Sweden to Require Withdrawal Button for Online Shopping

According to a new legislative proposal by the Swedish Government, from 19 June 2026, companies selling to Swedish consumers online must add a 'withdrawal button' to their websites and apps. The proposed amendments will require significant technical and legal updates for e-commerce businesses.

The proposed Swedish rules implement EU Directive 2023/2673 (the “Directive”). This Directive updates the Consumer Rights Directive 2011/83/EU to require a withdrawal function for distance contracts and brings financial services into the same regime (replacing the old Financial Services Contracts Directive 2002/65/EC). Sweden will incorporate these changes into its existing Distance and Off-Premises Contracts Act (SFS 2005:59) (the “Distance Contracts Act”). The aim of the new rules is to make it as easy for consumers to withdraw from a contract as it was to enter into it. If you can buy with one click, you should be able to cancel with one click.

What do the new rules require?

Pre-contractual information

The substantial list of pre-contractual information requirements set out in Chapter 2, Section 2 of the Distance Contracts Act is proposed to be supplemented with a requirement to provide information on the availability of the withdrawal function and where it can be accessed. 

Implementation of a withdrawal function

Chapter 2 of the Distance and Off-Premises Act is proposed to be supplemented by a new Section 10a, requiring any company entering into consumer contracts through an online interface, such as a website or an app, to provide a withdrawal function (essentially, a withdrawal button), where consumers have withdrawal rights. The withdrawal function shall meet the following criteria: 

Accessibility and Visibility Requirements 

The withdrawal function shall be:

• easily accessible within the online interface,
• clearly and legibly labelled (e.g. stating “withdraw contract here”), and
• available within the online interface (at least) during the withdrawal period.

Functionality Requirements

The withdrawal function must enable consumers to:

• provide or confirm its (i) name, (ii) details of the contract they wish to withdraw from, and (iii) the electronic readable and durable format in which the company should confirm the withdrawal message (confirmation of receipt), and
• send the withdrawal message by expressly confirming the withdrawal.

Confirmation Obligation

Companies must without delay send a confirmation of receipt to the consumer in the format requested by the consumer. The confirmation shall include the time of receipt of the confirmation.

What are the consequences of non-compliance?

Violations of the new rules are sanctioned in accordance with the Swedish Marketing Practices Act (SFS 2008:486). Consequently, violations may result in injunctions, combined with conditional fines, requiring the breaching company to provide certain information or cease unlawful marketing practices. Furthermore, intentional or negligent violations may also result in a market disruption fine of up to 4% of the breaching company’s annual turnover, plus liability for damages to consumers and other companies.

What steps should be taken by companies?

The new rules are proposed to enter into effect on 19 June 2026. To ensure compliance in due time, we advise companies to start preparing now by:

• Mapping which contract processes are in scope — identify all consumer contracts concluded through online interfaces that are subject to withdrawal rights
• Implementing the technical functionalities required — develop and integrate the withdrawal button with the required accessibility, visibility, and functionality features
• Updating Terms and Conditions, or similar documentation, to meet the new pre-contractual information requirement
• Reviewing other consumer-facing information and documentation (such as privacy notices) to ensure consistency with the new rules and withdrawal function.

If you have any questions about the new withdrawal button requirements or need assistance with implementation, please contact Mårten Lindberg or Julia Jansson.