Over the past few months, the regulation of the Withdrawal Button (Botón de Arrepentimiento) and the Service Cancellation Button (Botón de Baja de Servicios) has evolved to better reflect e-commerce reality, seeking to strike a balance between consumer rights and companies’ operational needs.
Before reviewing the latest updates regarding identity verification, it is important to clearly distinguish between both mechanisms:
Withdrawal Button: Allows consumers who purchased products or hired services remotely to revoke their consent and cancel the transaction within a cool-off period of 10 calendar days from the date of purchase or delivery of the product, whichever takes place later.
Service Cancellation Button: Enables consumers to request the termination of subscriptions or services that were contracted remotely.
Until this year, the applicable regulation provided that companies could not require consumers to complete any additional registration or formalities in order to use these buttons. While this prohibition aimed to facilitate the exercise of consumer rights, in practice it limited companies’ ability to implement identity verification processes for fraud prevention. To address this issue, in February 2026 a new regulation was enacted, allowing companies to implement reasonable mechanisms to verify the identity of consumers.
Below are key recommendations to ensure that websites and digital platforms comply with the current regulations on Withdrawal and Service Cancellation Buttons:
- Visibility: The buttons must be placed in a prominent location, at a minimum on the homepage of the website or platform.
- Processing Time: Companies must process the consumer’s request within 24 hours and provide a case identification code.
- Event Tickets: When the Withdrawal Button is used to return tickets for shows or events, the 10-day cool-off period for the consumer to notify their withdrawal shall be calculated from the date the tickets were received.
- Deadline for Cancellations: When the Withdrawal Button is used to return tickets for shows or events, or to cancel travel services (for example, transportation, accommodation, excursions, or car rentals), the consumer must notify their withdrawal at least 24 hours before the start of the show, event, or service.
- Identity Verification: To prevent fraud, companies may implement identity verification mechanisms for consumers using the Withdrawal and Service Cancellation Buttons. These mechanisms must be reasonable, taking into account the nature of the products or services, the actual fraud risks involved, and the security standards applied at the time of sale or delivery.
Additionally, since 2025, companies operating in the City of Buenos Aires that offer customer service or after-sales services through their websites must implement an Online Book for Complaints, Acknowledgments, Suggestions, and Claims. Further information on this matter is available here.
If you need legal advice regarding your website, platform, or e-commerce operations, please contact us at info@lermanszlak.com.
Gabriela Szlak – T° 79 F° 516 CPACF
Luciano N. Gutman – T° 145 F° 535 CPACF
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1- Provision 954/2025 of the Undersecretariat for Consumer Protection and Fair Trade. Available in Spanish here: https://www.boletinoficial.gob.ar/detalleAviso/primera/330827/20250904https://www.boletinoficial.gob.ar/detalleAviso/primera/330827/20250904.
2- Provision 3/2026 of the National Directorate for Consumer Protection and Consumer Arbitrarion. Available in Spanish here: https://www.boletinoficial.gob.ar/detalleAviso/primera/338248/20260206?busqueda=1.
