Germany proposes ‘one-click’ revocation right to implement EU consumer rights directive

The draft legislation requires businesses to amend their standard procedures for concluding contracts with consumers in Germany. At the same time, the draft law relieves businesses of some paperwork and aims to guarantee legal certainty for long-standing consumer contracts.

The draft law will implement a 2023 EU directive applicable to consumer contracts by the means of an online interface and to financial services contracts with consumers that are concluded at a distance.

Businesses must enable online revocation via a click of a button and must ensure the button is clearly labelled and easily accessible to consumers on online interfaces, and that it is continuously available throughout the revocation period.

The BMJV envisages that the button will empower consumers to exit contracts with the same ease with which they entered them. Announcing the proposals (link in German), federal minister of justice and consumer protection Stefanie Hubig said she hoped the cancellation button would “make life easier for consumers.”

Additionally, the draft foresees an obligation for businesses in the financial services sector to provide information in simple language to ensure an informed consumer decision at the time of the contract conclusion. Consumers will be entitled to request to be contacted personally when financial services contracts are offered via online tools.

The new draft law also sets limits on the duration of revocation rights when certain consumer information has not been provided from the outset. Reflecting the growth in digitalisation, consumers will no longer be entitled to request paper copies of contractual information.

While businesses must be primed to amend their revocation instructions, implement an online revocation button and provide explanations on financial services contracts in simple, clear language, the draft is also good news for businesses, said Johanna Weißbach, a dispute resolution expert at Pinsent Masons.

In particular, the draft law sets limits on the so-called ‘eternal revocation right’, she said. “German courts have been busy with consumer revocation cases in the financial services sector for many years. In many of these cases, the revocation period of 14 days or 30 days for consumer contracts had expired years ago. Nevertheless, businesses were still exposed to revocation cases because, under the current law, the 14 or 30 day revocation period does not commence if the consumer was not provided with all legally required information at the time of contract conclusion. Often, consumers use such immaterial lack of information for revocation to compensate for low-performing contracts or to maximise their profits.”

Weißbach said revocation rights “due to such immaterial lack of consumer information” will be “substantially limited” under the new law.

For financial services contracts, such minor information deficiencies can justify a contract revocation within 12 months and 14 days after contract conclusion. For life insurance contracts, it is proposed that a maximum revocation period of 24 months and 30 days will apply. After the expiration of these periods, it will no longer matter whether the consumer received the terms and conditions or pre-contractual information.

Carlo Schick of Pinsent Masons said these changes would likely be welcomed by many businesses. “The limitation of revocation rights is a relief for businesses,” he said. “Financial services providers in particular in Germany have been facing mass revocation claims from consumers concerning contracts that were concluded many years earlier. The risk of such mass claims for future contracts decreases significantly with the new draft law, on the condition that businesses provide information on the revocation rights to its customers.”

Interested stakeholders are invited to comment on the proposals by 1 August. The draft legislation is due to come into force on 19 June 2026, but with certain provisions taking effect from 27 September 2026.