Bought an app that doesn't work? A game that crashes constantly? A subscription you were tricked into? If you're in the EU (or EEA), you have significantly stronger refund rights than consumers in most other regions — and platforms like Apple, Google, and Steam are legally required to honor them.
EU digital consumer protection goes far beyond the platform's own refund policies. This guide explains your legal rights and exactly how to claim refunds that platforms might initially refuse.
Your EU Digital Consumer Rights (Overview)
Three key EU laws protect digital purchases:
1. Consumer Rights Directive (2011/83/EU)
- 14-day cooling-off period for online purchases
- For digital content: right can be waived IF the seller explicitly informed you and got your consent before download began
- If the waiver process was unclear or missing, the 14-day right remains intact
2. Digital Content Directive (2019/770)
- Digital content must conform to the contract (work as described)
- 2-year conformity guarantee for digital goods
- If content is defective, you have the right to: repair, replacement, price reduction, or full refund
- Burden of proof on the seller for the first year
3. Consumer Rights Directive Updates (Omnibus Directive 2019/2161)
- Stricter rules on fake reviews and personalized pricing
- Clearer information requirements for digital marketplaces
- Right to know if you're dealing with a trader or individual
Platform-Specific Refund Strategies
Google Play Store
Standard policy: 48-hour refund window for apps, 15 minutes for in-app auto-refund
EU legal rights beyond policy:
- If the app doesn't function as described → refund under Digital Content Directive regardless of time
- If consent to waive 14-day right wasn't clear → 14-day cooling-off applies
- Unauthorized purchases (especially by minors) → refund under unfair terms
How to claim:
- Try Google Play's standard refund: play.google.com/store/account/orderhistory
- If refused, reply stating EU Consumer Rights Directive and Digital Content Directive
- Escalate to Google's EU-specific support
- File with your national consumer authority if still refused
Apple App Store
Standard policy: Report a Problem within 14 days, case-by-case review
EU legal rights beyond policy:
- Same Digital Content Directive protections apply
- Apple as platform bears responsibility for consumer rights compliance
- The EU Digital Markets Act adds additional platform obligations
How to claim:
- Go to reportaproblem.apple.com
- Select the purchase and reason for refund
- If refused, email Apple's EU support citing Directive 2019/770
- Reference Ireland (Apple's EU entity) consumer protection law
- File with Competition and Consumer Protection Commission (CCPC) Ireland
Steam
Standard policy: Under 2 hours playtime AND within 14 days of purchase → automatic refund
EU legal rights beyond policy:
- Games that are broken, crash repeatedly, or don't match advertised requirements → Digital Content Directive
- Pre-orders: full 14-day cooling-off applies until download begins
- Early Access games must still meet minimum quality standards
How to claim:
- Steam support > Purchases > select game > "I'd like a refund"
- If outside standard window, cite Digital Content Directive non-conformity
- Provide evidence (crash logs, screenshots of issues vs. advertised features)
- Escalate to your national consumer authority if refused
Subscription Services (Netflix, Spotify, etc.)
- Monthly subscriptions can be canceled at any time
- Annual subscriptions: if service quality significantly degrades, claim partial refund under conformity rules
- Free trials converting to paid: company must clearly notify before charging
How to Write an EU Refund Claim
When the platform's standard refund process fails, send this:
Subject: Refund Request Under EU Consumer Rights — Order [ID]
I am requesting a refund for [purchase] made on [date] for [amount].
Under Directive 2019/770 (Digital Content Directive), digital content must conform to the contract. This purchase fails to conform because: [specific issue — crashes, missing features, doesn't match description].
As an EU consumer, I am exercising my right to a refund due to non-conformity of the digital content. Under Article 14 of the Directive, I am entitled to a full refund when the trader has failed to bring the content into conformity within a reasonable time.
Please process this refund within 14 days as required by law.
Unauthorized Purchases by Children
This is a common and strong claim in the EU:
- Under EU contract law, minors cannot enter valid contracts without parental consent
- In-app purchases made by children without parental authorization are voidable
- Platforms have a duty to implement adequate age verification and parental controls
- Request a full refund citing: unauthorized purchase by a minor, lack of adequate consent mechanisms
Where to Escalate
| Country | Authority |
|---|---|
| Ireland (Apple) | CCPC — ccpc.ie |
| Netherlands (Google) | ACM — acm.nl |
| Luxembourg (Steam) | ULC — ulc.lu |
| France | DGCCRF |
| Germany | Verbraucherzentrale |
| UK (post-Brexit) | CMA — gov.uk/cma |
| EU-wide | European Consumer Centre (ECC-Net) |
EU Online Dispute Resolution: ec.europa.eu/consumers/odr — free platform for resolving cross-border disputes
Quick Checklist
- [ ] Identified the specific EU directive that supports your claim
- [ ] Tried the platform's standard refund process first
- [ ] Documented the issue (screenshots, crash reports, comparison to advertised features)
- [ ] Sent a written claim citing specific EU directives
- [ ] Set 14-day deadline for response
- [ ] Filed with national consumer authority if refused
- [ ] Used EU ODR platform for cross-border disputes
Bottom Line
EU consumers have some of the strongest digital purchase protections in the world. Platform refund policies are the minimum — not the maximum — of what you're entitled to. When standard refund requests fail, citing specific EU directives (particularly the Digital Content Directive 2019/770) elevates your claim from a customer service request to a legal obligation the platform must honor.
Sources
- EU Digital Content Directive (2019/770): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0770
- EU Consumer Rights Directive: https://commission.europa.eu/law/law-topic/consumer-protection-law/consumer-contract-law/consumer-rights-directive_en
- EU Online Dispute Resolution: https://ec.europa.eu/consumers/odr
