The withdrawal button for online stores is now a requirement for businesses that enter into distance contracts with consumers online, where a right of withdrawal applies.
Under Law 5317/2026 a new article was added to Law 2251/1994, providing for a dedicated online function through which consumers can submit their notice of withdrawal.
The change applies to online stores, apps and other online interfaces used for distance transactions with consumers. The new procedure applies in Greece from 10 July 2026, the date Law 5317/2026 was published.
What is the withdrawal button in an online store?
The so-called Withdrawal Button or Withdrawal Button is an electronic function that allows consumers to indicate online that they wish to withdraw from a contract or purchase, where they have the right to do so.
The law provides that the function may be labelled:
“Click here to withdraw”
or use other equally clear and legible wording.
This is not simply a button linking to the Returns Policy. It is a complete online process that allows consumers to submit their notice of withdrawal, confirm it and receive an acknowledgement.
Which online stores does the new notice of withdrawal requirement apply to?
The new requirement applies to contracts concluded remotely through an online interface, where the consumer has a right of withdrawal.
In practice, it applies to a large proportion of online stores selling products or services to consumers.
Examples of online interfaces include:
- an online store,
- a mobile app,
- an online platform through which the relevant contract is concluded.
Having a website does not, in itself, mean that a business needs a withdrawal button.
A simple informational business website that does not allow consumers to make online purchases or enter into relevant contracts is not subject to this requirement merely because it has a web presence.
The exceptions to the right of withdrawal provided for under consumer law for specific categories of products and services continue to apply.
Is an online store’s Returns Policy enough?
No.
This is perhaps the most important aspect of the new regulation.
Having a page titled “Product Returns”, a contact email address or a PDF withdrawal form does not replace the new electronic function.
Existing ways of exercising the right of withdrawal remain in place. However, consumers will also be able to exercise this right through the online store’s dedicated electronic function.
How should the withdrawal button work?
It is not enough simply to have the withdrawal function implemented in the online store.
It must be:
- clearly visible,
- easily accessible to the consumer,
- available throughout the withdrawal period,
- designed to allow the declaration to be submitted electronically.
Consumers must be able to easily provide or confirm the information needed to identify themselves and the relevant contract or order.
What information does the electronic withdrawal declaration include?
Under the new Article 3za, the electronic process must allow consumers to provide or confirm:
- their full name,
- the details identifying the contract from which they wish to withdraw,
- the details of the electronic means by which the withdrawal confirmation will be sent.
For an online store, this means that, depending on the technical implementation, the process may be linked to details such as the order number and the customer’s email address.
Is a second confirmation step required?
Yes.
After completing the electronic declaration, consumers must be able to finalise their submission through a dedicated confirmation function.
The law specifies the label:
“Confirm withdrawal”
or other clear, equivalent wording.
A simple contact form with a generic “Send” button therefore does not, on its own, cover the full process described in the new provision.
What must happen after a withdrawal declaration is submitted?
Following final submission, the online store must send the consumer an acknowledgement of receipt of the withdrawal declaration on a durable medium without undue delay, for example by email.
The confirmation must include:
- the content of the declaration,
- the submission date,
- the submission time.
This creates a record of when the consumer exercised their right of withdrawal electronically.
Where should the withdrawal button appear in an online store?
Law 5317/2026 does not specify a single location where the function must be placed.
For example, it does not require the button to float in the bottom-right corner of the screen.
It does require the button to be clearly visible, easily accessible and available throughout the withdrawal period.
Depending on the structure of the online store, the function could appear, for example:
- in a prominent position above the footer,
- in the footer,
- on a dedicated Withdrawal Declaration page,
- on the order page,
- in the “My orders” section of the customer’s account,
- in another clearly visible, easily accessible part of the online interface.
The key requirement is that consumers should not have to search through complex menus or call the business first to access the function.
What about orders placed without an account?
Particular attention is needed for online stores that allow purchases through guest checkout.
Access to the online withdrawal function cannot depend solely on consumers signing in to an account if they made their original purchase without creating one.
GRECA notes, for example, that access in these cases can be provided using details such as the order number and the customer’s email address, or through another suitable secure mechanism.
When did the withdrawal button requirement take effect in Greece?
TheLaw 5317/2026 was published on 10 July 2026 and, among other things, transposed Directive (EU) 2023/2673 into Greek law.
No later implementation date was specified for this provision. According to GRECA’s guidance, the new requirement has applied in Greece since 10 July 2026.
What should online stores check today?
Online store owners should review the entire withdrawal process, rather than simply check whether they have a Returns Policy page.
A technical review of an online store should check the following, among other things:
1. Is there an online withdrawal function?
Consumers must be able to initiate the process through the online interface.
2. Is the function clearly visible?
The option must not be hidden or difficult to find in practice.
3. Is the correct order identified?
The business must be able to identify the contract or order to which the declaration relates.
4. Are guest orders supported?
The process must not be available only to users who have an account.
5. Is there a separate confirmation step?
It must be clear to consumers when they are making the final submission of their declaration of withdrawal.
6. Is an acknowledgement of receipt sent?
After submission, the required confirmation must be sent with the relevant details, date and time.
Phoenix Digital Agency’s solution for declarations of withdrawal
ThePhoenix Digital Agency has developed its own technical solution for online declarations of withdrawal in online stores, tailored to the requirements of Greek law and the practical needs of Greek online stores.
The solution goes beyond simply displaying a button.
It includes the online declaration submission process, identification of the relevant order, the confirmation step, recording of the necessary details and delivery of the corresponding acknowledgement to the consumer.
The Phoenix team handles installation and configuration to ensure that the function is properly integrated into each online store and technically tested before it goes live.
Frequently asked questions about the withdrawal button for online stores
Is a withdrawal button mandatory for all online stores?
The requirement applies to distance contracts concluded through an online interface where the consumer has a right of withdrawal. This does not mean that every product, service or online transaction is covered by the right of withdrawal.
Is a link to the Returns Policy enough?
No. The new legislation requires a dedicated online function that allows consumers to submit a withdrawal notice.
Does it have to be a floating button?
No. The law does not require a specific design or position on the screen. It requires the function to be clearly visible, easily accessible and available throughout the withdrawal period.
Does the customer need to receive an email?
Once the withdrawal has been confirmed online, an acknowledgement of receipt must be sent on a durable medium, including the contents of the notice and the date and time of submission.
Does this also apply to guest orders?
The online function must also be usable by consumers who have made a purchase without creating an account. The process must therefore include a suitable way to identify these orders as well.
Does your online store need updating?
ThePhoenix Digital Agency has developed its own technical solution for online withdrawal notices, tailored to the requirements of Greek legislation and the needs of modern online stores.
Our team handles the installation, configuration and technical testing of the function in your online store.
Contact us so we can review your online store and implement the appropriate technical updates.
This article is for informational purposes only and does not constitute personalised legal advice.
