, so a product selling there may need both.

The EU may add a general cancel rule later. Its planned Digital Fairness Act, which the European Commission had not published as of 29 October 2026, is expected in mid-November and is expected to address subscriptions that are hard to cancel. The withdrawal button does not wait for it.

Does it apply in my country yet?

Build for it wherever your consumers are. The rule is a new Article 11a in the EU's Consumer Rights Directive, added by Directive (EU) 2023/2673, and every EU country had to apply it from 19 June 2026 1. Some were slow to pass their own versions: in January 2026 the European Commission warned 21 of the 27 member states that their national laws were incomplete. Germany has since passed its version 3.

Does it apply to a SaaS subscription?

Yes, when the buyer is a consumer. The directive defines a consumer as an individual acting for purposes outside their trade, business, craft or profession 2. A company buying seats is not one. A person paying for a photo editor, a budgeting app or a writing tool for private use is.

For a consumer, a SaaS plan is a service contract: the directive's definition of a service contract expressly includes a digital service 2. Service contracts concluded at a distance come with 14 days to withdraw without giving a reason, counted from the day the contract is concluded 2.

Free trials move that day. In a case about an online learning platform whose free trial turned into a paid subscription, the EU's Court of Justice held that the customer has one right of withdrawal, at sign-up, provided the trial terms said clearly that payment would follow 7.

• If your trial page says clearly that it turns paid: the 14 days start at trial sign-up, so the button belongs on the trial account from its first day.
• If it does not: the judgment implies a second withdrawal right when the paid period starts, so the button has to be there again after the first charge.

Whether upgrading an existing free account starts a new contract is not settled. Until it is, I would show the button for 14 days after any upgrade to a paid plan.

The checkbox many checkouts carry ("start the service now, and I understand I lose my right of withdrawal") does not end the right on a subscription. It only ends once the service has been "fully performed" 2, and a subscription that runs month after month is not fully performed in its first two weeks.

A business-only product is out of scope. The definition turns on why the person buys 2, so a checkbox that private buyers tick without reading will not settle it on its own. A buyer who gives a company name and a VAT number is in a stronger position to be treated as a business. If you want to stay business-only, ask for both at checkout and sell only plans a private person would not buy, such as a minimum of three seats or billing by invoice.

What happens if the button or the sentence in your terms is missing?

The directive's text connects three provisions, and together they make a missing button expensive.

1. The information about "the existence and placement of the withdrawal function" is now part of the withdrawal information a business must give before the sale (Article 6(1)(h)) 1.
2. If a business does not give the withdrawal information, the withdrawal period does not end after 14 days. It ends 12 months after that 2.
3. A consumer who withdraws from a service contract bears no cost for the service they received during the withdrawal period if the withdrawal information was missing 2. The EU's Court of Justice has confirmed that this means nothing at all, even for a service already fully delivered 5.

Read together: if the Hamburg customer had kept the plan, and your terms never said where the withdrawal button is, they could still withdraw the following February and owe nothing for the months in between.

That is clearest where the button exists and the terms leave it out. Where there is no button at all, a business could argue that the placement sentence was only required "where applicable" 1. I find that weak, and as of October 2026 I have found no court decision on either case, so treat this as my reading of the text.

There is a way back. If you give the missing information later, the extended period ends 14 days after the consumer receives it 2.

The second cost is enforcement, and it varies by country. In Germany, competitors and trade associations can send formal warning letters (an "Abmahnung") that demand a signed promise to stop and a fee. The German e-commerce blog wortfilter.de has collected several since June, each aimed at a different defect. One shop's withdrawal link sat unstyled in the footer and led to three more steps before the form. Another shop's button was labelled "Widerruf" (withdrawal) but only opened the withdrawal instructions, so the withdrawal could not be sent through it.

If you sell paid plans to consumers in the EU, what should you change?

If you sell paid plans to consumers in the EU through a website or app, you need the button and a sentence in your terms that says where it is. Without them, a customer may be able to withdraw for more than a year and pay nothing for what they used. These are the changes, in the order I would make them:

• Add the button where your customers manage billing. Label it "withdraw from contract here", or the wording your customer's language and national law use (Germany's is "Vertrag widerrufen"). Show it for the withdrawal period: from trial sign-up if your trial turns paid on its own, after the first charge too if your trial page did not say so clearly, and for 14 days after any upgrade. Link to it from the confirmation email as well.
• Prefill the form. A logged-in customer should see their name, the plan and their email address already filled in, and only have to press "confirm withdrawal".
• Send the receipt automatically. An email with what was withdrawn and the date and time, sent straight away.
• Write the placement into your terms. One sentence in the withdrawal section, for example: "You can withdraw using the 'withdraw from contract here' button on your Billing page for 14 days after your purchase." If the billing page moves, that sentence has to move with it.
• Fix the customers you already have. If consumers signed up while your terms said nothing about the button, send them the corrected withdrawal information. Their withdrawal period then ends 14 days after they receive it.
• Ask before starting the service. At checkout, get the customer's express request to start the service immediately, so a withdrawal costs you only the unused part of the price.
• Check Germany's cancel button. If you sell subscriptions to consumers in Germany, you also need a "Verträge hier kündigen" (cancel contracts here) button leading to a confirmation page with a "jetzt kündigen" (cancel now) button 6.

Terms that describe your product go out of date as the product changes, the same way a privacy policy drifts away from the product it describes. Lawcel, the tool we build, reads each pull request and flags changes that may affect your legal documents.

If you sell only to businesses, none of this applies. How a business customer leaves is set by your contract and by the Data Act's switching rules.