There’s a lot of thought behind the journey that leads a customer to buy: how we introduce a product, explain its value and make the next step feel easy. But I’ve been wondering whether we give the same attention to what happens when someone wants to reconsider, cancel or ask for help. That question came to mind while reading the European Commission’s Digital Fairness Act proposal, presented on 11 November. It would replace the Unfair Commercial Practices Directive with a regulation covering business-to-consumer commercial practices online and offline. Several of its provisions concern moments that may belong to different teams inside a business, but form one continuous experience for the customer.

What the proposal would change

The proposed Digital Fairness Act would introduce more explicit rules for digital interfaces and contracts. These include a prohibition on interfaces likely to deceive, manipulate or materially distort consumers’ economic behavior. For free trials, the text would require a reminder and express agreement before moving to a paid contract. It also provides for reminders before specified automatic subscription extensions and an accessible online contract termination function.

Customer assistance is part of the proposal too. Where a trader offers online service after a contract is concluded, customers would be able to request human assistance when other means are ineffective.

These provisions remain subject to negotiation. They nevertheless show how the discussion reaches beyond the initial purchase to the customer’s continuing relationship with a business.

Where persuasion becomes a question of fairness

Ecommerce websites are designed to help people make decisions. Product recommendations, availability messages and reminders can all provide useful information. The question is what customers understand from them and whether that understanding reflects the actual offer.

Consider a message saying that only two items remain in stock. Does it refer to the selected size, the entire product range or stock available for delivery to that country? A short message can create a strong impression without making its meaning clear. This is an illustration, rather than a finding about a particular retailer. It also raises an existing legal issue: EU consumer law already prohibits false claims of very limited availability used to deprive customers of time to make an informed choice. The distinction matters and businesses should not read the proposal as suggesting that misleading urgency is acceptable until new legislation arrives.

For teams responsible for customer communication, the practical question starts before the wording. What information supports the message? Who maintains it? And will a customer interpret it in the way the business intends?

What happens after the customer says yes?

Subscriptions bring another part of the relationship into view. A customer may understand the introductory offer but be less certain about what happens afterwards. When does the trial end? What will the next payment be? How can they stop the service?

The proposal’s provisions on trials, renewals and termination address these transitions. From a customer-experience perspective, they are also moments when information needs to move with the customer. Imagine a subscription promoted as flexible. The purchase page explains how easily someone can join, but the account area leaves them unsure whether cancelling stops the next payment or only pauses a delivery. The original promise may have been clear, yet the experience of acting on it is not.

There is an important distinction here between ending an ongoing subscription and exercising a statutory withdrawal right. An online withdrawal function has already been required under applicable consumer-rights rules since 19 June 2026. The proposed termination provisions concern a different action. Customers should be able to understand which process they are using and what it will do.

When the first answer does not help

The proposed access to human assistance raises a similarly practical question. Automated support can be useful when a customer needs a straightforward answer. But what happens when the answer does not fit the problem? Perhaps an order is marked as delivered but has not arrived, or a cancellation confirmation does not match the next charge. In those situations, the route beyond the first response becomes part of the service.

The proposal would provide for human assistance on request under specified conditions. For businesses reviewing their support experience, a useful exercise is to follow an unresolved enquiry. Can the customer explain what remains wrong? Does the next person receive the information already supplied? Is it clear what happens next? These are editorial review questions, not additional requirements attributed to the proposal. They help connect the policy discussion with the experience a customer actually encounters.

What this means for ecommerce businesses

The final rules and timetable are still unsettled. For now, businesses need to keep existing obligations separate from proposed changes. However, the proposal gives teams a reason to look at the journey as a whole. A product page, account setting, confirmation email and support response may each be accurate on their own while leaving the customer uncertain about how they fit together.

For businesses operating across several markets, that review also involves language and local conditions. A localized label should preserve the difference between pausing a delivery and ending a renewal. Help content should describe the same outcome as the account interface. Support teams need to know what customers were told.

A useful starting point is to follow a few ordinary tasks: understand an offer, identify a recurring payment, end a subscription and ask for help when something goes wrong. Where does the customer need to guess? Where does one touchpoint create an expectation that another fails to explain? The Digital Fairness Act is still a proposal. But the question it brings into focus is already relevant: can customers understand and act on the choices a business gives them throughout the relationship?

Sources

• European Commission, Digital Fairness Act proposal and document collection, 11 November 2026.
• European Commission, Proposal COM(2026) 1100 final, 11 November 2026.
• European Commission, Commission strengthens consumer protection laws, making them fit for the digital age, 11 November 2026.
• EUR-Lex, Unfair Commercial Practices Directive, 11 May 2005, particularly Annex I, point 7.
• European Consumer Centre Finland, Requirement for online stores to offer a statutory withdrawal function in June 2026, 2026.

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Written by Iusti Ikert, Founder of In Between the Lines — a messaging and customer experience alignment studio for scaling product-led brands. I work with growing DTC companies to align brand promise, marketing, and operational delivery so they can scale without friction.

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