Requirement to link to the ODR platform no longer applies

The EU online dispute resolution platform — the ODR platform — will be discontinued on 20 July 2025. The requirement for online retailers to link to the ODR platform, in place since 2016, will therefore also cease to apply. For many retailers, this is a welcome relief. However, it is not quite that simple: retailers that have successfully been sent cease-and-desist letters for a missing or incorrect link to the ODR platform are an important exception.

What was the ODR platform — and why is it being discontinued?

The ODR platform was launched by the European Commission in 2016 to provide a straightforward way of resolving consumer disputes in online retail outside court. It was intended to serve as a central point of contact for conflicts between online retailers and buyers within the EU and formed part of a wider initiative to strengthen consumer protection in the digital single market. Since then, online retailers have had to provide a clearly visible reference to this platform — for example in their legal notice or cancellation policy. The ODR platform link thus became a mandatory component of many legal texts in e-commerce.

But the anticipated benefit failed to materialise:

Consumers barely used the platform. This was mainly because retailers were not required to participate and the settlements reached there were not legally binding. Final solutions therefore still had to be found through court proceedings. In addition, many users found the platform unintuitive, while technical problems compounded the issue. Trust was correspondingly low — among retailers and consumers alike. Ultimately, the ODR platform remained a toothless tiger.

Because of persistently low demand and limited practical relevance, the ODR platform will now be shut down permanently on 20 July 2025. Its closure also ends the corresponding statutory requirement to link to the ODR platform.

What does this mean for online retailers?

From 20 July 2025, the requirement to link to the ODR platform will no longer apply.

Specifically, this means:

From that date, you may and should remove the ODR platform link from your website — particularly from the legal notice, terms and conditions, or cancellation policy.

There is no requirement to link to a new platform, as no successor platform is currently planned.

If the ODR platform link remains online even though the platform is no longer accessible, this may confuse consumers — or result in outdated legal information, which may pose legal risks.

Caution: what about earlier cease-and-desist letters?

While consumers rarely used the platform, it was a popular target for competitors and associations issuing cease-and-desist letters — above all the notorious Interessenverband für das Rechts- und Finanzconsulting deutscher Online-Unternehmen e.V. (IDO association).

In the past, many retailers received cease-and-desist letters because of:

• A missing link to the ODR platform
• An incorrect or outdated link address
• A non-clickable ODR platform link

Many of these cease-and-desist letters resulted in the retailer issuing a cease-and-desist undertaking with a contractual penalty — meaning that the retailer contractually committed to provide the correct link in future, failing which a contractual penalty could apply.

Important: the end of the ODR platform does not automatically render such cease-and-desist undertakings void. Whether a contractual penalty remains possible depends on the wording of the undertaking.

What should retailers who received a cease-and-desist letter do now?

If you issued a cease-and-desist undertaking in the past, examine it carefully.

The following scenarios are possible:

The undertaking is worded dynamically (e.g. “I undertake to link to the ODR platform that is valid at the relevant time”): in this case, the obligation may end when the platform ceases to exist, as there is no longer a platform.

The undertaking expressly names the specific URL or a static action (e.g. “I undertake to link to www.ec.europa.eu/consumers/odr”): in this case, the obligation formally continues even though the platform no longer exists.

In both cases:

Do not take any risks. Obtain advice in good time if you wish to review and terminate your cease-and-desist undertaking. This will help you avoid possible contractual penalties.

We are available to provide legal advice. Please contact us for an individual assessment and practical solutions.

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