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Cancellation button report, December 2026: 525 subscription sites in Germany and Austria

For our second report we grew the panel from 150 to 525 subscription providers, 99 of them in Austria, and checked every home page in the weekly run of 9 and 10 November 2026. In Germany only 37 of 400 checked sites use the wording from § 312k BGB, 106 use a different label, and on 257 we found no cancellation link on the home page. In Austria, which has no such duty, we found none on 96 of 98.

Results for Germany

  • 37 of 400 (9%) show "Verträge hier kündigen" on the home page, the wording in § 312k(2) BGB.
  • 106 of 400 (27%) use a different label, most often "Abo kündigen" (32 times) and "Vertrag kündigen" (29 times). The statute also allows "a corresponding unambiguous wording"; whether a variant is enough depends on the case.
  • 257 of 400 (64%): we found no cancellation link or button on the home page.

26 more German sites could not be checked (blocked, empty, errors, or excluded by robots.txt). The 276 German providers added since the November report do worse than the November panel: on 185 of 257 checked (72%) we found no link, against 71 of 142 (50%) of the 142 sites from the November report.

By sector (Germany)

  • Telecom and energy, 34 sites: 8 statutory wording, 16 variant, 10 no link found.
  • Dating, 16: 6 statutory wording, 3 variant, 7 no link found.
  • Gyms and memberships, 40: 4 statutory wording, 17 variant, 19 no link found.
  • Newspapers and magazines, 82: 2 statutory wording, 36 variant, 44 no link found.
  • Digital subscriptions (learning, software, cloud, streaming), 81: 9 statutory wording, 13 variant, 59 no link found.
  • Mobility and insurance, 40: 1 statutory wording, 9 variant, 30 no link found.
  • Subscription boxes and deliveries (coffee, meal kits, pet food, wine, contact lenses), 107: 7 statutory wording, 12 variant, 88 no link found.

Telecom and energy providers are furthest along: 24 of 34 show a cancellation link. Newspapers and magazines often show a link (36 of 82) but rarely the statutory wording (2). The gap is widest among subscription boxes and deliveries: on 88 of 107 we found no cancellation link.

Germany and Austria compared

  • Germany, 400 checked: 37 statutory wording (9%), 106 variant (27%), 257 no link found (64%).
  • Austria, 98 checked: 0 statutory wording, 2 variant (2%), 96 no link found (98%). One more Austrian site could not be checked.

This is not a failing of Austrian providers: Austrian federal law has no cancellation-button duty like § 312k BGB. Since 1 October 2026, § 13a FAGG (BGBl. I No. 59/2026, implementing EU Directive 2023/2673) only requires a withdrawal function labelled "Vertrag widerrufen", available during the withdrawal period. The comparison shows what happens without a duty: the cancellation link on the home page is missing almost everywhere. Austrian businesses selling subscriptions to consumers in Germany should check whether § 312k BGB applies to them.

What changed since November

Of the 142 sites we checked on 4 November for the first report, 21 now use the statutory wording, 50 a variant and 71 show no link. On 4 November it was 21, 49 and 72. 1 site now shows a cancellation link where there was none. No site got worse.

Method and limits

  • We checked the home page only: it is fully rendered and scrolled to the footer, then the text of every link and button is classified. No forms are filled in.
  • "No link found" does not by itself mean the law is broken. The button may sit elsewhere, for example only on sub-pages or in the customer account, and some offers fall outside § 312k BGB. The statute does require the button to be permanently available and directly and easily accessible; the footer of every page is the usual place.
  • The sample covers providers that publicly advertise subscriptions or fixed-term contracts. It is not representative of the whole market. The 375 new sites joined on 4 and 6 November 2026; comparisons with November cover only the 142 sites checked then. The weekly run took place on 9 and 10 November 2026: 348 sites on 9 November and the remaining 177, with the same checking code, on 10 November after the run stopped.
  • We repeat the check weekly on the same sites and keep a hash of each page as evidence. We do not name individual providers.

Why it matters now

On 16 July 2026 (I ZR 200/25) the Federal Court of Justice ruled that retention offers do not belong on the confirmation page. On 5 November 2026 it heard two cases on logins behind the button (I ZR 272/25, I ZR 275/25); judgment will be announced on 14 January 2027. Both cases were brought by the Federation of German Consumer Organisations (vzbv) and the Wettbewerbszentrale.

How to check your own site

  • Open your home page logged out, ideally on a phone, and scroll to the footer.
  • Does it say "Verträge hier kündigen" or something equally clear?
  • Does the link lead, without a login, to a confirmation page with the statutory fields and "jetzt kündigen"?
  • Does a confirmation with date and time arrive right away, for example by email?

Whether you need the button at all, our free check answers in a minute. Not legal advice; if in doubt, ask a lawyer.

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