On this page
By default, yes — EU consumers have 14 days to withdraw from a distance contract, and for digital content the clock starts when the contract is concluded rather than when anything is delivered. The exception exists, but it needs three specific things to have happened at the checkout, and the Court of Justice has said it is to be read strictly.
Then there is the commercial answer, which points the same way for a different reason: a refund costs you €0.55 and a chargeback costs €20.
Not legal advice. The provisions below are from Directive 2011/83/EU and the Commission's guidance on it, checked 8 October 2026.
What is the default position?
Fourteen days, no reason required.
For most distance contracts that period runs from delivery. For digital content that is not supplied on a tangible medium — a download, a stream, access to a members' area — it runs from the day the contract is concluded. Which for a one-click purchase is the moment they paid.
So without doing anything, you have sold something that can be returned for a fortnight, including the version of it already sitting on the buyer's hard drive.
What are the three conditions?
Article 16(m) removes the withdrawal right for digital content not on a tangible medium, but only when all three of these are true:
| # | Condition |
|---|---|
| 1 | The consumer gave prior express consent for performance to begin during the withdrawal period |
| 2 | The consumer acknowledged that they thereby lose the right of withdrawal |
| 3 | The trader provided confirmation of the contract, per Articles 7(2) or 8(7) |
Three, not one. And the first two are things the consumer does, which is the detail that catches people.
A sentence in your terms and conditions is not express consent, because the consumer did not give it — you wrote it. What is needed is an active choice at the point of purchase: a field they tick, saying both that delivery starts immediately and that this ends their right to cancel.
The Court has held that this exception is to be interpreted strictly. In practice that means: if you are not sure the checkout captured it properly, assume you do not have it.
The whole list
67 tools, what each costs and when you actually need it. Updated twice a year.
What does a refund actually cost you?
Less than almost everyone assumes.
Stripe's documentation is explicit that processing fees from the original charge are not returned on a refund. So on a €20 sale:
| Amount | |
|---|---|
| Returned to the customer | €20.00 |
| Original card fee, kept by the processor | €0.55 |
| VAT already remitted | reclaimable through your return |
| Your net cost | €0.55 |
Fifty-five cents. That is the entire price of saying yes.
And what does saying no cost?
€20, plus the refund anyway, about one time out of however many people you refuse.
A customer told no does not generally go away. They go to their bank, and a dispute costs €20 in fees on Stripe's Netherlands pricing — on top of the money being taken back regardless of who is right.
| Outcome | Cost to you |
|---|---|
| You refund | €0.55 |
| They dispute instead | €20.00 + €20.00 refunded |
That is a factor of about thirty-six between the cheap path and the expensive one. You do not need a high dispute rate for the arithmetic to favour generosity — you need roughly one dispute per thirty-six refusals, which is not a demanding threshold.
What taking your first payment online actually costs has the rest of the per-sale numbers.
So what should your policy actually be?
Shorter than you think, and more generous than required.
Capture the consent properly anyway. Not to refuse people, but because without it you have no position at all if someone buys nine products on a Friday and withdraws from all of them on Monday. Having the right and not using it is a comfortable place to be.
Then refund on request, without interrogation. At €0.55 the investigation costs more than the refund. Asking "what went wrong?" once is useful product research; requiring an answer before you pay is a dispute waiting to happen.
Say so on the page, in one sentence. A visible refund line raises conversion more than it raises refunds, because the people reading it are the ones deciding whether you are real.
Never promise less than the law gives. A policy can add to a consumer's rights and cannot subtract from them. "No refunds under any circumstances" is both unenforceable and a signal that you have not looked this up.
What about the person refunding everything?
They exist, and they are not the problem you think.
At €0.55 a time, someone who buys and refunds repeatedly costs you small change and removes themselves from your list. The seller who builds a hostile policy to stop that person charges the honest majority for the inconvenience of the rare one — and then meets the rare one anyway, at the bank, at €20.
If it ever becomes systematic, the lever is the checkout, not the policy: require an account, or stop selling to the address. Both are better than making every other buyer read a paragraph about fraud before they can pay you.
Where this came from
Directive 2011/83/EU on consumer rights — the 14-day period, the start date for digital content, and the Article 16(m) exception with its three conditions — together with Commission guidance and the Court's position that the exception is read strictly. Checked 8 October 2026.
Stripe's Netherlands pricing and its refund documentation for the fee figures, same date. What VAT do you charge on a digital product in the EU? covers the tax side of the same sale.
National implementations differ in detail, and this is the structure rather than advice for your situation. The Digital Products Playbook covers the commercial side of running a shop like this.
Tools in this piece
| Tool | What it does | Price |
|---|---|---|
| Stripe | Payments and subscriptions. The standard, and integrating it is a matter of asking. | Free, percentage per sale |
| Shopify | Hosts the store, takes the payment and handles the tax. | From ~€29/mo |
Every tool has its own page with the price, who should skip it and what to check before paying. Some links are affiliate links.
Questions people ask
Is there a 14-day right to cancel on digital downloads in the EU?
Yes by default. Consumers have 14 days to withdraw from a distance contract without giving a reason, and for digital content not supplied on a tangible medium the period runs from the day the contract is concluded.
When does the buyer lose the right to withdraw?
Under Article 16(m) of the Consumer Rights Directive, when three things are true: the consumer gave prior express consent for performance to begin during the withdrawal period, acknowledged that they thereby lose the right of withdrawal, and the trader provided confirmation of the contract. All three, not one.
Is a line in the terms and conditions enough?
No. The consent and the acknowledgement have to be given by the consumer, which means an active choice at the checkout. The Court has held that this exception is to be interpreted strictly.
What does a refund cost the seller?
On Stripe's standard pricing the processing fee from the original charge is not returned, so a refunded €20 sale costs you the €0.55 fee. A chargeback costs €20 in dispute fees on top of the refund.
Should you offer refunds even when you do not have to?
At these numbers, usually yes. A refund costs €0.55 and a dispute costs €20 plus the refund anyway. Saying no converts a cheap outcome into an expensive one about one time in a hundred, which is all it takes.
Does a refund policy on the site change the legal position?
It can only add rights, never remove them. A policy more generous than the law is binding on you; a policy less generous than the law is not binding on the consumer.