"One-click returns", "an e-commerce revolution", "the EU forces stores to change by June" - industry portals bombarded us with headlines like these all spring. Clients started calling to ask whether they had to rebuild their stores by June 19, or else face fines of up to 10% of turnover. Most of them don't have to do anything. And those who do - are usually not the ones the headlines are scaring. So before you spend a single euro on "adapting your store to the new return regulations", it's worth knowing what is actually coming into force. It's not the only legal change affecting e-commerce in 2026, by the way - we've written separately about the new digital accessibility requirements for online stores, where we also separate the facts from the media noise.
Where this date came from
At the source lies Directive (EU) 2023/2673 of the European Parliament and of the Council of 22 November 2023. The deadline for its transposition into national law passed on December 19, 2025, and the provisions are to apply from June 19, 2026.[1] And it's this second date that circulates through the industry as "the day everything changes".
The problem is that the directive's full title says something the headlines consistently omit. It reads: a directive amending Directive 2011/83/EU as regards financial services contracts concluded at a distance and repealing Directive 2002/65/EC.[1] The key phrase is "financial services". The new provisions do not cover distance sales of shoes, electronics, or cosmetics - they cover financial services contracts concluded online.
What the "withdrawal function" is
The most talked-about element of the directive is indeed the simplification of cancellation. The new Article 11a introduces an obligation to provide the consumer with a "withdrawal function" - in practice, a clear, permanently available button labeled with words like "withdraw from the contract here". It must be easily accessible, clearly labeled, and allow cancellation without fighting through hotlines and forms.
The idea is sound and - worth noting - consistent with the broader direction of EU consumer policy: if concluding a contract online takes two minutes, exiting it shouldn't require two weeks and a registered letter. Except that in the 2026 version, this obligation applies to financial services contracts concluded at a distance, not to every store selling physical goods.
Who this really affects in e-commerce
So can a typical online store ignore the topic? Not entirely - and this is where the part worth thinking through begins. More and more stores offer products on their sites that are financial services: installment purchases, deferred payments (BNPL), consumer credit, product insurance. If such a financial service is concluded at a distance, within your purchasing environment, then it is precisely this service that may fall within the scope of the new provisions - regardless of the fact that you yourself sell washing machines.
To make this less abstract - imagine three stores. The first sells 3D printer filament for cash and instant payments; the new financial services provisions don't apply to it at all. The second sells furniture and, for more expensive orders, offers installments concluded online with a financial partner; that part of its offer may fall within the directive's scope. The third is a platform that itself offers a financial product - credit, insurance, deferred payment as its own service concluded at a distance; here the obligations are the fullest. The closer the moment of concluding the financial contract is to your checkout, the more seriously the topic should be treated.
In practice, this means the dividing line isn't "store versus bank", but "is a financial services contract concluded in my purchase process". For some stores the answer is: yes, if only through an integration with an installment provider. And that is a real reason to review your checkout - not the panic from the headlines. If you're not sure how your payment integrations relate to the new requirements, it's a good moment to review your store's architecture with someone who understands both the law and the code.
What this change doesn't touch: the fourteen days
In all this confusion, the question I hear most often is: "does the 14-day return period disappear?". No. The consumer's right to withdraw from a distance contract within 14 days, without giving a reason, has been part of Polish law for years under the Consumer Rights Act, and the new directive does not abolish it. So if you sell physical goods, your basic obligations toward the customer - the fourteen-day period, refund of payment, information about the right of withdrawal - remain as they were. This matters, because some commentary suggests a "revolution" after which store owners imagine the existing rules stop applying. On the contrary: they are the foundation, and Directive 2023/2673 adds a narrow, specialized element to it concerning financial services.
For companies that genuinely fall within the scope of the new provisions, the direction is as follows: in addition to the withdrawal button itself, there are information obligations - before concluding a distance financial services contract, the consumer must receive a clear set of information, must have time to review the terms, and in specific situations has a right of withdrawal calculated in a way specific to these services. This is subject matter closer to financial regulation than to the classic "returning a parcel", which once again shows why mixing these worlds in a single headline is misleading.
The Polish plot twist: there is no act (yet)
Here the story gets unusual, and it's worth knowing before someone sells you "guaranteed compliance with the act". The fact is that the Polish act implementing the directive - at the time of writing - does not exist in final form. The implementation bill was withdrawn from legislative work in May 2026, as reported by, among others, the legal industry portal LegalnieWSieci.[2]
What does this mean for a business owner? A directive does not apply directly to consumers the way a regulation does - it requires a national act to embed it in Polish consumer law. As long as that act doesn't exist, there is no final wording of the obligations, no Polish effective dates, and no penalty procedure. The EU deadline of June 19, 2026 formally remains, but a gap has emerged that creates uncertainty - and at the same time removes the point of hasty, costly "just in case" implementations before we know the letter of the national provisions.
My advice to clients in this situation is unchanged: don't overpay for compliance with provisions whose final shape we don't yet know, but don't put off the housekeeping that will pay off for you anyway.
What's worth doing regardless of the act's fate
Because there is a group of things that are a good idea regardless of when and in what wording the Polish act comes into force. A transparent, simple return process is not a concession to Brussels - it's an element that genuinely raises conversion: a customer who knows they can easily return goods buys them more easily. Clear information about the right of withdrawal, readable terms without clauses that could be deemed unlawful, an efficient return form instead of a hidden email address - all of this works in your favor today.
We've approached it in exactly this spirit in the stores we run or co-build. On filamencik.com and on best-dog.pl, a return is a single, clear process guided by the hand - the customer doesn't hunt for an email address or a form in the footer, they simply walk through a simple form. We did this before anyone required it, because a well-run return process simply pays off: it removes the fear of purchase and shortens handling on the store side. So we treat the new EU provisions not as a revolution to survive, but as a direction worth going in anyway.
It's also worth remembering who polices the market. In Poland, consumer rights are overseen by the President of the Office of Competition and Consumer Protection (UOKiK), who can challenge unlawful clauses in contract templates and impose fines - and does so regardless of whether the latest directive has just come into force.[3] Clean terms of service and fair return procedures therefore protect you all the time, not just from a specific date.
Concretely, if I had to point out what to review in a store regardless of the act's effective date, it would be a short list. Check whether the information about the right of withdrawal is provided before purchase, not buried in terms of service nobody reads. See whether a return can be initiated from the customer account or a simple form, instead of sending an email to an address that has to be dug out of the footer. Review your contract template for clauses that could be deemed unlawful - shortening the statutory period, shifting costs onto the customer that they don't have to bear, or making a return conditional on "original, undamaged packaging" where the law doesn't allow it. And finally - if you offer installments, deferred payment, or insurance, establish with the provider of those services who is responsible for the new obligations for a financial contract concluded in your store. That's a question worth asking your payment partner today, before an inspection asks it for you.
When the Polish act finally takes its final shape, we'll return to the topic with specifics - deadlines, the wording of obligations, and what actually needs to change in a store. Until then, it's better to invest in a solid, sales-friendly return process than in a rushed implementation driven by a headline. If you'd like us to assess your terms of service and return path for both compliance and conversion, get in touch - and we write separately about activities that increase sales.
Sources
- Directive (EU) 2023/2673 of the European Parliament and of the Council of 22 November 2023 amending Directive 2011/83/EU as regards financial services contracts concluded at a distance and repealing Directive 2002/65/EC - EUR-Lex.
- LegalnieWSieci.pl, "Fast returns delayed? The government withdraws the e-commerce bill" (May 2026) - legalniewsieci.pl.
- Office of Competition and Consumer Protection (UOKiK) - competences in protecting collective consumer interests: uokik.gov.pl.
