New requirements for consumer contracts concluded via online platforms

As of 19 June 2026, amendments to the Civil Code of the Republic of Lithuania have entered into force, introducing new requirements for contracts concluded with consumers through an electronic interface (e.g., a website or mobile application). Under these amendments, businesses are now required to implement an additional contract withdrawal function that can be activated by clicking a button.

Directive (EU) 2023/2673 must be transposed into the national legislation of all EU Member States. Therefore, the obligation to ensure this functionality must be implemented across all interfaces accessible in the respective Member States and in the relevant language, not only in Lithuanian-language interfaces. Given that penalties for non-compliance may vary depending on the Member State and are difficult to predict (the Directive sets only a general requirement that penalties must be “dissuasive,” while actual fines in individual countries may range from several thousand euros to up to 4% of annual turnover), we recommend implementing this functionality as soon as possible.

Additional requirements now apply to the contract withdrawal functionality in order to ensure that consumers can withdraw from a contract just as easily as they entered into it. The withdrawal function must be clearly labelled with the words “withdraw from the contract here” or another similarly clear, unambiguous, and easily readable phrase. This function (button) must remain continuously available for as long as the consumer retains the right to withdraw from the contract. Typically, this period is 14 days from the conclusion of the contract, unless a longer withdrawal period is provided in the applicable terms and conditions of sale (or service provision).

Although Directive (EU) 2023/2673 primarily requires this functionality to be introduced in contracts for financial services, it also emphasizes that the requirement applies to other consumer contracts as well.

When implementing this new functionality, companies must address a number of important technological and practical issues to ensure compliance with the new requirements. These include, for example, determining where exactly the withdrawal button must be placed, how the withdrawal declaration should be completed, and how and where confirmation of the received withdrawal notice should be sent to the consumer.

For example, a consumer who has already been identified, such as by logging into their account, should be able to withdraw from the contract without being required to submit their identifying information again or, where applicable, to re-enter details identifying the contract they wish to withdraw from.

If you require legal advice on these matters, please contact the lawyers of our law firm Nerijus Zaleckas, nerijus@zaleckas.com, or Ina Muckiene, ina.muckiene@zaleckas.com.