Policy Briefing — September 11, 2025
The EU Data Act’s core obligations come into force today, enforcing connected-product data access, SME contract fairness, emergency data sharing, and cloud switching rights across the bloc.
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
Zeph Tech provides Data Act readiness assessments, access automation, and switching enablement to support the September 2025 go-live.