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July 20, 2026 • 4 mins

As of 19 June 2026, withdrawing from a contract concluded online should become as simple as signing up for it. In this episode, journalist Antonio Ravenna interviews Federico Toscani of DLA Piper to unpack the new Article 54-bis of the Italian Consumer Code (Legislative Decree 206/2005), introduced by Legislative Decree 209/2025.

At the heart of the conversation is a new obligation for businesses selling at a distance: they must provide a clear, visible, and easily accessible digital withdrawal function — effectively a "withdrawal button" placed on the same online interface used to enter into the contract.

Over the course of the interview, Federico Toscani and Antonio Ravenna discuss:

1. the rationale behind the rule, and why it exists to rebalance the ease of purchase against the difficulty of cancelling;
2. what the withdrawal function must actually include (button wording, the withdrawal declaration, and the details identifying the consumer and the contract);
3. the confirmation step and the acknowledgment of receipt sent on a durable medium;
4. the moment at which withdrawal is deemed validly exercised in relation to the statutory deadline (paragraph 7);
5. what companies should do right now to bring their websites, apps, and customer journeys into compliance and avoid disputes.

A valuable episode for e-commerce operators, legal departments, compliance teams, and anyone working in the digital market who wants to align their withdrawal process with the transparency and accessibility standards required under the new regime.

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Episode Transcript

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SPEAKER_00 (00:00):
Hello everyone, I'm Federico Toscani and I'm a

(00:02):
trainee lawyer at DLA Piper.

SPEAKER_01 (00:04):
And I'm Antonio Ravenna, a journalist.

SPEAKER_00 (00:06):
Today we are here to talk about the new digital
withdrawal function introducedwithin the Italian consumer
code.

SPEAKER_01 (00:13):
And we're gonna make it in the time of a coffee
break.
So Federico, starting June 19,2026, a new rule changes how a
consumer can exit onlinecontracts in Italy.
So what's the problem it'strying to solve?

SPEAKER_00 (00:30):
Yeah, the this new provision is addressing a
specific problem which is verycommon in the online context.
Concluding a contract, enteringinto a contract is pretty easy
while withdrawing sometimes it'smore complex.
Indeed, in practice, normallywithdrawal functions are hidden
in complex term and condition.

(00:51):
Sometimes consumers are requiredto fill in complex forms or make
multiple steps in order towithdraw from the contract.
Whereas entering into thecontract is usually easy and
requires only a few clicks.
So the this new provision aimsto solve this specific problem
by making withdrawing from thecontract as easy as entering

(01:15):
into the contract.

SPEAKER_01 (01:16):
And so, what are the concrete requirements?

SPEAKER_00 (01:19):
There are mainly four concrete requirements.
First of all, all companiesshould include within the
website the so-called withdrawalbutton, which is a button
expressly stating that theconsumer can withdraw by
clicking on the button.
For instance, the law talksabout a button stating you can

(01:40):
withdraw from the contract byclicking here, so something that
can make the consumerimmediately acknowledge the real
elements.
The button should lead theconsumer to a specific section
within the website where theconsumer can fill in the
so-called declaration ofwithdrawal where some
information are necessary suchas the personal details of the

(02:03):
consumer and the informationneeded to identify the contract
from which the consumer iswilling to withdraw.
Then there should be a specificconfirmation button.
After the consumer has filled inthe declaration of withdrawal,
there must be a confirmationbutton which is used to send the
withdrawal declaration directlyto the company.

(02:27):
And after the consumer haspushed on such button, the
company must send immediately anacknowledged receipt stating
that the withdrawal declarationhas been properly submitted.

SPEAKER_01 (02:40):
So there are a few passages, and uh when exactly is
the withdrawal consideredexactly exercise?

SPEAKER_00 (02:47):
Yeah, that it's a critical point, and the law
expressive provides that thewithdrawal has to be considered
sent to the company when theconsumer clicks on the
confirmation button.
So that's not the moment wherethe company acknowledges
receipts, which could beafterward, but the specific
moment where the consumerselects the confirmation button

(03:10):
so as to avoid any kind ofmisunderstanding on the specific
moment.

SPEAKER_01 (03:15):
So, what should companies do right now?

SPEAKER_00 (03:18):
Companies should make we can say four specific
steps.
First of all, they should revisetheir website to understand
where the contract is concludedand thus where to insert the
confirmation button, as thebutton should be inserted in the
same page where the contract isconcluded.
Second, they should work on makethis button crystal clear so

(03:43):
that there will be no doubt onthe fact that that button leads
to withdrawing from thecontract.
Then they should preparespecifically the middle page
where the consumer can insertall the information and be sure
that the information to becontained in the declaration are

(04:03):
the one required by law.
And finally, they should have aspecific tool that ensures that
upon confirmation thedeclaration of withdrawal is
immediately sent to thecustomer.

SPEAKER_01 (04:17):
Thank you Federico.

SPEAKER_00 (04:19):
Thank you so much.
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