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how to draft a refund policy uk

How to Draft a Refund Policy in the UK

If you're selling goods or services in the UK, knowing how to draft a refund policy uk is not optional — it's a legal requirement shaped by the Consumer Rights Act 2015 and the Consumer Contracts Regulations 2013. A compliant refund policy tells customers exactly what they're entitled to, when they can claim it, and how the process works. Get it wrong and you risk chargebacks, Trading Standards complaints, and reputational damage. Get it right and it actually reduces disputes. This guide walks you through every clause you need to include, what the law mandates versus what's discretionary, and where founders typically make mistakes. Whether you sell physical products, digital downloads, or services, the rules differ — and your policy needs to reflect that. This is practical, UK-specific guidance written for founders who want a legally sound document without paying solicitor rates for a first draft.

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Why this matters

Most UK founders either copy a refund policy from a competitor's website — which may itself be non-compliant — or use a generic template that ignores UK-specific statutory rights. The result is a policy that either promises less than the law requires (which is unenforceable and exposes you to complaints) or is so vague it gives customers no clarity and invites disputes. If you sell online, you also have to account for the 14-day cooling-off period under the Consumer Contracts Regulations. Miss that, and you're in breach before a customer even asks for a refund. This page exists to fix that gap with a clear, step-by-step drafting approach.

The Atornee approach

Atornee lets you generate a UK-compliant refund policy in minutes by answering a short set of questions about your business — what you sell, how you sell it, and your preferred returns window. The output is a structured draft built around the Consumer Rights Act 2015 and Consumer Contracts Regulations 2013, not a generic international template. You can review, edit, and download it immediately. It is not a substitute for a solicitor if your situation is complex — for example, if you sell regulated financial products or have bespoke B2B arrangements — but for the vast majority of UK e-commerce and service businesses, it gets you to a solid, usable first draft without the wait or the cost.

What you get

A refund policy draft that reflects your specific business model — physical goods, digital products, or services — with the correct statutory rights language for each.
Clear coverage of the 14-day cooling-off period required under the Consumer Contracts Regulations 2013 for online and distance sales.
Clauses that correctly distinguish between your legal obligations and any additional discretionary goodwill policy you choose to offer.
Plain-English language your customers will actually understand, reducing inbound queries and disputes.
A downloadable document you can publish directly to your website or terms page without reformatting.

Before you sign checklist

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1. Identify what you sell — physical goods, digital content, or services — because the statutory refund rights differ for each under the Consumer Rights Act 2015.
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2. Confirm whether you sell online or in-person, as the 14-day cooling-off period under Consumer Contracts Regulations 2013 applies to distance and off-premises sales only.
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3. Decide your discretionary returns window — many UK businesses offer 28 or 30 days as a goodwill gesture beyond the statutory minimum.
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4. List any exclusions you intend to apply, such as perishable goods, personalised items, or unsealed hygiene products, and check these are legally permitted exclusions.
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5. Confirm your refund method and timeline — UK law requires refunds within 14 days of receiving returned goods; your policy should state this clearly.
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6. Draft or generate your policy, then check it does not attempt to limit or waive statutory rights, which is unenforceable under UK consumer law.
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7. Publish the policy in a prominent, accessible location on your website — ideally linked from your checkout page and footer — before taking any customer payments.

FAQ

Is a refund policy legally required in the UK?

You are not legally required to have a written refund policy document, but you are legally required to honour statutory consumer rights under the Consumer Rights Act 2015 and Consumer Contracts Regulations 2013 regardless. Having a clear written policy is strongly advisable because it sets expectations, reduces disputes, and demonstrates compliance. If you sell online, you must also provide pre-contract information about cancellation rights — which in practice means having a written policy.

What is the minimum refund period I must offer UK customers?

For online and distance sales, customers have a 14-day right to cancel under the Consumer Contracts Regulations 2013, starting from the day they receive the goods. They then have a further 14 days to return the item after notifying you. For faulty goods, the Consumer Rights Act 2015 gives customers 30 days to reject the item and receive a full refund. These are statutory minimums — you can offer more, but you cannot offer less.

Can I exclude digital downloads from my refund policy?

Yes, but only under specific conditions. Under the Consumer Contracts Regulations 2013, you can exclude the right to cancel for digital content if the customer has given explicit consent to immediate download and acknowledged they lose their cancellation right. This must be captured at the point of purchase — a checkbox is the standard approach. If you do not capture this consent, the customer retains the 14-day cancellation right even for digital products.

Does my refund policy need to cover B2B customers differently?

Yes. Consumer rights legislation applies to consumers — individuals buying for personal use. Business-to-business transactions are governed by contract law and the Sale of Goods Act 1979 (as amended), not the Consumer Rights Act 2015. If you sell to both consumers and businesses, your policy should clearly distinguish between the two, or you should have separate terms. Applying consumer-level rights to B2B customers is generous but not legally required.

What happens if my refund policy contradicts UK consumer law?

Any clause in your refund policy that attempts to limit or remove statutory consumer rights is unenforceable under the Consumer Rights Act 2015. The customer retains their legal rights regardless of what your policy says. Beyond unenforceability, misleading customers about their rights can constitute an unfair commercial practice under the Consumer Protection from Unfair Trading Regulations 2008, which carries regulatory and reputational risk.

Do I need a solicitor to draft a refund policy?

For most standard UK e-commerce or service businesses, no — a well-structured template or AI-generated draft built around the correct legislation is sufficient. You should involve a solicitor if you operate in a regulated sector, have complex subscription or SaaS arrangements, sell internationally with UK customers, or have had a specific legal dispute that needs addressing in your terms. For everything else, a solid draft reviewed by a founder with this guide is a reasonable starting point.

Related Atornee Guides

Cheap Contract Solicitor Alternative (UK)

If you need broader contract support beyond a refund policy, this guide covers cost-effective options for UK founders.

Atornee Use Cases

See how UK businesses across different roles use Atornee to handle document drafting and review workflows.

Cheap Solicitor for NDA (UK)

If you also need confidentiality terms alongside your refund policy, this guide covers NDA drafting options.

External References

GOV.UK Business and Self-employed

Official UK government guidance on business operations, including consumer rights obligations for UK sellers.

UK Legislation

Primary statutory reference for the Consumer Rights Act 2015 and Consumer Contracts Regulations 2013 cited throughout this guide.

ICO Guidance for Organisations

Relevant if your refund process involves collecting or processing personal data — the ICO sets out your obligations under UK GDPR.

Trust & Verification Policy

Authored By

A

Atornee Editorial Team

UK Consumer Law Content Research

Reviewed By

C

Compliance Review Desk

UK Business Legal Content QA

Last reviewed on 3/4/2026

"This content is based on analysis of the Consumer Rights Act 2015, Consumer Contracts Regulations 2013, and common refund policy drafting patterns across UK e-commerce and service businesses. It reflects practical drafting considerations drawn from reviewing real UK business terms and consumer complaints patterns."

References & Sources