This guide is operational guidance only, not legal advice. Confirm your specific compliance obligations with your own legal counsel before making changes.
You need an active Cancel Flow published in your Skio Dashboard. If you haven't set one up yet, complete that first.
This guide explains how to configure your Skio Cancel Flow to support EU "right of withdrawal" requirements introduced by Article 11a of the EU Consumer Rights Directive (Directive (EU) 2023/2673), which takes effect on June 19th, 2026.
What Article 11a requires
From June 19th, 2026, if you sell subscriptions to consumers in the EU, you must give them a clear, labeled way to withdraw from their contract directly from your online interface — without obstacles. In practice, your Cancel Flow needs to:
Offer a clear path for a customer who wants to exercise their right of withdrawal.
Let that customer reach cancellation without being forced through retention offers first.
Present the relevant withdrawal information during the process.
Keep a record of withdrawal requests you can export for your files.
All of this can be configured inside Skio's Cancel Flow editor using the steps below.
Step 1: Add a "right of withdrawal" cancellation reason to your Cancel Flow
In the left-hand menu of your Skio Dashboard, go to Retain > Cancel Flow and open your active flow in the editor.
On the canvas, add a new Cancellation Reason node. You can drag it in from the node panel or branch it off your start node.
Enter the reason text:
Withdraw from contract here.Make sure the node is enabled.
The cancellation reason node connected directly to a treatment with no offer.
Place this reason near the top of your reason list so EU customers can find it immediately.
Step 2: Attach a treatment with no offer
This is the key compliance step. The customer who selects the withdrawal reason should see information only — no discount, swap, pause, or other retention offer — before being able to cancel.
From the Cancellation Reason node, add a new Treatment node.
In the Action selection dropdown, choose No action. Do not add a discount, swap, pause, upsell, or credit offer.
In the Treatment copy field, add your withdrawal information text. Have your legal team review the copy before publishing.
Connect the treatment directly to the cancel step so the customer can complete cancellation without any further detour, then click Save.
The result is a two-step path: the customer selects the withdrawal reason, sees the withdrawal information with no offer, and confirms cancellation.
Step 3: Localize the reason and treatment copy
Article 11a applies to EU consumers, so the withdrawal path should appear in your customers' language. The Cancel Flow editor stores per-locale copy on each node.
In the Cancel Flow editor, open the locale selector at the top of the canvas and click Update locale(s).
Add the locale(s) for your EU markets. German (
de) is built in; many others are available (e.g.fr,it,es,nl,pl), and you can add custom locales if needed.Switch the editor to the new locale using the locale selector.
With that locale selected, translate the reason text on the Cancellation Reason node and the information text on the Treatment node. The default (English) wording stays intact.
Update the cancel button and label copy per locale the same way — for example,
Jetzt widerrufenin German.
Use the locale selector to add EU locales and switch between them when translating node copy.
Repeat for each EU language you support. Customers are shown the copy that matches their locale automatically.
Step 4: Export withdrawal data for your records
Skio records a session for every Cancel Flow interaction, including the reason selected and the outcome. To export it:
In the left-hand menu of your Skio Dashboard, go to Analytics > Cancel Flow dashboard. Set the date range filter accordingly.
In the top right corner, click on Export > Choose specific metrics > Cancel reason breakdown to get a CSV of relevant subscriptions.
After exporting: validate eligibility and process refunds
Skio records a session for every customer who selects the withdrawal reason, but it doesn't automatically validate whether each withdrawal request is eligible under the directive or process any refunds. After pulling your export, you'll need to:
Review each withdrawal request and confirm the customer is within the applicable withdrawal period for your market.
Process any refunds due under the right of withdrawal, in line with the requirements for your EU markets.
Your legal team can confirm the eligibility rules and refund timelines that apply to the markets you sell in.
Checklist
"Right of withdrawal" Cancellation Reason node added and enabled in your Cancel Flow.
Treatment set to No action, with withdrawal information text, connected directly to the cancel step.
Reason text, information text, and cancel button copy localized for each EU language.
Cancel Flow CSV export tested, with a recurring schedule to retain the records.
(Optional) Cancellation confirmation email Journey live.
FAQ
Does this only apply to customers in Germany?
Article 11a applies broadly to EU consumers. Germany's national rules apply first where they differ, but the withdrawal path should be available to any customer in an EU market you sell into. Work with your legal counsel to confirm which markets and languages you need to cover.
Can I add extra locales myself, or do I need to contact Skio support?
Many common locales (including de, fr, it, es, nl, pl) are available directly in the cancel flow editor's locale selector. EU region targeting for the Cancel compliance global setting is not yet self-serve — contact your Skio account contact to get that configured.
How often should I export the withdrawal session data?
Pull the export on whatever cadence your compliance process requires. A monthly export is a reasonable baseline, but check with your legal team if your markets have specific record-keeping requirements.