refund-page-generator

# Pages: Refund / Return Policy

Guides refund and return policy page content for SaaS, digital products, e-commerce, and services. Covers jurisdiction-specific requirements including EU withdrawal rights.

**When invoking**: On **first use**, if helpful, open with 1–2 sentences on what this skill covers and why it matters, then provide the main output. On **subsequent use** or when the user asks to skip, go directly to the main output.

## Initial Assessment

Identify:
1. **Product category**: See §Product Categories — refund logic is fundamentally different for SaaS vs digital downloads vs physical goods vs services
2. **Jurisdiction**: EU (14-day withdrawal right + mandatory withdrawal button), UK (DMCCA subscription rules), US (FTC clear-and-conspicuous), Australia (consumer guarantees), China (2026 platform rules)
3. **Refund model**: Full refund, partial/pro-rata, store credit only, no refund, or conditional
4. **Payment flow**: One-time, subscription/recurring, or tiered pricing

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## Product Categories

Refund policies differ radically by product type. Identify the category first:

| Category | Default Refund Stance | Key Considerations |
|---|---|---|
| **SaaS / Subscription** | Pro-rata or conditional | EU withdrawal button required by Jun 2026; trial periods; auto-renewal cancellation; Sky Austria case may reclassify subscriptions as "digital services" with full-period withdrawal rights |
| **Digital Downloads** | Typically non-refundable | "Once downloaded, all sales final"; exceptions for technical failure or duplicate purchase; must obtain explicit consent to waive EU withdrawal right before download |
| **Physical Goods** | 30-day return window (standard) | Return shipping costs; restocking fees; original packaging; final-sale categories |
| **Courses / Coaching** | Conditional | Pre-recorded: non-refundable once accessed; Live: partial refund before start, none after; rescheduling preferred over refunds |
| **API / Usage-Based** | Prorated or non-refundable | Pay-as-you-go typically non-refundable; subscription components may be prorated |
| **Marketplace** | Per-vendor or uniform | Who processes refunds; vendor return rates (>8% review, >15% suspend); uniform policy builds trust |
| **Free Tools** | N/A | No payment = no refund policy needed; state "free, no purchase required" if asked |

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## Jurisdiction Requirements

### EU — Consumer Rights Directive + 2026 Withdrawal Button

**14-Day Cooling-Off Period**:
- EU consumers have an unconditional 14-day right to withdraw from any distance contract (online purchase)
- Applies to goods, services, AND digital products/SaaS
- You must inform consumers of this right BEFORE purchase — failure extends the period by up to 12 months
- For goods: withdrawal period starts on delivery
- For services/digital: starts on contract conclusion

**Mandatory Withdrawal Button — Deadline June 19, 2026** (Directive EU 2023/2673):

This is the most urgent 2026 compliance item. Requirements:

- A clearly labeled digital withdrawal function (e.g., "Withdraw from contract" button) on your website/app
- **Two-step process**: (1) Withdrawal button → confirmation page → (2) "Confirm withdrawal" button
- Automated confirmation sent to consumer on a **durable medium** (email) with timestamp
- Button must be **permanently available** during the withdrawal period, prominently placed, not hidden behind logins or menus
- Applies to **any business targeting EU consumers**, regardless of where the business is registered
- Penalties: fines up to 4% of annual turnover in some member states; extended withdrawal periods until compliant

**Digital Content vs Digital Services — Sky Austria Case (CJEU, pending 2026)**:

This pending case may significantly change how SaaS refunds work:
- Advocate General opined that streaming subscriptions (and by extension, SaaS) are **"digital services"** — not "digital content"
- **Why it matters**: Digital content can waive withdrawal rights immediately upon access. Digital services only lose withdrawal rights once the service is **fully performed** — not when access begins
- **Practical impact**: If the CJEU follows this opinion, SaaS providers may not be able to extinguish withdrawal rights at first login; the right would persist for the full subscription term
- **Monitor this case** and be prepared to update refund terms

**Exceptions** (Article 16 CRD — withdrawal right does NOT apply to):
- Digital content where performance has begun AND consumer gave prior express consent AND acknowledged loss of withdrawal right (but note Sky Austria risk)
- Fully performed services with consent and acknowledgment
- Customized/personalized products
- Services for specific dates (events, hotel bookings)

**2-Year Conformity Guarantee**: Under Digital Content Directive (2019/770), consumers have a minimum 2-year guarantee for defective digital products and services.

### UK — DMCCA Subscription Rules (Spring 2027)

- Pre-contract disclosure of key subscription terms (trial price, renewal date, cancellation method)
- Two 14-day cooling-off periods (one at sign-up, one after auto-renewal of long-term contracts)
- Mandatory renewal reminders with prescribed information
- Cancellation must be "straightforward" — no unnecessary steps

### US — FTC Requirements

- No federal right of withdrawal for online purchases
- FTC requires refund policies to be "clear and conspicuous"
- Some states have specific rules: California requires posting the refund policy if not offering full refund within 7 days
- State AGs increasingly enforce against "dark patterns" that make cancellation difficult

### Australia — Consumer Guarantees (ACL)

- Consumer guarantees **cannot be excluded** by store policy
- Defective items entitled to refund, repair, or replacement regardless of what the policy says
- No fixed return window — "reasonable time" applies

### China — 2026 Platform Rules (Effective February 1, 2026)

- Platforms **cannot force merchants** to ac