Received a warning letter over the withdrawal button — what to do?

Have you received a letter from a lawyer – alleging that your online shop does not meet the requirements for the withdrawal button? Don’t panic. This article shows you what such a warning letter means, which deadlines apply, what costs you should expect and how to protect yourself against future warning letters.

Why a wave of warning letters is expected from 19 June 2026

19 June 2026 marks the entry into force of the new withdrawal-button obligation (in Germany § 356a BGB). From that day, every B2C online shop in the EU is required to provide a two-step withdrawal button. Experience shows that new information obligations in e-commerce are picked up very quickly by enforcement associations and specialised law firms. Precisely because this is an easily verifiable obligation – a single click on the home page is enough – breaches can be identified and documented in a matter of seconds.

The best-known example is the cancellation button under § 312k BGB, which has been mandatory since 1 July 2022. As early as the first weeks after it took effect, several associations and competition watchdogs systematically sent out warning letters. The German competition watchdog (Wettbewerbszentrale) reported several hundred cases in the first three months. The same dynamic is to be expected for the withdrawal button – possibly on an even larger scale, because far more shops are affected. The cancellation button mainly affected subscription providers, whereas the withdrawal button applies to almost every B2C goods shop.

On top of this: since the 2021 reform of German unfair-competition law (UWG), warning letters from competitors have become harder to issue. But that does not mean the risk is falling – qualified associations and the competition watchdog remain fully entitled to issue warnings, and specialised consumer protection associations have already announced the withdrawal button as a focus topic for 2026.

First steps after receiving a warning letter

You should take the following three steps within the first 24 hours of receiving the warning letter.

1. Don’t panic – but don’t be reckless either

Never sign the enclosed cease-and-desist declaration without review. Such declarations are often too broadly worded and can trigger a contractual penalty of €5,001 or more for every renewed breach. But do not ignore the warning letter either – that almost always leads to an interim injunction with additional costs.

2. Note the deadline and consult a lawyer

The deadline set (usually 3 to 10 days) is as a rule tight. Note the deadline immediately in your calendar and contact a lawyer specialising in competition law within 48 hours. In Germany, the initial consultation is capped at a maximum of €190 net under the lawyers’ fees act (RVG) and is worthwhile in almost every case.

3. Check your shop technically

In parallel, check whether the breach described in the warning letter actually exists. Is the withdrawal button present? Is it correctly labelled („Withdraw from contract“ in step 1, „Confirm withdrawal“ in step 2)? Does the automatic acknowledgement of receipt by email work? Document the current state with screenshots – ideally with a visible date in the browser.

In parallel, you should remedy the breach without delay. Every additional day on which your shop is not compliant increases the risk of a second warning letter from another association. A compliant withdrawal button is ready to use in under five minutes – there is no reason to wait for the lawyer’s response before implementing the technical fix. After remedying it, take another screenshot with a timestamp and store it together with the warning letter in your compliance folder.

What does a warning letter cost?

The cost of an unfair-competition warning letter consists of the lawyer’s fees that the warning party claims from you. These are based on the so-called value in dispute, which for breaches of information obligations is typically set between €7,500 and €25,000. The more serious the court rates the breach and the larger your shop, the higher the value in dispute.

• Simple warning (value in dispute €7,500): approx. €500–800 in lawyer’s fees
• Medium warning (value in dispute €15,000): approx. €900–1,200
• Serious warning (value in dispute €25,000): approx. €1,200–2,000
• Plus your own lawyer’s fees: another €500–1,500 for the defence

For comparison: a whole year of WiderrufButton on the Pro plan costs less than the lawyer’s fees of a single simple warning letter. And while the warning letter only concerns the current breach, a clean technical solution protects you permanently from further claims.

In addition, there is the threat of fines from the competent authorities: the rules implementing the withdrawal-button obligation provide for fines of up to €50,000 if a shop provides no withdrawal button at all or configures it in an obviously faulty way. In practice, such fines are usually imposed only for repeated or deliberate breaches – the risk of a civil-law warning letter is far more realistic for most merchants.

Who is entitled to issue warning letters?

Under German unfair-competition law (UWG), those entitled to issue warning letters are: competitors (i.e. other online shops in the same sector), qualified industry associations, the central office for combating unfair competition (Wettbewerbszentrale) and qualified consumer associations such as the vzbv. Since the 2021 UWG reform, the requirements for competitor warning letters have been tightened – pure warning-letter firms without a genuine competitive connection have a harder time today.

In practice this means: most warning letters will in future be issued by the large associations. They often send their letters in standardised form and simultaneously to hundreds of shops. If you receive such a letter, you are very likely not alone – and the warning firm can prepare for efficient processing.

What a warning letter typically looks like

An unfair-competition warning letter usually contains four elements: a description of the facts with a screenshot of the alleged breach, a legal assessment (usually with reference to § 356a BGB and § 3a UWG), a pre-formulated cease-and-desist declaration, and a claim for the lawyer’s fees. Reputable warning parties also enclose a power of attorney from the principals and point out the option of a modified cease-and-desist declaration.

The deadlines are typically short: 3 to 7 days for submitting the cease-and-desist declaration, 10 to 14 days for payment. These deadlines are not legally binding, but failure to meet them risks an interim injunction – which causes considerably higher costs. Going to court additionally brings court fees and further lawyer’s fees, and in an unfavourable case can result in enforcement proceedings.

Pay particular attention to warning signs of dubious warning letters: excessive values in dispute, a missing power of attorney, references to flat-rate settlement offers, or unusually short deadlines under three days. Such letters are becoming rarer, but they do occur from time to time, especially with newly introduced obligations such as the withdrawal button. A lawyer specialising in competition law spots such patterns quickly.

How to protect yourself against future warning letters

The best protection is a clean technical implementation before the 19 June 2026 deadline. You should tackle the following points already today:

1. Install the withdrawal button in good time: not on 18 June 2026, but ideally weeks beforehand
2. Check the correct labelling: „Withdraw from contract“ and „Confirm withdrawal“ – no creative custom text
3. Automatic email confirmation activated: mandatory (in Germany under § 356a(3) BGB)
4. Keep documentation: retain screenshots and timestamps of the correct implementation
5. Keep updates active: legal changes must land in your shop automatically
6. DPA with the widget provider: for the case where a consumer or a supervisory authority asks

You can find more background on the new obligation in our guide Withdrawal Button Obligation 2026. On the WiderrufButton home page you can also see a live demo of the two-step process.

Conclusion

A warning letter over the withdrawal button can cost €500 to €2,000 – per incident. Authority fines can additionally reach up to €50,000. The good news: with a clean technical implementation you are on the safe side. Act now, before 19 June 2026 arrives.

If you have already received a warning letter, follow our three-step checklist: stay calm, involve a lawyer, fix your shop technically. The combination of a quick technical response and legal advice leads in most cases to a modified cease-and-desist declaration and a reasonable settlement. If you have not yet received a warning letter, now is the right time to check your shop and install the withdrawal button securely – ideally several weeks before the deadline, so that you still have time for corrections if anything is unclear.