In short. When a European customer exercises their right of withdrawal, the money goes back to the same means of payment they used, unless they expressly agree to another one and it costs them nothing: store credit is offered, never imposed. And if you go past the 14 days, Spain and Portugal let the customer claim twice the amount, and France increases it progressively, up to the price of the product.
The refund or store credit question moves more money than anything else in the returns process, and it is also the one most shops get wrong. The temptation is obvious: a voucher keeps the amount in the house, a refund sends it out. The problem is that, in the European Union, that decision is not the shop's to make. It is the customer's —and only when you put it to them properly—. In this guide we explain exactly what they can demand, what counts as «express agreement» and what does not, how to audit your flow with a parity test, and how much getting it wrong costs in each country. It is a satellite of our definitive guide to returns in Shopify.
Can a shop give store credit instead of the money back?
On a withdrawal, not by default. Article 13(1) of Directive 2011/83/EU requires you to reimburse all payments received «using the same means of payment as the consumer used for the initial transaction», with two cumulative conditions for stepping outside that rule: that the consumer expressly agrees to another means and that they incur no fees as a result. Each Member State has transposed it into its own consumer law, so check the national text for the markets you sell to.
The nuance is worth getting right, because it is not exactly that «a voucher is another means of payment». Store credit is not money: it is a promise of future consumption in your shop. That is why the German courts have treated it as a breach of the duty to reimburse, not as an alternative payment method. It only works if the customer accepts it instead of the money, knowing what they are giving up.
And there is a second front, a newer one. From 19 June 2026, Directive (EU) 2023/2673 requires stores that direct their activity at EU consumers to offer a clearly identified withdrawal function for the contracts where that right exists. If that button leads into a flow where the voucher is one click away and the money four, you do not just have an Article 13 problem: you have exactly the dark pattern that directive is designed to stop. We unpack the difference between the two worlds in withdrawal, return and exchange: why they are not the same.
What counts as «express agreement» and what does not?
An express agreement is a specific choice by the customer, made after they know they are entitled to the money. It is not a clause, not a default value, and not the outcome of a funnel.
The clearest reference was set by the Landgericht Bochum in its judgment I-13 O 72/25 of 15 October 2025: a shop had given a customer a voucher valid for one year after a withdrawal. The court recalled that § 357(3) BGB —the German transposition of Article 13(1)— requires the same means of payment to be used, and ruled that a clause in the general terms and conditions is not enough as an express agreement. The law asks for an agreement between the parties, and terms and conditions nobody negotiates are not one.
Italy closes it from the other end: Article 56 of the Codice del Consumo declares null and void any clause providing for limitations on the reimbursement of the sums paid as a consequence of exercising the right of withdrawal. In other words: not only does the clause fail as an agreement, it simply does not exist.
Translated into your returns flow:
| How you get the «yes» to the voucher | Is it express agreement? | Why |
|---|---|---|
| Clause in the terms and conditions or in your web policy | ❌ No | The customer has not chosen anything (LG Bochum I-13 O 72/25) |
| Pre-ticked box on the returns form | ❌ No | Silence is not consent |
| Default option applied if the customer touches nothing | ❌ No | It is an imposition dressed up as a choice |
| Voucher issued with a «if it does not suit you, write to us» | ❌ No | It reverses the burden: they have to claim what is already theirs |
| Two equivalent buttons, «Refund» and «Store credit», their call | ✅ Yes | A real, informed choice |
| Email setting out both options, and they reply choosing | ✅ Yes | A real choice, with a written trail |
Rule of thumb: if you cannot show when and how the customer chose, you do not have an express agreement. And the proof is on you.
The parity test: seven questions to audit your flow
Parity of access is the operational criterion that makes offering store credit defensible. It is not a safe harbour —Article 13(1) still requires express agreement at no cost, and the rest of consumer law still applies— but without it there is no conversation to be had. Open your shop's returns flow and answer these:
- Are both options visible at once, on the same screen? If the refund sits behind «other options», no.
- Do they carry the same visual weight? Same button size, same contrast. A voucher in your brand colour and a refund in light grey is an answer.
- Do they cost the same number of clicks? Count the steps on each path. If the money takes one more, you have already created friction.
- Are there questions or confirmations that only appear if they choose money? Asymmetric «are you sure?» prompts are the sector's most common dark pattern.
- Is the bonus and its expiry explained before the choice? Explaining afterwards is not informing: it is justifying.
- Can they change their mind if you have not issued the credit yet? A reasonable change of heart should not cost a phone call.
- Is it recorded what they chose and when? Without a record you cannot prove the express agreement.
If you fail even one, fix it before reading on. The seven together are not a literal requirement of the directive: they are the practical way to show that the customer's «yes» was really theirs.
When can you settle with store credit and when can you not?
Not every return is a withdrawal, and that is where almost all of your room to manoeuvre sits. Here is the reading, scenario by scenario:
| Scenario | Voucher, no questions asked? | What governs it |
|---|---|---|
| Withdrawal within the 14 legal days | ❌ No | Money to the same means of payment, unless expressly agreed (Art. 13(1)) |
| Commercial return beyond the legal period, if you offer it | ✅ Yes | It is your policy: you may limit the resolution to credit, saying so beforehand |
| Exchange for another product | ✅ Yes | Credit is the natural vehicle for the price difference |
| Faulty product (legal guarantee) | ❌ No | Directive (EU) 2019/771: repair or replacement and, where appropriate, the price returned |
| Order you cancel yourself (out of stock, not delivered) | ❌ No | There is no return: there is a payment with nothing given in exchange |
| Customer who paid with credit or a gift card | ✅ Yes | That was their initial means of payment; returning it to the same balance is consistent |
The second row is the one almost nobody uses well. Your commercial returns policy —the one that goes beyond the 14 legal days— can indeed pay in store credit, because it is a right you grant and whose conditions you set, provided you announce them before the purchase and apply them equally to everyone. That is where store credit with a bonus belongs, not inside the legal flow. We cover it in Shopify store credit.
What does refunding late (or refunding in credit) cost you?
Here is the point almost no guide makes: an imposed voucher is not «a worse refund», it is a refund that has not happened. And the 14-day clock keeps running, with no cover from the Article 13(3) withholding right: that lever is there to wait for the goods, not to pay in store credit. These are the consequences of delay in the five frameworks we get asked about most:
| Country | What happens if you do not refund on time | Rule |
|---|---|---|
| Spain | The consumer can claim twice the amount, plus any damages exceeding that sum. The burden of proof that the deadline was met falls on the trader | Art. 76 TRLGDCU |
| Portugal | Duty to return double within 15 working days, without prejudice to compensation for damages | Art. 12(6) Decreto-Lei n.º 24/2014 |
| France | Progressive surcharge: statutory interest up to 10 days late, 5% between 10 and 20, 10% between 20 and 30, 20% between 30 and 60, 50% between 60 and 90, and 5 more points per additional month up to the price of the product | Art. L242-4 Code de la consommation |
| Germany | Default interest under the general rules (§§ 286 and 288 BGB) and, in practice, cease-and-desist demands from competitors or associations | §§ 286 and 288 BGB · LG Bochum I-13 O 72/25 |
| Italy | Null and void any clause limiting the reimbursement; the practice can be pursued as an unfair one before the AGCM | Art. 56 Codice del Consumo |
Two practical readings of that table. First: the cost of delay is not the order amount, it is a multiple of it. Second: in Spain the proof that you refunded on time has to come from you, so a time-stamped record of every request stops being a luxury and becomes your defence.
And watch the withholding mechanism, which gets confused often: you may wait until you receive the goods or until the customer supplies evidence of having sent them, whichever comes first, unless you have offered to collect the goods yourself (Article 13(3) of the directive). But withholding does not restart the clock: the 14 days run from the moment the withdrawal is communicated to you. With one qualification that does protect you: while you withhold lawfully you are not in default, so the surcharges in the table above are not triggered merely because 14 days have passed —they come into play once you already have the goods, or the evidence of dispatch, and still do not refund without undue delay, and from day one if you had offered to collect the goods yourself. We develop it in when the 14-day period starts.
What if the customer paid with credit, a gift card or in several ways?
If the initial means of payment was store credit, returning it to that same balance is precisely what complies with Article 13(1). There is no conflict: you are not changing the form of their money, you are keeping it. The problem only appears when the payment came in as money and goes out as a voucher.
Three frequent situations and how to resolve them without inventing anything:
- Mixed payment (part card, part credit or gift card): refund each part through its own route, in the same proportion in which it was paid. It is the most faithful reading of Article 13(1) and the easiest to explain in a complaint.
- Purchase paid with a gift card received from someone else: the right of withdrawal belongs to whoever concluded the contract, not to whoever received the gift. If your policy accepts gift returns —and it is a good idea—, that is commercial policy, and there you can pay in credit.
- Expired card: there is nothing to agree here. The refund is submitted against the original transaction and the issuer usually routes it to the replacement card or the underlying account, so asking the customer for an alternative only delays a refund the law requires you to make without undue delay.
- Closed account, or a refund that comes back rejected: there the original means really has gone, and you will need to agree another one with the customer. That agreement also has to be express, even if the alternative is obvious: ask for it in writing and keep the reply.
How this translates to your Shopify store
Shopify lets you refund to the original payment method, to store credit, or split the amount between the two, and its return rules live in Settings → Policies. With two prerequisites for store credit that are worth knowing before you design anything: your store must use the new customer accounts and the order must be associated with a customer —a guest order has no customer record to credit, so there the only possible resolution is the original payment method—. What the platform does not do —and this is worth being clear about— is tell a legal withdrawal apart from a commercial return: that is your call when you set up the flow.
Three concrete decisions you can take today:
- Separate the two doors. One entrance for the legal withdrawal, with the refund going to the original payment method by default, and another for your commercial returns and exchanges policy, where store credit is a legitimate resolution.
- Keep the voucher as an explicit offer, never as a default value. In the legal flow, the default destination for the money is the card.
- Keep the trail. What was offered, what they chose, when and through which route. In Spain, without that trail the burden of proof works against you.
In returnEasier that separation comes built in: the withdrawal button is on every plan, including the free one, and its flow ends in a refund to the original means of payment; the commercial flow —exchanges, store credit and your own rules— is a separate layer available from the Pro plan up, so that revenue retention never contaminates a right.
Common mistakes
- Making the voucher the default option in the legal flow. Even if the customer can change it, a default value is not a choice.
- Leaning on a clause in the terms and conditions. It does not work as express agreement; in Italy, on top of that, the clause is null and void.
- Issuing the voucher and telling them afterwards. It turns a right into a complaint the customer has to start.
- Putting an expiry date on a voucher that replaces a refund. It was their money: letting it evaporate is very hard to defend.
- Treating a faulty product as an ordinary return. It goes through the legal guarantee, with its own order of remedies.
- Believing that withholding the refund freezes the deadline. It does not —the 14 days run from the communication of the withdrawal— although while you withhold lawfully you are not in default. What you cannot do is keep not paying once you already have the goods or the evidence of dispatch.
- Not recording the customer's choice. Without a date, a time and a trail, your express agreement does not exist in practice.
Frequently asked questions
Can a shop give me a voucher instead of the money? On a withdrawal, not by default. Article 13(1) of Directive 2011/83/EU requires the refund to go to the same means of payment unless the consumer expressly agrees otherwise and at no cost to them.
Does a clause in the terms and conditions count as express agreement? No. The LG Bochum (I-13 O 72/25, 15 October 2025) held that a clause in the general terms and conditions is not the express agreement the law requires.
What happens if the shop misses the deadline? In Spain the consumer can claim twice the amount (Art. 76 TRLGDCU); in Portugal the supplier must return double within 15 working days (Art. 12(6) Decreto-Lei n.º 24/2014); in France the amount is increased progressively (Art. L242-4).
What if I paid with store credit? That was your initial means of payment, so returning the amount to that same balance is what Article 13(1) calls for. On mixed payments, each part goes back through its own route.
Can I offer more value in credit than in cash? Yes, as long as the refund stays equally accessible: same screen, same visual weight, same number of clicks, and with the bonus explained before the choice.
And a faulty product? It goes through the legal guarantee (Directive (EU) 2019/771), not through withdrawal: repair or replacement first and, where appropriate, a price reduction or termination with the price paid returned.
Conclusion
If you sell on Shopify to European Union consumers, the rule that saves you most of the trouble fits in one sentence: in the legal flow, the money goes back the way it came in; store credit is offered, explained and chosen. Everything else —the bonus, the exchange, the credit with an expiry date— is commercial policy, and there you have plenty of room to retain revenue without touching a right.
The most profitable thing you can do today is not changing your policy but timing your flow: count the clicks that separate a customer from their money and compare them with the ones that separate them from a voucher. If they do not match, you already know where to start.
💡 Ready to comply effortlessly? returnEasier separates the compliant withdrawal button —refund to the original means of payment, no friction and every request sealed with a date and time— from your commercial flow of exchanges and store credit (Pro plans and above), in the 7 languages it supports. Try it free — 3 trial returns, no card.
Official sources
- Directive 2011/83/EU on consumer rights (arts. 13 and 14) — EUR-Lex
- Directive (EU) 2023/2673 — EUR-Lex
- Directive (EU) 2019/771 on the sale of goods — EUR-Lex
- Real Decreto Legislativo 1/2007 (TRLGDCU), arts. 76 and 107 — BOE
- Decreto-Lei n.º 24/2014, art. 12.º — Diário da República
- Article L242-4 du Code de la consommation — Légifrance
- § 357 BGB — Gesetze im Internet
- Art. 56 Codice del Consumo (D.Lgs. 206/2005) — Gazzetta Ufficiale
Informational content; not legal advice. For specific cases, consult a lawyer specialising in consumer law.