"Cancel Contract" button from 1 January 2027: an obligation for every e-shop

From 1 January 2027, every e-shop and any other trader that concludes contracts with consumers via a website or an app must offer a "Withdraw from contract" button. The obligation is introduced by the new Section 1830a of the Czech Civil Code, supervision lies primarily with the Czech Trade Inspection Authority (CTIA), and the fine is up to CZK 5 million. The lawyers at ARROWS law firm explain how to set up the button, what to change in your terms and conditions and what applies to financial services.

What Changes from 1 January 2027 and Why

The button for withdrawing from a contract (in European terminology, the "withdrawal function") is brought into Czech law by Act No. 159/2026 Coll. It implements Directive (EU) 2023/2673, which amended the European Consumer Rights Directive. The European date from which the new rules were to apply was 19 June 2026. The Czech legislation does not take effect until 1 January 2027.

What matters is where the legislator placed the new rule. The new Section 1830a of the Civil Code is part of the general rules on distance contracts – that is, contracts concluded remotely, without the simultaneous physical presence of the parties. It therefore applies to the ordinary sale of goods, subscriptions, digital content and services. It also covers financial services: the Civil Code otherwise excludes them from the general rules on distance contracts, but for the button it expressly provides an exception to that exception.

Beware of the common assumption that an email or a model form in PDF is enough. The consumer may still withdraw by any unequivocal statement, such as a letter or an email. However, the trader must now enable the consumer to withdraw also by means of a button directly in the online interface.

Who is affected by this obligation

The obligation applies to a trader who has concluded a distance contract with a consumer through an online interface, where the consumer has a statutory right to withdraw from it. Typically, this concerns:

• e-shops selling goods, including sales through their own mobile app,

• online subscriptions, memberships and digital services,

• providers of services arranged via a website (courses, servicing, energy, telecommunications),

• banks, insurance companies, credit providers and other providers of financial services arranged online.

Conversely, the obligation does not apply to contracts where the consumer has no right of withdrawal. The Civil Code lists, for example, goods customised to the customer's wishes, perishable goods, hygienically sealed goods once the packaging has been broken, or accommodation, catering and leisure services for a specific date.

Certain types of contracts also fall outside the general rules on distance contracts – for example, contracts for healthcare, social services, betting and gaming, the transfer of real estate, residential leases, passenger transport or package travel. Nor does the obligation apply to business-to-business (B2B) transactions.

What the Button and the Whole Process Must Look Like

The law does not describe only the button itself, but the customer's entire journey from the click to the confirmation. The process has four mandatory steps.

1. The "Withdraw from contract" button. It must be displayed prominently in the online interface, be easily accessible and be available continuously throughout the withdrawal period. The label must read "Withdraw from contract" or use another equally unambiguous wording.

2. The withdrawal declaration. After clicking, the consumer must be able to easily fill in or confirm three items: their name, details of the contract they are withdrawing from, and an electronic contact (typically an email address) to which the confirmation will be sent.

3. The "Confirm withdrawal from contract" button. The declaration is submitted by a second button with the easily legible label "Confirm withdrawal from contract" or another unambiguous wording.

4. Acknowledgement of receipt. The trader must, without undue delay, confirm receipt of the declaration to the consumer in text form at the electronic contact provided, including its content and the date and time it was sent.

In practice, it is worthwhile to generate the confirmation email automatically and to store a copy of it with a timestamp. If the customer later claims to have withdrawn in time, it is precisely this audit trail that is decisive.

How long the button must be available

The button must work throughout the withdrawal period. For the sale of goods, this is usually 14 days from receipt of the goods. Where goods are delivered in several consignments, the period runs from receipt of the last item or the last part of the delivery.

If the trader did not inform the consumer of the right of withdrawal at all, the period is extended by up to one year. It is therefore not enough to display the button for only 14 days from the order. It is safer to link its display to the actual delivery date and, in disputed cases, to keep it active for longer.

What to adjust in pre-contractual information and terms and conditions

From 1 January 2027, the scope of mandatory information before the conclusion of a contract also changes. For a contract concluded online, the trader must state, in addition to the conditions, time limit, procedure and model withdrawal form, information on the possibility of withdrawing by means of the button and on where the customer can find the button.

In your terms and conditions and in the order confirmation, you should therefore add where the button is located (for example, in the order details or on the "My Orders" page) and how the process works. Failure to provide a mandatory piece of information is a separate administrative offence. It also opens up a dispute as to whether the customer was properly informed of the right of withdrawal and, therefore, whether the period was extended by one year.

The lawyers at ARROWS law firm will review your terms and conditions, pre-contractual information and the texts of your confirmation emails so that they comply with the wording of the law as of 1 January 2027. Write to us at konzultace@arws.cz.

Financial Services: The Button and Other New Obligations

For distance contracts for financial services – loans, insurance, payment, investment or pension services – the button applies in the same way as for e-shops. In addition, Act No. 159/2026 Coll. rewrites the general rules of the Civil Code on distance financial services:

• Pre-contractual information: the mandatory items now also include information on the withdrawal button and its location.

• Prohibition on layering key information: in electronic communication, the provider's identity, the description of the service, the total price and information on the right of withdrawal, among other things, must not be "hidden" in further layers (expandable links).

• Adequate explanation: the trader must explain the essential information about the service to the consumer free of charge. If the trader used only an automated tool for this purpose (for example, a chatbot), the consumer has the right to an explanation by a human.

• Burden of proof: in case of doubt, the trader must prove that it provided and explained the information.

• Prohibition of manipulative interfaces: when concluding distance contracts for financial services, an interface that deceives or manipulates the consumer or materially impairs their free decision-making, including by giving certain options greater prominence, is expressly prohibited.

Note: the information duties and the duty to explain under the Civil Code do not apply where the sector has its own rules. The law expressly excludes them for consumer credit, investment services and funds, insurance distribution and, to a large extent, payment services (the duty to inform about the right of withdrawal always remains, however, with the exception of life insurance and consumer credit, where separate rules apply). The withdrawal button applies to these services regardless.

The withdrawal period for a financial service contract is 14 days, and 30 days for a pension service. For life insurance, the policyholder has 30 days under a special provision on insurance contracts. Withdrawal is not possible, for example, in the case of services whose price depends on movements in the financial markets, travel or baggage insurance with an insurance period of less than one month, or where the obligation has been fully performed by both parties at the consumer's express request.

What this means for an e-shop offering instalments or insurance

If a customer concludes a credit or insurance contract with a financial institution in the e-shop's shopping cart, the obligations under that contract are borne primarily by the financial service provider as the contracting party. In fact, however, the contract is concluded in the e-shop's interface. It is therefore necessary to resolve, contractually and technically, where and how the button for withdrawing from the financial service will be available and who is responsible for the confirmation.

Bear in mind the link between the contracts as well. If the consumer withdraws from the purchase contract, ancillary contracts also terminate by law, for example insurance of the goods arranged with a third party on the basis of an agreement with the seller. The processes for both contracts must therefore be interlinked.

For entities holding a licence or registration from the Czech National Bank (CNB), supervision of the button, the information duties and the prohibition of manipulative interfaces is carried out by the CNB. The attorneys at ARROWS help financial service providers and e-shops set up cooperation agreements and rework their pre-contractual documentation; get in touch at konzultace@arws.cz.

What Penalties Apply and Who Supervises

From 1 January 2027, failure to comply with the obligations relating to the button is a separate administrative offence under the Consumer Protection Act. A seller commits it if it does not enable the consumer to withdraw by means of the button in the online interface or does not confirm receipt of the withdrawal declaration. The fine may reach CZK 5,000,000.

If the infringement is dealt with as part of a coordinated action by European supervisory authorities under Regulation (EU) 2017/2394, a fine of up to 4% of the seller's total annual turnover may be imposed. If information on turnover is not available, the upper limit is CZK 50,000,000.

Supervision is carried out primarily by the CTIA. For financial institutions supervised by the CNB, the supervisory authority is the CNB; in the energy sector, it is the Energy Regulatory Office; and for electronic communications services and postal services, it is the Czech Telecommunication Office. For food and other selected sectors, checks are carried out by specialised authorities, for example the Czech Agriculture and Food Inspection Authority.

In addition to a fine, there are also civil-law consequences: a dispute over whether the customer withdrew in time, and the risk that the withdrawal period will be extended.

Manipulative design

The Digital Services Act (DSA) prohibits manipulative design for providers of online platforms (for example, marketplaces), not for every e-shop. For an ordinary e-shop, the Consumer Protection Act is decisive: obstruction of withdrawal – for example, a hidden or greyed-out button, repeated "Do you really want to leave?" prompts or making withdrawal conditional on a phone call – may be assessed by the CTIA as an aggressive commercial practice. Among the criteria, the Act expressly mentions a disproportionate non-contractual barrier to the exercise of the consumer's rights. For distance financial services, an express prohibition of manipulative interfaces also applies from 1 January 2027.

Practical Steps to Take by 31 December 2026

1. Map where you conclude contracts online. Website, mobile app, customer account, third-party platforms – every interface through which a consumer concludes a contract.

2. Identify the contracts with a right of withdrawal. Separate the items for which the law excludes withdrawal and set up the logic for displaying the button for them.

3. Design and test the process. The button, the form with three items, the confirmation button and the automatic confirmation with the content, date and time. Test on mobile devices and for purchases made without registration as well.

4. Update your documents. Terms and conditions, pre-contractual information, order confirmations and, for financial services, pre-contractual forms as well.

5. Train your customer support. A withdrawal received via the button must feed into the refund of money and the return of goods within the standard time limits.

The legal reality tends to be more complex than the technical specification: combined orders, subscriptions with automatic renewal, digital content or sales via a marketplace require individual solutions. The attorneys at ARROWS have long focused on consumer protection and e-commerce and, thanks to the ARROWS International network, can also help e-shops that sell to several EU Member States. Contact us at konzultace@arws.cz.

Final Summary

From 1 January 2027, every business that concludes contracts with consumers via a website or an app must offer a “Withdraw from contract” button. This does not apply only to banks and insurance companies – the obligation covers ordinary e-shops, subscriptions, and digital services as well. The law precisely specifies the form of the button, the form, and the confirmation, and breaching these requirements is an administrative offence punishable by a fine of up to CZK 5 million.

For management, this means a project at the intersection of law, IT, and customer service, with little time left to complete it. A mistake will not result only in a fine, but also in disputes with customers over whether the withdrawal was made in time and over the extension of the withdrawal period. If you do not want to take risks, entrust the review of your process, terms and conditions, and contracts with partners to ARROWS law firm. Contact us at consultation@arws.cz.