Order Button Rules for Irish Webshops (CRA 2022 s.108)

Your checkout button probably says "Place Order" or "Buy Now." Under Irish law that is not good enough. Section 108(5) of the Consumer Rights Act 2022 says the button must be labelled either with the exact words "order with obligation to pay" or with an equivalent unambiguous phrase. Get the wording wrong and section 108(6) is unambiguous about the consequence: the consumer is not bound by the contract.

You can run a free compliance scan on your checkout to see whether your current button text passes.

What the Irish statute actually says

Section 108 of the Consumer Rights Act 2022 (Act 37 of 2022) carries the title "Additional information requirements for distance contract concluded by electronic means." The button rule sits at subsection 5:

Where placing an order entails activating a button or a similar function, the trader shall ensure that the button or similar function is labelled in an easily legible manner only with the words "order with obligation to pay" or a corresponding unambiguous formulation indicating that placing the order entails an obligation to pay the trader.

And subsection 6 closes the loop:

If the trader fails to comply with subsection (4) or (5), the consumer is not bound by the contract or order.

That is the substantive risk. A non-compliant button does not just earn you a regulator warning. It turns every order placed through it into a contract the customer can walk away from.

The CRA 2022 transposed the EU Consumer Rights Directive (2011/83/EU) into Irish primary legislation, replacing the older European Union (Consumer Information, Cancellation and Other Rights) Regulations 2013 (S.I. No. 484 of 2013) for in-scope distance contracts. The button rule was already in the 2013 SI at Regulation 13, but the CRA 2022 is now the controlling statute and the CCPC's guidance is written against it.

What button text is safe in Ireland

The literal phrase from section 108(5) is the gold standard. Any close variant that names both the act of ordering and the obligation to pay is also fine. Vague labels that talk about "submitting," "continuing" or "confirming" are not.

The Irish CCPC has not yet published case-by-case rulings on individual phrases the way German courts have for §312j BGB. Until it does, the safe pattern is to make the word "pay" appear on the button itself, ideally with the total.

What happens if your button text is wrong

This is the most important section. The risk is not primarily a fine.

The contract is not binding. Section 108(6) gives the consumer a clean exit from any order placed through a non-compliant button. The customer can decide, even after delivery, that they are not bound. They can return the goods and demand a refund and you have no contract to point at.

Chargebacks become very hard to defend. When a card-scheme chargeback arrives and the customer claims they never agreed to pay, your defence rests on showing they did agree. A button labelled "Continue" is a weak document.

The CCPC can take enforcement action. Beyond the private-law unwinding under s.108(6), the Competition and Consumer Protection Commission can investigate breaches of the CRA 2022 and the Consumer Protection Act 2007. The CRA 2022 carries summary and indictable offence routes. Class A fines (up to €5,000 per offence under the Fines Act 2010) apply on summary conviction, and the indictable route allows materially higher penalties.

Stacked unfair-trading exposure. A misleading checkout can also be challenged as a misleading commercial practice under sections 43-46 of the Consumer Protection Act 2007. The CCPC routinely combines both heads in enforcement letters.

What popular platforms ship by default

Here is the problem. Most e-commerce platforms do not ship with CRA-compliant button text by default.

The takeaway: never trust the platform default. Always check what your customers actually see on the final checkout page in production.

How to fix your button text

The fix is straightforward. You change the text on the final order button.

Shopify

1. Go to Settings > Languages in your Shopify admin.
2. Click your store language.
3. Search for "Place order" (or the localised equivalent).
4. Replace it with compliant text such as "Order with obligation to pay" or "Buy and pay."
5. Save and verify the change on a live test checkout.

WooCommerce

Add this to your theme's functions.php or a custom plugin.

add_filter('woocommerce_order_button_text', function() {
    return 'Buy and pay';
});

If you run a multi-language Irish shop with WPML or Polylang, set the translation for each language separately.

Squarespace, Wix, Big Cartel

Look for "checkout button" or "order button label" in the editor settings. If the platform does not let you change the button text at all, that is a serious limitation and you should raise it with their support team.

Any custom build

The label needs to live on the actual submit button, not in adjacent helper text. CJEU and German BGH case law on the equivalent provision is consistent that small print near a button does not cure a non-compliant label. Ireland has not had to litigate this yet, but the statutory text in s.108(5) is "the button or similar function is labelled," which puts the obligation on the button itself.

Don't forget the rest of your checkout page

Button text is one piece of a CRA-compliant checkout. Your checkout page also needs:

• Your trading-name and business identity per the trading disclosure rules for Irish business websites, including your CRO number where applicable.
• Clear total pricing including VAT and shipping costs, shown before the final button.
• A link to your terms and conditions that the customer can read before ordering.
• Your cancellation and return policy, including the 14-day right of withdrawal and from 19 June 2026 a working withdrawal button on subscription confirmations.
• Compliant discount pricing labels under the 30-day prior price rule if any line on your basket carries a "was/now" claim.

Check your checkout right now

The fastest way to find out if your checkout button is CRA-compliant is to test it. Open your webshop in a private browser window, add something to your cart and go to checkout. Read the button. Does it tell you, in words, that clicking it commits you to pay? If you are not sure, it almost certainly does not.

You can also run a free scan on your website to catch this and other Irish e-commerce compliance issues.

Frequently asked questions

Can I just add "with payment obligation" in small text near the button instead of changing the button itself?

No. Section 108(5) says the button "is labelled in an easily legible manner only with the words..." which puts the obligation on the button itself. Adding helper text alongside does not cure a non-compliant label and the CCPC will treat a "Continue" button with adjacent disclaimer text the same way it treats a "Continue" button alone.

Does this apply to B2B sales too?

The CRA 2022 applies to business-to-consumer (B2C) contracts. If you sell exclusively to other businesses (your terms restrict orders to "in the course of a business or trade") the s.108 button rule does not bite. But mixed B2B / B2C shops cannot reliably tell the two apart at the button-press moment, so the safe play is to use compliant wording for all orders.

What about subscription services and recurring payments?

Section 108(5) attaches to the moment the consumer commits to pay. For a new subscription, that is the initial sign-up. The button must indicate the payment obligation. "Start paid subscription" or "Subscribe and pay €X / month" is good practice. Separately, from 19 June 2026 Ireland's withdrawal-button rule for subscription confirmations requires a visible withdrawal action on the confirmation page itself.

My shop is in English but I sell to Irish and German customers. Which rules apply?

The rules of the customer's country apply, not your shop's language. An Irish consumer buying from your English-language webshop gets the protection of CRA 2022 s.108. A German consumer buying the same way gets §312j BGB. The safe baseline that satisfies both is "Buy and pay" or "Order with obligation to pay" in English, plus localised compliant strings for German and other languages where you have an in-language checkout.

Will my payment provider or platform warn me about this?

Almost never. Payment providers like Stripe, Mollie and Adyen process payments but do not check your checkout page for legal compliance. Platforms like Shopify and WooCommerce hand you the tools and leave legal compliance to you. As the trader, the responsibility is yours.

Has the CCPC actually enforced this against an Irish webshop?

Public CCPC enforcement on s.108 button-wording alone is thin so far. Most CRA enforcement to date has focused on the price-reduction rule and on misleading commercial practices. That does not change the contract-validity risk under s.108(6), which any customer or chargeback team can invoke without waiting for the CCPC. A non-compliant button is a private-law liability before it is a regulatory one.