A consumer buying at a distance has fourteen days to withdraw without giving a reason, under section 20 of the Consumer Protection Law 112(I)/2021, and thirty days where the contract was made during an unsolicited visit or an organised excursion. A seller who never mentions the right lives with it for twelve months longer, under section 21. The refund is due within fourteen days of being told, by the same means of payment, and the exceptions in section 27 protect a seller only where the consent they require was actually collected.
Most disputes about an online return in Cyprus are not really about the product. They are about whether a right existed, when it expired, who pays the postage, and what the seller was allowed to keep. All four are answered by the Consumer Protection Law of 2021, Law 112(I)/2021, whose Part IV applies to a distance contract and to a contract concluded away from business premises, and which is not displaced by anything the seller writes into its own terms.
That Part is where this subject now lives. Section 74 of the 2021 Law repealed the Consumer Rights Law of 2013 outright, together with the unfair terms, unfair commercial practices, price indication and consumer guarantees legislation, and gathered all of it into a single statute. A returns policy that still cites the 2013 Law is citing something that no longer exists, and the section numbers in it are not the ones a court or the Consumer Protection Service will be reading.
This is written for both sides of that argument. A buyer needs to know what the right actually is before demanding it. A seller needs to know which of its own habits, a pre-ticked box at checkout, a premium-rate helpline, a returns policy copied from another site, quietly create liability.
The fourteen days, and when they start
Unless one of the exceptions in section 27 applies, section 20(1) gives the consumer fourteen days to withdraw from a distance or off-premises contract without giving any reason and without any charge beyond the obligations in sections 24(2) and 25. There is no requirement to show that the goods were faulty, and no requirement to justify the change of mind.
Section 20(1A) adds a longer period that the 2013 Law did not have. Where the contract was concluded during an unsolicited visit by the trader to the consumer's home, or during an excursion organised by a trader with the aim or effect of promoting or selling products to consumers, the period is thirty days. That is the doorstep sale and the coach trip, and it is precisely the situation in which a buyer is least likely to know they have any right at all.
Section 20(2) decides when the clock starts, and it is not the same date for everything. For a services contract the period runs from the day the contract was concluded. For a sale it runs from the day the consumer, or a third party they indicated other than the carrier, acquires physical possession of the goods, which is the point most often misstated in a returns policy written around the order date.
The twelve months a seller invites by saying nothing
The provision that turns a paperwork failure into a commercial one is section 21(1). Where the trader has not given the consumer the information about the right of withdrawal that section 17(1)(h) requires, the withdrawal period does not simply continue: it ends twelve months after the end of the original period.
Section 21(2) provides the cure, and it works only until that year is up. If the trader supplies the missing information within those twelve months, the period ends fourteen days after the consumer receives it. A seller who discovers the omission has an obvious step to take, and taking it late is still better than not taking it.
There is a second consequence in section 25(2), and it is easy to miss. A consumer is liable for any diminished value of goods resulting from handling beyond what was necessary to establish their nature, characteristics and functioning. But where the trader failed to give the section 17(1)(h) notice, the consumer is not liable in any case for that diminished value. The same omission therefore extends the right and removes the seller's main defence about the condition of what comes back.
How the right is exercised
A sentence saying you are cancelling is enough; there is no form you have to use. Under section 22(1) the consumer informs the trader of the decision to withdraw before the period expires, either using the model withdrawal form set out in Part B of Annex I to the Law or by any other unequivocal statement. A telephone call can satisfy that, which is why a seller should keep a record of calls about orders, and why a buyer should follow one with an email.
The withdrawal button, which an online seller must now build
Since 19 June 2026 an online seller has to put a cancel button on the interface, and it has to be there for the whole of the withdrawal period. This is the newest obligation on the page and the one most Cyprus websites do not yet meet.
Section 22A(1)(a), inserted by Law 30(I)/2026, requires a trader, for distance contracts concluded through an online interface, to ensure that the consumer can also withdraw using a withdrawal function. Section 22A(1)(b) then prescribes how it looks and where it lives: it carries the words "Click here to withdraw" or a clear equivalent, legibly; it is continuously available throughout the withdrawal period; it appears prominently on the online interface; and it is easily accessible to the consumer.
The function is not merely a link to a contact form. Section 22A(2) requires it to let the consumer send an electronic withdrawal statement, informing the trader of the decision and easily providing or confirming three things: the consumer's name; the details identifying the contract they are withdrawing from; and the details of the electronic means by which the confirmation of withdrawal is to be sent back to them. Section 22A(3) then requires a second step: once the statement is complete, the trader must let the consumer submit it through a confirmation function, marked legibly and only with the words "confirmation of withdrawal" or a clear equivalent.
What the seller owes back immediately is a receipt. Section 22A(4) requires the trader, once the consumer activates the confirmation function, to send an acknowledgement of the withdrawal on a durable medium, including its content and the date and time it was submitted, without undue delay.
And the last subsection is the one that decides disputes. Section 22A(5) deems the consumer to have exercised the right of withdrawal within the period if they used the withdrawal function before it expired. A seller whose button was broken, hidden after the first week, or routed to an inbox nobody reads is arguing against a statutory deeming provision.
What the seller owes back, and when
Fourteen days to refund, counted from the day you are told, and the delivery you charged goes back too. Section 24(1) requires the trader to reimburse every payment received from the consumer, including where applicable the costs of delivery, without undue delay and in any event within fourteen days of being informed of the decision to withdraw. The refund must use the same means of payment the consumer used for the original transaction, unless the consumer has expressly agreed otherwise, and the consumer must not incur any fee as a result of the refund. A credit note is not a refund unless the buyer agreed to one.
Two qualifications sit alongside it. Under section 24(2) the trader need not reimburse supplementary delivery costs where the consumer expressly chose a delivery method other than the cheapest standard delivery the trader offers: the standard cost comes back, the premium for next-day delivery does not. Under section 24(3), unless the trader has offered to collect the goods itself, it may withhold the refund on a sale of goods until it receives them back, or until the consumer supplies evidence of having sent them, whichever happens first.
What the buyer owes, and who pays the postage
Post the goods back within fourteen days of telling the seller you are cancelling. Section 25(1) requires the consumer, unless the trader offered to collect the goods, to send them back without undue delay and in any event within fourteen days of communicating the decision to withdraw. Sending them before that period expires is enough; they need not have arrived.
The consumer bears only the direct cost of returning the goods, and not even that where the trader agreed to bear it or failed to tell the consumer that the cost would fall on them. A returns page that is silent on postage therefore leaves the seller paying it. For an off-premises contract where the goods were delivered to the consumer's home at the time the contract was concluded, the trader collects them at its own expense if they are goods that by their nature cannot normally be returned by post.
Where the consumer asked for a service to begin during the withdrawal period and then withdraws, section 25(3) requires payment of an amount proportionate to what was supplied up to the moment of withdrawal, calculated on the total price agreed in the contract, or on the market value of what was supplied where that total price is excessive.
Financial services bought at a distance are a separate regime
An online loan, an insurance policy or an investment service bought without meeting anyone is not governed by the sections above. Law 30(I)/2026, in force since 19 June 2026, inserted sections 27A to 27E to transpose Directive (EU) 2023/2673, which amended Directive 2011/83/EU for distance contracts for financial services and repealed Directive 2002/65/EC. The periods and the duties are different, and a business that assumed the goods rules applied has the wrong ones.
Fourteen days, and thirty for a personal pension. Section 27B(1)(a) gives the consumer fourteen calendar days to withdraw from a distance financial services contract without penalty and without giving a reason, extended to thirty calendar days for contracts concerning individual pension operations. The period runs from the day the contract is concluded, or from the day the consumer receives the contractual terms and the section 27A information if that is later.
Where the terms and the information never arrive, section 27B(1)(c) sets a longstop of twelve months and fourteen days from conclusion. That longstop does not apply where the consumer was never told about the right of withdrawal under section 27A(1)(p), so on those facts the right does not expire at all.
What has to be given, and by whom it is proved. Section 27A(1) lists nineteen items that must be provided in good time before the consumer is bound, among them the supervisory authority where the trader's activity is subject to authorisation, the total price including every fee, charge and tax or the basis of its calculation, the consequences of late or missed payments, whether the price was personalised by automated decision-making, and any environmental or social objectives the service pursues. The information goes on a durable medium, must be legible, and must be provided on request in an accessible format for consumers with disabilities, including those with impaired sight. It may be layered when given electronically, except for the identity, the main characteristics, the price, the notice about other taxes and costs and the withdrawal information, and the layers must still be capable of being displayed, saved and printed as a single document. Section 27A(8) puts the burden of proving compliance on the trader.
Where the contract is concluded at the consumer's request by a means that does not allow the information to be given beforehand, a reminder of the right of withdrawal and the procedure for exercising it must be given on a durable medium between one and seven days after the contract is concluded.
What withdrawal costs. Under section 27C(1) the consumer pays only for the service actually provided, promptly, and the amount may not exceed what is proportionate to the extent of the service already supplied and may in no case amount to a penalty. Section 27C(2) is absolute for one product: no amount at all is payable for withdrawing from an insurance contract. Section 27C(3) bars the trader from claiming anything unless it can prove the consumer was duly informed of the amount payable, and bars it entirely where the trader began performing before the withdrawal period expired without the consumer having asked it to. The trader must refund the consumer within thirty calendar days of receiving the notice of withdrawal.
Dark patterns are named. Section 27E prohibits traders concluding distance financial services contracts from designing, organising or operating their online interfaces, as defined in Article 3(m) of Regulation (EU) 2022/2065, in a way that deceives or manipulates consumers or distorts or impairs their ability to make free and informed decisions, including by giving greater prominence to certain options when a decision is requested.
The right of withdrawal does not reach services whose price depends on financial market fluctuations outside the trader's control during the withdrawal period, and section 27B(2) names them: foreign exchange, money market instruments, transferable securities, units in collective investment undertakings, futures including cash-settled equivalents, forward rate agreements, interest rate, currency and equity swaps, and options to buy or sell any of those.
If a customer has asked to withdraw, or you are drafting the notice, send us the terms at office@kleanthousplatis.com, or the enquiry form. We reply within one business day.
Where the right does not arise at all
Section 27 lists the cases, and three of them decide most online arguments.
- Goods made to the consumer's specifications or clearly personalised are outside the right, under paragraph (c). So is the supply of goods liable to deteriorate or expire quickly, and of sealed goods unsuitable for return on health or hygiene grounds which were unsealed after delivery.
- Sealed computer software, sound or video recordings unsealed after delivery are outside it under paragraph (i).
- Digital content not supplied on a tangible medium is outside it under paragraph (m) only where performance began with the consumer's prior express consent and their acknowledgement that they thereby lose the right of withdrawal. A fully performed service is outside it under paragraph (a) on the same two conditions.
The last two matter more than the list suggests. Both depend on something the checkout has to collect and record at the time, and a seller relying on them without that consent and acknowledgement has neither the exception nor, if the section 17(1)(h) notice was also missing, the fourteen day limit.
Three provisions a seller should read before its terms are drafted
Section 32 deals with pre-ticked boxes. Before the consumer is bound, the trader must seek express consent to any additional payment beyond the remuneration agreed for the trader's main contractual obligation. Where the trader has not obtained express consent but inferred it by using default options that the consumer must reject in order to avoid the payment, the consumer is entitled to a refund of that payment. Insurance and extended warranties added by default at checkout are the everyday examples.
Section 31(1) deals with the helpline. Where the trader operates a telephone line for contact about contracts concluded, the consumer, when calling, is not obliged to pay more than the basic rate for the line. A premium-rate number for order enquiries is not a revenue stream; it is a breach.
Section 28(7) deals with risk in transit, which is where a seller most often assumes the buyer's problem is the buyer's. Risk passes to the consumer when they, or a third party indicated by them other than the carrier, take physical possession of the goods. It passes on delivery to the carrier only where the consumer instructed that carrier and the trader did not offer that option, and even then without prejudice to the consumer's rights against the carrier. Goods lost or damaged on the way to the buyer are, in the ordinary case, still the seller's risk.
Questions we are asked
Do I have to say why I am returning it?
No. Section 20(1) gives the right to withdraw from a distance contract without giving any reason. A seller asking for one may be gathering feedback, but it cannot make an answer a condition of the refund.
The website says returns are accepted within seven days. Is that binding?
Not against the statutory period. The right in section 20 is fourteen days, and a term purporting to shorten it does not displace the Law. A policy that offers longer than fourteen days is a commercial promise the seller can be held to, so read the two together rather than assuming the shorter one governs.
Who pays to send the goods back?
The consumer bears the direct cost of return under section 25(1), but only where the trader informed them that they would. Where the returns information is silent on it, or where the trader agreed to bear the cost, it falls on the seller. Outbound delivery is different again: under section 24(1) the standard delivery cost is refunded, and under section 24(2) any premium the consumer chose to pay for a faster method is not.
I opened the box and tried it. Have I lost the right?
No. Section 25(2) makes the consumer liable only for diminished value resulting from handling beyond what was necessary to establish the nature, characteristics and functioning of the goods, which is broadly what you could have done in a shop. And where the trader never gave the notice of the right of withdrawal required by section 5(1)(h), the consumer is not liable for diminished value in any case.
I sell digital downloads. Do I have to accept withdrawals?
Only where you did not collect the consent. Digital content not supplied on a tangible medium falls outside the right under section 27, but the exception applies where performance began with the consumer's prior express consent and their acknowledgement that they lose the right by starting. That is a checkout requirement rather than a drafting one: the record of it has to exist before the download begins.
The parcel never arrived. Whose loss is that?
In the ordinary case the seller's. Under section 28(7) risk passes to the consumer when they, or a third party they indicated other than the carrier, take physical possession of the goods. It passes earlier only where the consumer instructed the carrier and the trader did not offer that option, and even then the consumer keeps its rights against the carrier.
This article is for general information only and does not constitute legal advice. Laws and their application can change, and individual circumstances differ. For advice on your own matter, contact Klitos Platis at klitos@kleanthousplatis.com.
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