Two-Click Cancellation Law and the EU Withdrawal Button: What Subscription Businesses Must Do

Germany's two-click cancellation law, the EU withdrawal button (since June 2026) and the UK's 2027 subscription rules: what subscription businesses must do.

Garima Singh

Product Marketing Manager

TABLE OF CONTENT

Updated September 2026: this guide now covers the EU-wide withdrawal button (in force since 19 June 2026) and the UK's new subscription rules, alongside Germany's two-click cancellation law.

Key takeaways

Germany's two-click cancellation law (the "Kündigungsbutton", § 312k BGB) has applied since 1 July 2022. Any business that lets consumers sign a subscription contract online must also let them cancel it online through a clearly labelled button and a confirmation page.
Since 1 March 2022, German consumer contracts can have an initial term of up to two years, but can only auto-renew into an indefinite contract that the customer can cancel with one month's notice.
Since 19 June 2026, an EU-wide "withdrawal button" applies to online consumer contracts: customers must be able to withdraw within the 14-day withdrawal period through a two-step function on your website or app.
In the UK, the new subscription contracts regime under the DMCC Act is set to go live in January 2027, with reminder notices, renewal cooling-off periods and easy online exit.

What is the two-click cancellation law?

The two-click cancellation law is part of Germany's Fair Consumer Contracts Act (Gesetz für faire Verbraucherverträge). Its rules came into force in stages: restrictions on assignment clauses from 1 October 2021, the new contract term and auto-renewal rules from 1 March 2022, and the cancellation button from 1 July 2022 (IHK Köln). The button requirement itself sits in § 312k of the German Civil Code (BGB).

What does the law require?

Consumer-facing businesses can no longer lock customers into automatic yearly renewals. After the initial term, a contract may only continue indefinitely, with a notice period of one month.
Businesses must provide a visible cancellation button on the website so consumers can easily cancel their subscription contracts.
The cancellation button must be permanently accessible and clearly labelled.
The button must lead to a confirmation page where the consumer provides the type of termination, the reason, clear means of identification, the date the termination should take effect and contact details for the confirmation.
Customers must be able to save the termination notice, and the notice must show that it was submitted by pressing the confirmation button.

What changed in 2026: the EU withdrawal button

Germany's cancellation button is about ending a running contract. Since 19 June 2026, EU law also regulates how customers withdraw from an online contract during the 14-day withdrawal period. Directive (EU) 2023/2673, which amends the Consumer Rights Directive, requires traders who conclude contracts through a website or app to offer a withdrawal function: a prominently displayed button labelled "withdraw from contract here" (or equally clear wording), followed by a confirmation step labelled "confirm withdrawal". The trader then has to acknowledge receipt on a durable medium without undue delay (Loyens & Loeff; EUR-Lex, Directive (EU) 2023/2673).

For a physical product subscription sold online, that means you may need both: a withdrawal button for the first 14 days, and (in Germany) a cancellation button for the rest of the contract. Our guide to consumer protection laws for subscription businesses covers the withdrawal rules in more detail.

Germany vs EU vs UK at a glance

RuleWhereApplies sinceWhat it coversCancellation button (Kündigungsbutton)Germany1 July 2022Cancelling an ongoing contract concluded onlineContract term and renewal rulesGermany1 March 2022Max. 2-year initial term, then indefinite with 1-month noticeWithdrawal buttonAll EU member states19 June 2026Withdrawing within the 14-day withdrawal periodSubscription contracts regime (DMCC Act)UKPlanned for January 2027Pre-contract information, reminders, renewal cooling-off, easy exit

The UK go-live date was brought forward to January 2027 in an announcement on 10 August 2026 (TLT). If you sell into the UK, also check whether your model needs FCA approval.

What needs to be done?

Button on the website: add a clearly labelled cancellation button that is available on every relevant page, and (for EU customers) a separate withdrawal function for the 14-day withdrawal period.

Confirmation page: the button should lead to a page where the customer provides the type of termination, the reason, identification, the effective date and contact details, and then confirms.

Contract terms: review your minimum terms, renewal logic and notice periods so they match the German rules and, where relevant, the upcoming UK regime.

Solution for subscription eCommerce

The page the button leads to can live in a customer self-service portal. A self-service portal already contains all order and subscription information, which is exactly what a customer needs to complete the cancellation.

Being able to tell products and subscriptions apart matters, especially when a customer has more than one active subscription with the same brand.

The circuly customer self-service portal covers the cancellation process, so customers can cancel their subscription themselves. To learn more, read this article or see the two-click cancellation flow in circuly.

FAQ

Does the two-click cancellation law apply outside Germany?

No. The Kündigungsbutton is German law (§ 312k BGB). Other EU countries have their own rules, and since 19 June 2026 the EU-wide withdrawal button applies to online consumer contracts in all member states.

Is the EU withdrawal button the same as the cancellation button?

No. The withdrawal button lets a consumer withdraw from a contract within the 14-day withdrawal period. The German cancellation button lets them end an ongoing contract at any time under its notice terms. A German subscription business selling online may need both.

Can I still offer a 12- or 24-month minimum term in Germany?

Yes, an initial term of up to two years is allowed. After that, the contract can only renew indefinitely, and the customer must be able to cancel with one month's notice.

When do the UK subscription rules apply?

The DMCC Act subscription contracts regime is planned to go live in January 2027. It adds pre-contract information, reminder notices, a renewal cooling-off period and easy online cancellation.

This article is practical guidance, not legal advice. Check your setup with a lawyer in each market you sell into.