"Cancel Contract" button for financial services: New Requirements in 2026

From 19 June 2026, providers of distance financial services in the Czech Republic will be required to introduce a so-called contract withdrawal button. This obligation stems from a European directive and fundamentally changes how consumers cancel loans or insurance arranged online. This article explains who the change applies to, what fines may be imposed, and how to prepare for the change in practical terms.

In the image, we see a specialist consulting on the implementation of a withdrawal button.

Key takeaways

  • From 19 June 2026, it will be mandatory to allow customers to withdraw from a financial services contract via a visible button, not through complicated forms or by post.
  • The button must be easily accessible and functional throughout the withdrawal period; otherwise, a fine of up to CZK 5 million may be imposed.
  • The obligation applies to banks, insurers, non-bank providers, and also to e-shops if they act as intermediaries for these services.
  • Implementation requires changes to the user interface, automated confirmations, and updates to the terms and conditions.
  • It must not involve manipulative design (dark patterns) and the process must be transparent and compliant with the Digital Services Act (DSA).

New European regulation and who it applies to

The European Union has focused on an area where withdrawal is often the most complicated—financial services. The result is Directive (EU) 2023/2673 amending the Consumer Rights Directive. The Czech Republic will transpose this amendment into the Czech Civil Code and the Consumer Protection Act. As of 19 June 2026, provisions introducing the so-called withdrawal function will take effect.

Who does the obligation apply to?

Unlike the general sale of goods, where easy withdrawal is recommended but a specific button in this form is not strictly mandated, this directive targets distance contracts for financial services.

This concerns you if you offer online:

  • Consumer credit (including deferred payments such as BNPL, if structured as credit).
  • Insurance (e.g., travel insurance, electronics insurance, extended warranties in the form of an insurance policy).
  • Investment products and pension savings.

For e-shops, this becomes crucial when they offer purchase financing or product insurance in the cart. If the customer enters into a financial services contract directly on your website, you must ensure that this button is available. For regulated financial products, it is also advisable to verify whether your distribution model requires authorisation or registration with the supervisory authority—see ČNB licence & investments.

What exactly the new obligation requires

The function (button) must meet the directive’s strict requirements as transposed into Czech law:

Visibility and accessibility. The button must be easily accessible in the user interface throughout the withdrawal period (typically 14 days; 30 days for life insurance and pension products). The customer should be able to find it without unnecessary searching, for example in a “My products” section or in the contract details. It must not be hidden.

Unambiguous labelling. The text on the button must clearly state its function. The law prefers wording such as “Withdraw from the contract” or similarly clear phrasing.

A simple process after clicking. After clicking, the customer must be able to complete a withdrawal statement. It is not possible to require login unless it is necessary for identification, and the form should be pre-filled if the customer is identified.

Confirmation without undue delay. The trader must, without undue delay, send the customer confirmation of receipt of the withdrawal on a durable medium (email), including the date and time. In practice, it is worth ensuring—both technically and contractually—who generates the confirmation and how it is archived, especially if part of the process is handled by external suppliers—see External suppliers versus employees: How to properly set up contractual relationships and eliminate tax risks of disguised employment.

Ban on Dark Patterns. In line with the Digital Services Act (DSA) and the amendment to the Consumer Protection Act, it is prohibited to use manipulative design that would complicate the process. When setting up the user interface and withdrawal flows, it is often also necessary to address related personal data processing and logging of user steps, which typically falls under GDPR.

Related questions 

1. Do I need a button even if I only sell shoes and do not offer credit?

If you sell only ordinary goods and do not offer any financial products (credit, insurance), this specific obligation under Directive 2023/2673 does not apply to you directly. However, implementing an easy withdrawal process is strongly recommended even for standard e-shops to help prevent fines for “Dark Patterns” and to increase trustworthiness.

2. Who is responsible for the button—the e-shop or the credit company?

Responsibility primarily lies with the financial service provider. However, if the e-shop acts as an intermediary and the contract conclusion process takes place entirely on its domain, it must ensure (often by technically integrating the provider’s widget) that the customer has the option to withdraw.

3. Can I replace the button with an email to support?

For financial services, from 19 June 2026, no. The directive explicitly requires a “withdrawal function” (button). The mere option to send an email or a PDF form will no longer be sufficient.

What penalties apply for non-compliance

Supervision of compliance with obligations in the area of financial services is carried out by the Czech National Bank (ČNB) and, in certain consumer protection aspects, the Czech Trade Inspection Authority (ČOI). If the obligation applies to you via digital channels as well, it may be useful to align the implementation with rules for online services and data processing, as summarised in the article SaaS platform in the EU: Legal coverage of T&Cs, GDPR and licensing arrangements for AI outputs.

For breaches of obligations related to the right of withdrawal and information duties, a fine under the Consumer Protection Act of up to CZK 5,000,000 may be imposed.

In addition to an administrative fine, there is a risk of invalidity of legal acts or an extension of the withdrawal period by one year if the consumer was not properly informed. There is also significant reputational risk and the possibility of losing a licence for regulated entities.

How to prepare in practice for June 2026

  1. Product audit (March–April 2026). Determine whether you offer products that fall under the definition of distance financial services (product-related insurance, loans, deferred payments arranged directly by you).
  2. Technical implementation (March–June 2026). If you are a service provider, you must develop an interface with the button. If you are an e-shop intermediating services, contact your partners and request information on implementing their withdrawal solution into your user interface.
  3. Legal updates (May 2026). Update your terms and conditions (GTC) and pre-contractual information, which must explicitly describe the existence and function of the withdrawal button. The legal team at ARROWS advokátní kancelář can prepare wording compliant with the new directive.
  4. Process testing. Verify that pressing the button terminates the correct contract. For example, only the insurance contract should be terminated, not the purchase contract for goods, unless the customer wishes so.

Manipulative design and how to avoid it

Although the new obligation primarily concerns financial services, the ban on dark patterns (manipulative design) applies to all e-shops under the Digital Services Act (DSA).

What is prohibited:

  • The withdrawal button is greyed out or invisible compared to the "Keep it" button.
  • Having to click through a series of questions like "Are you sure?".
  • Emotional blackmail or false urgency.

Regulators will assess whether the withdrawal process is as easy as the purchasing process.

Exceptions – when withdrawal is not possible

Even for distance financial services, the right of withdrawal is not absolute. Under the Czech Civil Code and the directive, it is not possible to withdraw, for example, from:

  • Services whose price depends on fluctuations in the financial market that the trader cannot influence.
  • Travel insurance or baggage insurance if concluded for a period shorter than 1 month.
  • Contracts that, at the consumer’s express request, have been fully performed before the withdrawal period expires.

In these cases, the button does not have to be active or may lead to information stating that withdrawal is not possible.

Potential issues

How ARROWS helps (office@arws.cz)

Incorrect implementation for financial services – Missing button for insurance/loans. You may face sanctions from the Czech National Bank (ČNB) / the Czech Trade Inspection Authority (ČOI) of up to CZK 5 million.

Legal audit of your processes and contractual relationships with loan/insurance providers.

Conflict with the DSA (Dark Patterns) – The withdrawal process is too complicated, which is a breach of the law even for ordinary goods.

Review of UX design from a legal perspective (Legal UX).

Outdated terms and conditions – Missing information about the withdrawal function.

Comprehensive review and update of your terms and conditions for 2026 to reflect the new legislative requirements.

Dispute over timely withdrawal – The customer claims they withdrew, but you have no record.

Setting up a legally robust confirmation process and archiving of digital actions (audit trail).

Final summary

The new obligation to introduce a contract withdrawal button under Directive (EU) 2023/2673 targets the distance financial services sector. From 19 June 2026, banks, insurers, non-bank providers, and e-shops intermediating these services must offer a transparent digital tool for terminating the contract.

Although this specific obligation does not yet apply in this strict form to the sale of ordinary goods, the consumer protection trend clearly points towards making withdrawal as simple as possible at all times. We recommend taking inspiration from this and simplifying processes for everyone.

Do you need help with a legal review of distance financial services sales or setting up your e-shop in compliance with the DSA? Contact the attorneys at ARROWS advokátní kancelář. Reach us at office@arws.cz.

Notice

Notice: The information contained in this article is of a general informational nature only and is intended to provide basic guidance on the topic based on the legal status and applicable EU and Czech legislation as of 2026. Although we take the utmost care to ensure accuracy, legal regulations and their interpretation evolve over time. We are ARROWS advokátní kancelář, an entity registered with the Czech Bar Association, and for maximum client protection we are insured for professional liability with a limit of CZK 400,000,000. To verify the current wording of regulations and their application to your specific situation, it is necessary to contact ARROWS advokátní kancelář directly (office@arws.cz). We accept no liability for any damages arising from the independent use of the information in this article without prior individual legal consultation.

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