Policy Briefing — September 11, 2025

Executive briefing: 11 September 2025 marks the application date for the bulk of the Data Act, activating Articles 4–40 on data access, compensation, unfair contract terms, public-sector requests, and data processing service switching.

Key data governance checkpoints

• Access workflows. Deploy authenticated portals and APIs for users and designated third parties to request product and related service data.
• Compensation frameworks. Finalise cost-based pricing models, invoicing, and dispute-handling processes for B2B data sharing.
• Emergency request handling. Operationalise Chapter V playbooks for responding to public-sector data requests in exceptional circumstances.

Operational priorities

• Switching enablement. Offer 30-day switching assistance, remove egress fees, and provide interoperability documentation for cloud and edge services.
• Contract remediation. Ensure legacy agreements have been updated to remove unfair clauses that will be unenforceable from the application date.
• Compliance evidence. Maintain audit trails, service metrics, and governance documentation to demonstrate compliance to competent authorities.

Enablement moves

• Launch customer communications explaining new rights, request channels, and switching support.
• Monitor national enforcement activity and guidance to calibrate internal assurance testing and reporting.

Sources

• Regulation (EU) 2023/2854 (Data Act)
• European Commission Data Act policy page

Zeph Tech provides Data Act readiness assessments, access automation, and switching enablement to support the September 2025 go-live.

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