Policy Briefing — EU Data Act obligations begin applying
The EU Data Act (Regulation (EU) 2023/2854) becomes applicable on 12 September 2025, forcing connected-product makers, cloud providers, and public-sector requesters to operationalize data access, switching, and interoperability controls.
Executive briefing: The EU Data Act enters into application on . Data holders for connected products and related services must enable user access and sharing on fair, reasonable, and non-discriminatory terms, support B2G requests in emergencies, and provide safeguards against unlawful third-party use. Cloud providers must support switching and functional equivalence when customers migrate workloads.
What changes now
- User and third-party access. Product and service data must be made available via transparent terms and machine-readable interfaces; gatekeeping or pretextual delays breach Articles 4–5.
- Cloud switching. Providers must remove technical and commercial barriers to exit, publish switching processes, and phase out egress fees under Articles 23–24.
- Public-sector requests. Competent authorities can compel access for public emergencies under Articles 14–22 with compensation and confidentiality controls.
Program actions
- Inventory connected products and services sold in the EU, mapping telemetry flows and contractual data-holder roles.
- Publish FRAND-aligned access terms, rate limits, and API documentation, and ensure lawful basis review for third-party recipients.
- Update cloud contracts and playbooks with switching timelines, egress charge removal plans, and functional equivalence test cases.
- Establish a B2G request triage process covering authentication, necessity checks, and compensation calculations.
Sources
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