Regulation No. 945/2025 issued by the Undersecretariat of Consumer Protection and Fair Trade, published in the Official Gazette on September 4, 2025, repealed Resolutions Nos. 316/2018 and 424/2020, which governed the procedures for requesting service cancellation and exercising the right of withdrawal in remote contracts, respectively.
Below is an analysis of the new regulation governing the Service Cancellation Button and the Withdrawal Button, as well as their differences from the repealed framework.
1. Withdrawal Button
The regulation concerning the Withdrawal Button is similar to that established under Resolution SCI No. 424/2020, which has now been replaced by the present Regulation.
Under the new Regulation, suppliers offering goods or services remotely—through websites or similar digital formats—must display, in a visible and prominent location and upon first access, a link titled “WITHDRAWAL BUTTON”, through which consumers may request to revoke their acceptance of the purchased product or contracted service, in accordance with Articles 34 of Law No. 24,240 (and its amendments) and 1,110 of the National Civil and Commercial Code.
Suppliers may not require prior registration or any additional procedure from consumers, and within twenty-four (24) hours of receiving a withdrawal request, must provide the consumer with an identification or registration code corresponding to the request and take the necessary actions to process the revocation.
A distinctive feature of the new Regulation is that it specifically governs the exercise of the right of withdrawal for certain types of goods and services.
In the case of tickets for shows, sports, or artistic events, the ten (10) calendar-day period to exercise the right of withdrawal begins on the date the tickets or payment receipt are delivered to the consumer, whichever occurs first, regardless of the event date.
To exercise the right of withdrawal within this ten-day period, the consumer must notify the supplier at least twenty-four (24) hours prior to the scheduled date of the show or event.
The same timeframes apply to tourism-related contracts with specific dates, such as hotel stays or property rentals, car rentals, excursions, or medium- and long-distance transportation services, among others.
Accordingly, in the case of event tickets or tourism services, the consumer may exercise the right of withdrawal provided it is done within ten (10) days of receiving the payment receipt or ticket/voucher—whichever occurs first—and not less than twenty-four (24) hours before the event or service date.
If the withdrawal occurs within the ten-day period but less than twenty-four hours before the event, or more than twenty-four hours before but after the ten-day period has expired, the withdrawal shall not be effective.
The right of withdrawal shall not apply in the following cases:
a) As provided in Article 1,116 of the National Civil and Commercial Code, unless otherwise agreed. (This includes products made according to consumer specifications or clearly personalized; products that, by their nature, cannot be returned or may deteriorate quickly; audio or video recordings, disks, or software unsealed by the consumer; and digital files supplied electronically that can be downloaded or reproduced immediately for permanent use; as well as newspapers, periodicals, and magazines.)
b) When the consumer has actually used or consumed the purchased product or service and subsequently seeks to exercise the right of withdrawal within the period established in Article 34 of Law No. 24,240 and its amendments.
c) When the consumer, whether an individual or legal entity, seeks to exercise the right of withdrawal regarding products or services acquired for resale and/or intended to be integrated into production, transformation, marketing, or service provision processes, as provided under Article 2 of Decree No. 1,798 dated October 13, 1994.
d) When the products purchased are perishable goods.
It should be noted that, in our opinion, the inclusion of item (c) is unnecessary, as the purchaser of goods intended for production or resale does not qualify as a consumer and is therefore not protected by the right of withdrawal.
2. Service Cancellation
Article 4 of Regulation No. 945/2025 provides that suppliers offering goods and services remotely—through websites and/or digital marketing channels or similar formats—must display, in a visible and prominent location and upon first access, a link titled “SERVICE CANCELLATION BUTTON”, through which the consumer may request cancellation of the contracted service, in accordance with Article 10 ter of Law No. 24,240 and its amendments.
When using the Service Cancellation Button, the supplier may not require prior registration or any additional procedure, and within twenty-four (24) hours of receiving the cancellation request, must provide an identification or registration code corresponding to the request and take the necessary measures to process the cancellation.
The new Regulation sets parameters similar to those established in the repealed Resolution SCI No. 316/2018 but now applies to all companies providing remote services.
The prior Resolution only applied to companies within the sectors listed in its Annex, which was gradually expanded over time.
Moreover, while the repealed Resolution required the inclusion of a link, the new Regulation mandates the inclusion of a button with a specific designation.
For this reason, exclusively for the purpose of adapting websites and digital channels to include the Service Cancellation Button, the Regulation grants a sixty (60) calendar-day compliance period from the date of publication in the Official Gazette.
3. Consumer Service
The Regulation further establishes that companies supplying goods and services and providing customer service—whether by telephone or electronic means—must offer customer service hours that are no less than their regular business hours.
Where customer service is provided exclusively by telephone and/or electronic means, the service hours must be no less than eight (8) hours per business day, Monday through Friday.
Suppliers must publish on their websites the telephone number, alternative communication channel, or online portal for submitting inquiries and/or complaints, clearly indicating the department responsible for customer service.