The EU Commission will finally discontinue the online dispute resolution platform (ODR platform) on July 20, 2025. Originally intended as a central online portal for consumer complaints, the platform remained largely unused in practice. This also means that the legal obligation to provide information no longer applies.
For companies with online offers, this means that existing references to the platform – for example in the legal notice, in the terms and conditions or in automated emails – should be removed. Incorrect or misleading information may be subject to a warning.
The changeover offers a good opportunity to bring the entire online presence up to date and to check it legally.
Need for action – specific points for review and adjustment
The legal obligation to refer to the ODR platform ceases to apply when it is deactivated. This means that all direct or indirect references to the platform should be completely removed – in all areas in which they have become established. This includes
- Legal notice
The legal notice of many company websites now contains a link to the ODR platform as standard. This will not only become obsolete from mid-2025, but can also be misleading under competition law as a misrepresentation of existing arbitration offers – an avoidable risk of a warning. - General Terms and Conditions (GTC)
Formulations such as “The EU ODR platform is available to you for out-of-court dispute resolution” will be incorrect in future. The GTC should be checked for outdated provisions and amended accordingly. - Cancellation policy and consumer information
Even if the ODR platform does not have to be mentioned in the cancellation policy, many legal texts contain corresponding references. These should be deleted if necessary. In any case, mandatory information in withdrawal instructions is constantly changing. Incorrect information is liable to a warning. The withdrawal policy should therefore be updated at least once a year. - Data protection declaration
In individual cases, the ODR platform also appears in data protection declarations as information on data processing in connection with complaints. Here, too, there may be a need for adaptation; in any case, data protection declarations are often incomplete. - Email signatures, invoice templates and customer communication
Standard forms and automatically generated communication should also be checked – for example, whether a link to the platform is also included in the email footer. Otherwise, legally required information must be included in the email signature.
Additional need for action: Declarations to cease and desist
Companies that have received warnings in the past due to incorrect or missing OS notices and have subsequently issued a cease-and-desist declaration must check the status of this obligation. Even if the legal obligation no longer applies, the declaration remains effective as a contractual obligation – unless it is formally terminated or amended. Legal assistance is urgently recommended here, as the actually lawful waiver of the platform notice may constitute a breach of a previous contractual obligation and thus a contractual penalty.
Opportunity for comprehensive website compliance
The removal of references to the ODR platform can be a good reason to legally review your own online presence. In addition to removing outdated mandatory information, companies should take the opportunity to check their legal texts for up-to-dateness, consistency and conformity with the current legal situation – in particular:
- Completeness and legally compliant design of the imprint
- GDPR-compliant privacy policy, including the use of cookies, tracking services and third-party tools
- General terms and conditions with industry-specific regulations (e.g. shipping, payment, warranty)
- Mandatory information for digital products
- Accessibility (see: Need for adaptation of websites – The Accessibility Reinforcement Act)
Conclusion
The deactivation of the ODR platform is initially only a legal formality. However, website operators are forced to make adjustments. This should be accompanied by further measures to make website content and legal texts legally compliant. Those who act early protect themselves from legal risks and at the same time document their own diligence in dealing with regulatory requirements.
