EU Checkout Page Requirements: Button Text, Pricing & Consent
6 April 2026
Your checkout page is the most regulated page on your website. EU consumer protection law dictates what your order button says, how you display prices, what information you must provide before the sale, and how consent checkboxes work. Get any of it wrong and your orders may not be legally binding.
This guide covers every requirement that applies to your checkout page. If you sell to consumers in the EU, all of this applies to you regardless of where your business is registered.
Order button text: the words matter legally
The Consumer Rights Directive, Article 8(2), requires that the final order button clearly tells the customer they are committing to pay. The exact legal text says the consumer must "explicitly acknowledge that the order implies an obligation to pay."
This isn't a suggestion. If your button text doesn't meet this standard, the contract might not be enforceable. The customer could argue they didn't knowingly agree to pay, and courts have sided with consumers on this.
Compliant button text:
- "Buy now"
- "Pay now"
- "Order and pay"
- "Complete purchase"
Not compliant:
- "Continue"
- "Next"
- "Submit"
- "Complete order" (debatable in some jurisdictions)
- "Confirm"
Each EU country implemented this rule in national law, and some are stricter than others. Germany's "Buttonlosung" (button solution) under BGB section 312j(3) is the toughest. German courts expect the button to say "zahlungspflichtig bestellen" (order with obligation to pay) or something equally unambiguous. "Jetzt bestellen" (order now) has been found non-compliant by German courts.
In the Netherlands, Article 6:230v of the Burgerlijk Wetboek requires the same. "Bestellen en betalen" works. "Bestelling plaatsen" does not.
If you sell across borders, use the strictest standard. A button that says "Order and pay" or its local equivalent satisfies regulators in every EU country.
For the full breakdown including court cases and platform defaults, read our order button requirements guide.
Price display: no surprises at checkout
The total price the customer pays must be visible before they place the order. This means the final checkout screen must show:
- The product price including VAT. Every price a consumer sees must include the applicable VAT rate. Showing ex-VAT prices and adding tax at checkout is not allowed in B2C transactions.
- Delivery costs. Shipping, handling and any other delivery charges must appear before the customer commits. If delivery cost depends on the shipping method, show the options with prices before the order button.
- Any additional fees. Payment processing surcharges, gift wrapping fees, insurance costs. Anything that increases the total must be disclosed upfront.
The principle is simple: the number the customer sees before clicking the order button must be the number that leaves their account. No hidden fees, no surprise charges, no "plus applicable taxes" footnotes.
This comes from the Consumer Rights Directive, Articles 6 and 8. The Dutch ACM and German regulators both actively investigate complaints about hidden checkout fees.
The Omnibus Directive and discount pricing
If your checkout page shows discounted prices, the Omnibus Directive (2019/2161) adds another requirement. Any advertised price reduction must show a reference price, and that reference price must be the lowest price you charged for the product in the 30 days before the discount started.
This applies to crossed-out prices on product pages, percentage-off labels, and any discount shown during checkout. You can't inflate a price two days before a sale and then "discount" it back to the normal level.
Read our discount pricing rules guide for details on progressive reductions, exceptions for perishable goods, and how enforcement works in practice.
Pre-contractual information: what the law requires you to show
Before the customer clicks the order button, the Consumer Rights Directive (Article 6) requires you to provide a specific list of information. The checkout page is where most of this must appear, either directly or through clearly accessible links. The list includes:
- Your business identity. Legal name, geographic address and a way to contact you (phone or email). A contact form is not sufficient on its own.
- The main characteristics of the product or service. What the customer is actually buying. For physical goods, this usually appears on the product page, but the order summary at checkout should be clear enough to avoid confusion.
- Total price including all taxes and charges. As covered above.
- Payment, delivery and performance arrangements. Which payment methods you accept, when and how you'll deliver, and any performance deadline.
- The right of withdrawal. Customers must know they have 14 days to cancel before they complete the purchase. More on this below.
- Return shipping costs. If the customer will bear the cost of returning goods after withdrawal, you must say so before the sale.
- Contract duration and termination. For subscriptions or recurring services, the minimum commitment and how to cancel.
- Digital content functionality and compatibility. For digital products, what the content does, what devices or software it works with, and any DRM restrictions.
Missing any of these items has consequences. The most severe: if you fail to inform the customer about the withdrawal right, the cancellation window extends from 14 days to 12 months.
Most e-commerce platforms handle some of this automatically. Few handle all of it. Check your checkout flow against this list manually.
For a broader look at all consumer rights obligations, see our EU consumer rights guide.
The 14-day withdrawal right disclosure
EU consumers can cancel any online purchase within 14 calendar days of receiving the goods. No reason required. This is non-negotiable for most products.
Your checkout page must inform the customer about this right before they place the order. A link to your returns policy page is acceptable, but the information must be genuinely accessible. Burying it in page 12 of your terms and conditions does not count.
What you must communicate:
- The customer has 14 days to withdraw
- How to exercise the right (email, form, letter)
- Who pays for return shipping
- How refunds are processed and the timeline (14 days from receiving the returned goods or proof of shipment)
- A model withdrawal form or a link to one
Exceptions
Some products and services are exempt from the withdrawal right. If you sell any of these, say so clearly on the product page and at checkout:
- Perishable goods like food or flowers
- Sealed hygiene products that have been opened (cosmetics, earbuds)
- Custom-made or personalized items like engraved jewelry or made-to-measure clothing
- Sealed audio, video or software with a broken seal
- Hotel bookings, event tickets and transport tied to specific dates
For the full list of exceptions and how to handle the return process, read our 14-day withdrawal right guide.
Digital product exceptions
If you sell downloads, streaming access, software licenses or other digital content, you can ask the customer to waive their withdrawal right at checkout, but only if you follow a specific process.
At checkout, before the customer clicks the order button, you must:
- Get explicit consent for immediate delivery of the digital content. A checkbox that says something like "I agree that delivery starts immediately" works.
- Make the customer acknowledge that by consenting to immediate delivery, they lose their 14-day withdrawal right.
- Send a confirmation on a durable medium (email) repeating this consent and acknowledgment.
All three steps are required. Skip one and the customer retains the full 14-day withdrawal right, meaning they could download your product, use it, and then demand a refund within two weeks. In practice, this means digital sellers need two checkboxes or a combined checkbox with clear language at checkout.
Consent checkboxes: what to separate
Your checkout page likely has checkboxes for terms acceptance, newsletter signup, or marketing consent. EU law has specific rules about how these work.
Terms and conditions
You must give customers the opportunity to read your terms before they agree. A checkbox that says "I agree to the terms and conditions" with a link to the full text is the standard approach. Pre-checking this box for the customer is illegal under EU consumer protection law. The customer must actively tick it.
Read more about why pre-checked boxes are problematic in our guide on prechecked checkbox rules.
Newsletter and marketing consent
Under GDPR (Article 7) and the ePrivacy Directive, marketing consent must be:
- Freely given. You cannot make newsletter signup a condition of completing a purchase. The customer must be able to buy without subscribing.
- Separate from other consents. The newsletter checkbox must be independent from the terms acceptance checkbox. Bundling them into a single "I agree to everything" checkbox violates GDPR.
- Not pre-ticked. The checkbox must be empty by default. The customer actively opts in.
- Specific. "We may send you marketing" is too vague. "Receive our weekly product updates by email" is specific enough.
If you collect consent for multiple channels (email, SMS, phone), each needs its own opt-in. A single "contact me about offers" checkbox covering all channels is not granular enough.
Country-specific checkout rules
While the Consumer Rights Directive creates a baseline across the EU, some countries add their own requirements.
Germany: the Buttonlosung
Germany's implementation of checkout button rules is the strictest in Europe. The law (BGB section 312j) specifically requires that the order button contains the words "zahlungspflichtig bestellen" or equally clear language. Courts have struck down orders placed through non-compliant buttons, ruling that no valid contract was formed.
Beyond button text, German law requires a clear order summary page showing all items, quantities, prices and the total including shipping, directly above or beside the order button. The customer must see everything they're paying for in the same view as the button.
Netherlands: Wet koop op afstand
The Dutch implementation through the Burgerlijk Wetboek follows the EU directive closely but is enforced actively by the ACM. The ACM has investigated and fined online shops for non-compliant checkout pages, with penalties that can reach up to 900,000 euros for consumer law violations.
Dutch shops must also display their KVK number and BTW-ID, which should remain visible throughout the checkout process.
For the full Dutch requirements, see our Dutch webshop compliance checklist.
Other markets
France requires an additional confirmation step for certain subscription services. Belgium enforces strictly through the SPF Economie. The safest approach for cross-border sellers: comply with German standards. If your checkout passes German requirements, it passes everywhere else in the EU.
The ODR platform link (no longer required)
Until July 2025, EU law required every online shop to link to the EU Online Dispute Resolution platform. That platform has been abolished. If your checkout page or terms still contain this link, remove it. A dead link doesn't help your customers and it makes your site look unmaintained.
See our guide on the ODR platform removal for the full background.
Checkout compliance checklist
Use this as a quick audit of your checkout page:
- [ ] Order button clearly states a payment obligation ("Buy now", "Order and pay")
- [ ] Total price shown including VAT and all fees
- [ ] Delivery costs visible before the order button
- [ ] Discount prices show the 30-day prior lowest price
- [ ] Business name, address and contact details accessible
- [ ] 14-day withdrawal right communicated before purchase
- [ ] Model withdrawal form available (link or download)
- [ ] Return shipping cost responsibility stated
- [ ] Terms and conditions checkbox is not pre-ticked
- [ ] Newsletter signup is a separate, unchecked checkbox
- [ ] Digital content: consent to immediate delivery + waiver acknowledgment
- [ ] Order summary visible on the same page as the order button
- [ ] Subscription terms and cancellation process disclosed
If you're unsure whether your checkout page meets these requirements, run a scan. Our free website compliance scan checks your checkout for button text, price display issues, consent problems and missing legal disclosures. It takes about 30 seconds and tells you exactly what needs fixing.
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"Buy Now" vs "Order": Why Your Button Text Matters Legally
EU law requires specific wording on order buttons. The wrong text could make your orders non-binding. Here is what your checkout button must say.
Dutch Webshop Compliance: Complete Checklist
A full checklist of legal requirements for online shops in the Netherlands. KVK, order buttons, withdrawal rights, pricing rules and more.
Discount Pricing Rules: The 30-Day Prior Price Requirement
EU Omnibus Directive requires showing the lowest price from the past 30 days when advertising a discount. Here is how it works.