New EU requirements for online retailers: Digital contract withdrawal process
14.07.2026 7 min. 27 views
On 19 June 2026, Directive (EU) 2023/2673 entered into force, introducing new requirements for exercising the right of withdrawal from distance contracts. One of the most important changes is the digitalisation of the withdrawal process and the introduction of a clearly marked electronic function that allows consumers to exercise their right of withdrawal directly through the online store.
For online retailers, this means implementing or updating a return merchandise authorisation system (RMA - Return Merchandise Authorization) that meets the new legal requirements. In addition to ensuring regulatory compliance, such a system digitalises, automates and improves return and exchange processes, leading to greater operational efficiency and a better customer experience.
This article aims to draw your attention to the new regulatory requirements affecting online retailers that sell to consumers in the European Union.
What does Directive (EU) 2023/2673 introduce?
Directive (EU) 2023/2673 amends the Consumer Rights Directive 2011/83/EU by introducing a new Article 11a, which regulates the electronic exercise of the right of withdrawal. The requirement applies to any retailer that enters into distance contracts through an online interface when a legal right of withdrawal applies to the relevant goods, services or digital content. The main principle is that consumers should be able to withdraw from a contract as easily as they placed the order.
What is the current situation in Bulgaria?
As of today, Bulgaria has not yet transposed the directive into national law. However, Directive (EU) 2023/2673 is already in force at European Union level and requires member states to apply its requirements in their national legislation from 19.06.2026. The transposition process in Bulgaria has not yet been completed, which is why online retailers are advised to prepare for the upcoming changes in good time.
On 09.06.2026, a draft law amending the Consumer Protection Act was submitted to the National Assembly. The draft law provides for the introduction of the relevant requirements. It is expected to be voted on at first reading in the near future. The standard period between the first reading and final adoption is approximately one month.
Which retailers are affected by the directive?
The new requirements apply to online retailers that enter into distance contracts with consumers through an online interface - an online store or mobile application - where the law provides for a right of withdrawal.
The scope includes retailers offering goods, services or digital content for which a legal right of withdrawal exists under the Consumer Rights Directive.
The retailer’s location is not relevant. When an online store offers its products or services to consumers in the European Union, it must meet the regulatory requirements, regardless of whether it is established in an EU member state or outside the EU.
What are the new mandatory requirements for online retailers?
To bring your online store into line with the new requirements, you need to provide:
- A clearly marked withdrawal function: A permanently available, visible and easily accessible function with clear wording, such as “Withdraw from the contract”, through which consumers can exercise their right of withdrawal.
- A digital two-step process: The withdrawal request must be submitted entirely online through the store interface in two steps - entering the required information and then confirming the request. The withdrawal form must allow the relevant contract or order to be clearly identified. The process must also be available to guest users, without requiring registration or login.
- Automatic confirmation: After a withdrawal request is submitted, the system must automatically send confirmation that it has been received on a durable medium, such as by email. The confirmation must include the date and time of submission, as well as information about the request received.
- Updated terms and conditions: The online store’s terms and conditions must be updated to describe the electronic method for exercising the right of withdrawal, the relevant deadlines and the process that consumers must follow.
Please note that Magento, Adobe Commerce and Shopify do not include a ready-made solution by default that covers these legal requirements.
What action should you take for your online store?
The steps you need to take depend on which of the two main scenarios applies to you - whether your online store already has a return merchandise authorisation system (RMA) or whether such a system still needs to be implemented.
- Scenario I - Your online store already has an RMA system
When you already use a return merchandise authorisation system (RMA), the existing functionality should be reviewed to determine whether it meets the new regulatory requirements. Where necessary, the required changes should be made to ensure that the process for exercising the right of withdrawal fully complies with Directive (EU) 2023/2673.
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Scenario II – Your online store does not have an RMA system
When your online store does not currently have a return merchandise authorisation system (RMA), you need to plan the implementation of a return management solution that provides a digital process in line with the requirements.
How can Stenik help?
The Stenik team has hands-on experience in developing and implementing RMA solutions for different online stores. Over the years, we have delivered both basic solutions using ready-made extensions and more advanced solutions that automate return and exchange processes. In our article “Optimize the return and exchange process in your online store. Integration of a return merchandise authorization (RMA) management system”, we have shared more information on the subject. Depending on your budget, deadlines and priorities, we can offer the most suitable option for your business.
This article does not constitute individual legal advice or consultation. We recommend discussing the matter with the person responsible for these issues within your company.
You can follow the progress of the draft law submitted by the Ministry of Economy and Industry on the official website of the Public Consultation Portal of the Council of Ministers and read the Official text of Directive (EU) 2023/2673 (EUR-Lex)
FAQ
Do you need assistance?
There is limited time to respond. The new requirements require timely action to bring your online store into line with the applicable regulations.
At Stenik, we recommend that all online stores fully comply with this and all other applicable regulatory requirements.
Our team is available to all our clients to review their existing RMA functionality, assess the required changes and assist with upgrading it or implementing a solution that meets the new regulatory requirements.
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