Frankfurt

As part of the EU’s measures to support consumers contracting with online retailers, it has introduced requirements that retailers make it easier for consumers to withdraw from online contracts, by providing clearer (and well signposted) means of withdrawal online. Despite its name, Directive (EU) 2023/2673 as regards financial services contracts concluded at a distance contains important new rules for all online consumer contracts as it amends an important directive on consumer rights (Directive (EU) 2011/83).  Online retailers (whether based in the EU or based outside the EU but targeting the EU market) will therefore need to adjust their online contracting processes and ensure they have appropriate online architecture in place to permit consumers to withdraw from a contract in the manner the directive requires. France has now implemented the changes required into French national law, but all EU Member States need to follow suit. Online retailers should be working to implement these new requirements before 19 June 2026.

As anticipated in our 2024 privacy round up, 2025 has proven to be a defining year for data privacy and the broader digital landscape. Significant developments in AI regulation and cybersecurity have emerged, with legislative updates and regulatory activity accelerating as expected. Geopolitical dynamics continue to influence the adoption of new technologies, and questions remain over whether the EU will advance its tech regulation agenda, particularly following steps to delay certain implementation phases (most notably in AI) through its Digital Omnibus. With global data protection developments continuing at pace and further changes expected in 2026, now is an opportune moment to reflect on what 2025 delivered for businesses and to consider what 2026 may hold for the EMEA region.

On 13 November 2025, the European Parliament (the “Parliament”) adopted its negotiating position on the EU Omnibus I Directive amending the EU Corporate Sustainability Reporting Directive (“CSRD”) and the EU Corporate Sustainability Due Diligence Directive (“CSDDD”). The text adopted by the European Parliament can be found here and their press release here.