Dutch consumer-facing digital services must clearly show subscription prices, duration, automatic conversion, withdrawal and cancellation throughout the sales journey. Since 25 June 2026, relevant online purchases also need an accessible online withdrawal function. Gaps can turn billed revenue into refunds, complaints and disputed debt.
Why this matters
An invoice records a claim. It cannot, on its own, show that a customer clearly accepted a subscription. Unclear terms can drain cash through refunds, payment disputes, support work and collection files. Review subscription revenue alongside cancellations, refunds, disputed invoices and customer complaints.
Example
CVmaker offered a €1.99 trial to create and download a CV. After 14 days, it became a €21.99 monthly subscription. Dozens of consumers said they expected a one-off purchase. After intervention, CVmaker clarified its website. It also agreed to stop collecting certain outstanding amounts where agreements had not been properly formed, and said it would stop charging statutory collection costs.
XTROVERSO tips
- Follow one live customer journey. Start with the advert. Continue through checkout, confirmation, invoice, withdrawal and cancellation. Test the journey on a phone without relying on staff knowledge.
- Show the full price before payment. Put the trial price, recurring price, renewal date and duration together. Include VAT and unavoidable costs. Keep optional extras separate.
- Test the route out. Make withdrawal and cancellation easy to find and use. For relevant online purchases, the withdrawal function must work without an account and send confirmation.
- Compare sales with cash records. Review subscription growth beside refunds, chargebacks, failed payments and disputed invoices. Billed revenue matters less when the cash does not stay in the business.
- Code recurring complaints. Track phrases such as “unexpected charge,” “unknown subscription” and “cannot cancel.” Repeated wording can point to a problem in the offer or checkout.
- Review collection files before pursuit. Separate ordinary late payment from invoices disputed over price, consent or contract formation. Give collection partners clear instructions for each file.
Want a practical review of your subscription journey, billing records and cancellation controls?
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- Website CVmaker voortaan duidelijk over kosten voor gebruikers na actie ACM | ACM
- Autoriteit Consument & Markt - Price transparency and recurring charges
- Autoriteit Consument & Markt - Withdrawal rights and the new online withdrawal function
- Autoriteit Consument & Markt - Cancellation friction as a supervisory concern
- Autoriteit Consument & Markt - Online influence and dark-pattern risk
- Autoriteit Consument & Markt - Consumer complaints as a supervisory signal
- Autoriteit Consument & Markt - Cancelling consumer contracts
