23 June 2026 Article Series – 2 of 21 Insights As of last Friday, 19 June 2026, traders must provide consumers with a direct electronic option to exercise their right of withdrawal for distance contracts concluded by means of an online user interface: the so-called “withdrawal function” (in German practice often referred to as the “Widerrufsbutton” or “Button-Lösung”). This new requirement stems from the transposition of Directive (EU) 2023/2673 into German law. At the heart of the matter is the new Section 356a of the German Civil Code (Bürgerliches Gesetzbuch – BGB), which obliges traders to provide consumers, on the respective online user interface, with a simple, clearly recognizable and permanently available option to submit a withdrawal declaration. Undertakings across all industries have been working intensively on implementing the new requirements in recent weeks and months. The implementation deadline has passed, but many questions remain unanswered, particularly for the automotive sector. The changes are particularly relevant for OEMs and providers of digital vehicle services. This is because, in the automotive sector, distance contracts on digital content and digital services have long since ceased to be concluded or managed solely via traditional websites or apps. Increasingly, contracts are also being concluded via in-car stores, vehicle head units, connected service portals, or “functions-on-demand” offerings. The following may be particularly affected: Depending on the nature of the respective service, providers must in future enable affected B2C users (consumers) to exercise their statutory right of withdrawal electronically in accordance with the applicable legal requirements. The key principle is this: If a B2C distance contract with a statutory right of withdrawal is concluded via an online user interface, the exercise of the right of withdrawal must also be possible via such an online user interface in future. The new obligation to provide an electronic mechanism