New online laws and obligations for 2026

The challenges will continue in 2026 

The year 2025 brought many regulatory changes for companies in the online sector. In particular, the German Accessibility Strengthening Act (BFSG)  entering into force has caused a lot of effort and uncertainty. While many platforms are still working on these challenges and there is still a lot of uncertainty, 2026 will bring further new obligations that require early planning and implementation. This applies in particular to 

implementing the new cancellation button and the new EU warranty and guarantee labels. In addition, the next milestone on the horizon after the Digital Services Act (DSA) is the Digital Fairness Act (DFA). 

The "cancellation button" 

From 19 June 2026, online retailers must provide a clearly visible cancellation button that is available at all times, both in their own shops and on third-party platforms where contracts for goods, services or financial services can be concluded online. Consumers must be able to use the cancellation button to exercise their 14-day right of cancellation with ease. The button has to be labelled clearly - for example "Cancel Contract". It cannot be hidden. Clicking on it must lead to the next step, in which the cancellation data can be entered or confirmed. From there, it must be possible for consumers to simply send their declaration of cancellation using another clearly labelled button - such as "Confirm Cancellation". They must then immediately receive confirmation of receipt on a durable medium (e.g. by email) documenting the content, date and time of the cancellation. 

Implementing these steps requires a great deal of effort for all online retailers. This new obligation will be particularly challenging for online marketplaces. Even if they are not the direct addressees of the new obligation, they have to reorganise their online marketplaces so that this function is available for their online retailers. This raises many unanswered questions. All online retailers also have to update their cancellation policies in accordance with the revised cancellation policy template. There are also other changes. For example, the "perpetual right of cancellation" for financial services is now limited to a maximum of one year and two weeks. 

New EU warranty and guarantee labels 

From 27 September 2026, online retailers in the EU will be required to use a standardised label system that provides transparent information about the statutory warranty and existing manufacturer guarantees (see also: "EmpCo" transposition brings greenwashing ban and warranty label). The EU specifies labels for this which must be integrated according to very precise content and graphic specifications. Even the choice of colour is prescribed down to the last detail. The labels are then part of the pre-contractual information obligations and must be integrated transparently into the offer or order process. This requires considerable effort for all online retailers, especially online marketplaces. It should be implemented promptly in order to be compliant in good time. 

The Digital Fairness Act ("DFA") 

After the DSA brought about a momentous change with far-reaching consequences for hosting service providers such as online marketplaces and social media platforms – and is currently causing tension in foreign policy, particularly with the US – the planned DFA marks the next milestone. 

To this end, the EU conducted extensive consultations and collected results through October of this year. In contrast to the DSA, addressees will not only be hosting service providers, but also "simple" e-commerce offerings, including online shops. 

The focus is on the regulation of dark patterns, addictive designs, problematic influencer practices, personalised advertising and the managing digital subscriptions. The DFA strives for a principle of fairness by design and by default: Manipulative designs will be banned, clear design and transparency requirements will be established and standardised and easy-to-understand general terms and conditions will be promoted. The right to a human contact person is also being pushed – a signal against the lack of transparency in automated customer relationships. 

The EU is still analysing the results of the consultation. A first draft of the new law is expected by the end of 2026. But this much is already certain: The regulation of EU digital law will be expanded significantly. Even companies that have not yet been affected by the comprehensive regulations of the DSA will have to meet similar, perhaps more extensive obligations and adapt their online offerings comprehensively.