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ARTICLE · 02 JUNE 2026

EU Withdrawal Button, UK Subscription Rules, And Data Protection Risks For U.S. Online Sellers

Arnold & Porter
Arnold & Porter
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Arnold & Porter

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European and UK regulators are implementing sweeping changes to online subscription practices that will fundamentally reshape how businesses handle consumer contracts and cancellations.

United KingdomPrivacy

Introduction

Regulators are intensifying scrutiny of subscription practices worldwide, as we previously highlighted in our discussion of U.S. developments, and the European Union (EU) and United Kingdom (UK) are now moving aggressively ahead of the United States. In the EU, Directive 2023/2673 comes into force on June 19, 2026, requiring all businesses that sell online to EU consumers to provide a mandatory digital withdrawal function for consumer (B2C) contracts. In the UK, the Digital Markets, Competition and Consumers Act 2024 (DMCCA) will introduce new rules for subscription contracts effective Spring 2027. Together, these represent the most significant overhaul of online consumer law in over a decade. Both also carry data protection implications that may not be immediately obvious.

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