The EU Withdrawal Button Rule: Most Global Studios Are Not Ready

On June 19, new EU consumer rights obligations come into force. Game studios will be impacted not only by fines - set by each EU member state - but also by a forced 12 month refund window. 

This will apply for every sale to an EU player.

What the EU withdrawal regulation requires

In plain English, the directive will require any online business to provide an electronic withdrawal function for transactions concluded via an online interface.

The requirements for sellers are specific:

• The function must be labeled "withdraw from contract here" (or an equivalent that is similarly unambiguous)
• Labels like "Cancel" alone are not sufficient
• It must follow a two-step flow: the first step registers the consumer's intention to withdraw, the second confirms it. 
• The withdrawal function must be accessible throughout the full 14-day withdrawal period

This applies to goods, services, digital content, and digital services. 

Meaning subscriptions, battle passes, DLC - any digital purchase sold to EU consumers - falls within scope.

Who it applies to - and what most studios are missing

This is the most common blind spot.

In practice, that means any business that actively sells to EU consumers, regardless of where the business is incorporated.

(Specifically, the language says the regulation applies to ‘any business whose contracts are governed by EU member state consumer law.’)

Meaning, a studio based in Los Angeles or London, with a webstore that takes payments from EU players for subscriptions or DLC, is on the hook and can be found liable for breaching the new regulation.

Many studios we’ve spoken to outside the EU have not made this connection. 

Because it’s a EU regulation, there’s an assumption it does not apply to them. For this one, it does. 

Studios that are acting on this now still have time. The ones that discover it after June 19 will be catching up while the exposure builds.

Unpacking the real risk

Some member states have implemented a tiered penalty structure for sellers found guilty for breaching the rules. Germany for example, announced that companies with EU annual turnover below EUR 1.25 million, default fines run up to EUR 50,000. 

For larger businesses, the cap rises to 4% of annual turnover. 

Other EU member states are setting their own enforcement frameworks.

But the fine is not what studios should be modeling.

Under the Consumer Rights Directive, a trader who fails to properly facilitate withdrawal can face a withdrawal period that extends from 14 days to up to 12 months. 

That means a player who purchases a subscription in July 2026 from a non-compliant store can request a full refund as late as July 2027.

For any studio running recurring revenue to EU players, that is a year of open refund exposure per non-compliant sale. 

Every new transaction from a non-compliant store adds to the window. Missing the deadline is not just a fine. It is the start of a rolling liability window on every EU sale made after it.

What a compliant experience looks like

The regulation is built on a clear principle: withdrawing from a contract must not be harder than entering one. 

If a player can subscribe in two clicks, they need to be able to cancel in two clicks.

A compliant flow has five elements:

1. A dedicated withdrawal function. Not a generic contact form or a buried settings page.
2. Clear labeling: "withdraw from contract here" or an unambiguous equivalent
3. A two-step confirmation: an intent step, then confirmation
4. Consistent placement: withdrawal button must remain accessible throughout the full withdrawal period
5. Visibility: a player should be able to find it within a few clicks from the point of purchase
6. If a studio's current storefront does not have all five, it will be non-compliant on every EU sale it makes

Why studios using a Merchant of Record have nothing to worry 

A Merchant of Record is the legal seller of record on every transaction it processes. Compliance with consumer law, including the cancellation infrastructure required under the Consumer Rights Directive, sits with the MoR.

For example, the Tebex Portal gives every player a self-serve view of their full purchase history and every active subscription, with a cancellation flow already meeting the two-step withdrawal requirement before June 19. 

Studios powering their monetization through Tebex are covered without additional steps.

This is one of the biggest strengths for studios partnering with a Merchant of Record: when regulators move, your monetization layer adapts with it. 

The MoR takes on the regulation, tax, and dispute obligations. The studio simply keeps building.

What to do now if you are not on a Merchant of Record

June 19 is close. 

Getting compliant before the new regulation takes place protects studios from the rolling exposure window and any specific fess:

Three steps to take now:

1. Audit all your player-facing store for EU players: does a dedicated, clearly labeled withdrawal function exist? If not, that is the first fix.
2. Check whether your current payment provider or monetization layer can implement the two-step flow before June 19
3. Review the withdrawal language in player-facing terms: if your legal documentation references the right of withdrawal without a working button or other mechanism that is not sufficient and your studio is at risk.

The regulation is designed to give players an easy way out when they want one. The studios building their commerce infrastructure with that in mind will be ready on June 19. The ones that are not will be managing it after the fact.

To learn more, join Liam at Develop:Brighton where he’ll be speaking on D2C monetization and regulatory change in gaming or contact Tebex here to see how Tebex scales D2C revenue while offloading the operational risk for global sales.