New “Withdrawal Button” Required on Swedish E-Commerce Platforms from 19 June 2026

On 19 June 2026, several amendments to the Distance and Off-Premises Contracts Act will enter into force. One of the most significant changes concerns the right of withdrawal. Companies that sell goods or services to consumers online will, after this date, be required to provide a clear and easily accessible function - in practice, a “withdrawal button” - that enables consumers to withdraw from an agreement directly within the same online interface where the contract was concluded. Through this button, consumers should be able to easily exercise their right of withdrawal during the withdrawal period. The requirement applies to both distance contracts for financial services and instruments, as well as other goods and services.

What Does the Requirement Entail?

The withdrawal function must meet the following requirements:

• The function must be easily accessible on the same website or app where the agreement was concluded, and it must remain available throughout the entire withdrawal period.
• The function must be labelled in a clear and easily readable manner, for example “withdraw from the agreement here”.
• Through the function, the consumer must be able to enter (or confirm) their name and details identifying the contract being withdrawn from, as well as select the electronic, readable, and durable format in which the confirmation of withdrawal is to be sent.
• An express confirmation of the withdrawal must be required to prevent the consumer from withdrawing from an agreement by mistake.
• The company must, without delay, send a confirmation of the withdrawal to the consumer, including the time of receipt.

In practice, the requirement affects most businesses that offer goods or services to consumers online where the right of withdrawal applies. This includes, among others, e-commerce companies, subscription services, companies providing digital platforms and apps, as well as financial services providers.

The legislative amendment, including the withdrawal function requirement, will enter into force on 19 June 2026 and is implemented through amendments to the Swedish Distance Contracts and Off-Premises Contracts Act (2005:59). The rules originate from EU law and implement an EU directive amending the Consumer Rights Directive.[1]

CMS Wistrand’s Comment

The legislative amendments aim to strengthen the protection of consumers who enter into agreements for financial services or other goods and services online. The new requirement means that affected businesses may need to adapt their websites and apps to comply with the requirements described above.

It should also be noted that the withdrawal function may only be made available after the consumer has logged in to the website - the requirement of easy accessibility does not prevent the function from being placed behind a login.

The requirement does not create a new or extended right of withdrawal compared to current regulation; it is solely intended to make it easier for consumers to actually exercise the right of withdrawal they already have.

In addition to the requirement for the withdrawal function itself, a requirement is introduced for businesses to inform consumers, prior to concluding the agreement, of the existence of the withdrawal function and where it is available. This may require businesses to update their general terms and conditions or other information provided before the agreement is concluded.

If a withdrawal function is missing, or does not meet the requirements, it may be considered unfair marketing, which can lead to, among other things, injunctions, penalty payments, and market disruption fees.

Please contact CMS Wistrand if you have any questions or wish to receive further information.

[1] Directive (EU) 2023/2673 of 22 November 2023 amending Directive 2011/83/EU as regards financial services contracts concluded at a distance and repealing Directive 2002/65/EC.