Provision No. 954/2025 – Comprehensive update of the regulations on distance contracting, right of repentance and cancellation of services
Department of Consumer Protection Report | Provision No. 954/2025 – Comprehensive update of the regulations on distance contracting, right of repentance and cancellation of services
On September 4, 2025, Provision No. 954/2025 of the Undersecretariat of Consumer Protection and Fair Trade (Ministry of Industry and Commerce) (the “Provision”) was published in the Official Gazette. In general terms, the Provision:
– Unifies in a single text the regulations applicable to the right of repentance and the cancellation of services contracted remotely.
– Repeals and replaces Resolutions 316/2018 (unsubscribe button) and 424/2020 (repentance button).
– It grants 60 calendar days for the adaptation of the suppliers’ websites and digital channels.
General principles
– Obligation for all suppliers of goods and services to incorporate, on the first access to the website and with high visibility:
“BOTON DE ARREPENTIMIENTO” (revocation of purchases and services).
“BOTO DE BAJA DE SERVICIO” (Termination of Continuing Services/Subscriptions).
In both cases, the provider cannot require prior registration or additional procedures.
– Confirmation to the consumer: within 24 hours the supplier must inform, by the same means, the identification code of the request and adopt the necessary measures to make it effective.
– Consumer service: information must be provided on the website, a telephone number, alternative communication channel or electronic site for the formulation of queries and/or complaints; it must be enabled during hours no less than business hours; if it is exclusively by telephone/electronic, at least 8 working hours per day, from Monday to Friday.
Special treatment for tickets for shows and tourist services
The Provision introduces a specific regime for tickets to shows, sporting or artistic events:
– Period of repentance: 10 calendar days from the delivery of the ticket or proof of payment (whichever comes first).
– Minimum prior notice: the communication of the consumer’s regret must be sent to the supplier, at least, 24 hours before the event takes place.
– Similar conditions apply to tourism services with a specific date (hotel, car rental, excursions, medium and long distance transport, “among others”).
Waivers and Limits on the Right to Repentance
The repentance button does not apply when:
– These are perishable products or products that have already been used or consumed;
– The exceptions included in Article 1116 of the CCyC apply[1], unless otherwise agreed;
– The purchase was made for resale purposes or as a productive input or for the provision of services to third parties.
Obligations eliminated by the repeal of Res. 316/2018 and 424/2020With the entry into force of the Provision, the following are null and void:
– The closed list of activities subject to the “unsubscribe button” of Res. 316/2018; The new rule applies to all suppliers that operate remotely, without distinction of industry;
– The requirement of the detailed database provided for in art. 2 of Res. 316/2018. 954/2025 only requires the communication of the application code.
[1] (a) products which are manufactured in accordance with specifications supplied by the consumer or which are clearly personalised or which, by their nature, cannot be returned or may deteriorate rapidly; (b) the supply of sound or video recordings, discs and computer programs that have been decoded by the consumer, as well as computer files, supplied electronically, capable of being downloaded or reproduced immediately for permanent use; c) Those for the supply of daily newspapers, periodicals and magazines.