Does the requirement also apply to contracts concluded before 1 July 2022?

Yes. The cancellation button requirement does not depend on when the contract was concluded, but on whether there is an ongoing contractual relationship with a consumer. Anyone who sold subscriptions or memberships before July 2022 that continue to this day must also offer their customers a functioning digital cancellation method — regardless of how the original contract was concluded, whether online, by phone or on paper. Operators who have not updated their website in years should not assume that older contract portfolios are automatically exempt from the requirement. This is precisely where one of the most common oversights appears in practice among established providers with long-standing customer bases.