Infrastructure Strategy Briefing — September 12, 2025

Executive briefing: The EU Data Act’s Chapter VI obligations on cloud switching and interoperability became enforceable on September 12, 2025—twenty months after Regulation (EU) 2023/2854 took effect. Providers must strip withdrawal fees, expose functional equivalence documentation, and deliver continuity support when customers exit a service. Zeph Tech engineers exit runbooks so financial, health, and public-sector tenants can satisfy supervisory scrutiny.

Key industry signals

Fee abolition. Article 25(3) prohibits charges beyond cost-based compensation from this date; hyperscalers (AWS, Azure, Google Cloud) updated EU contracts in August 2025 to remove egress uplift fees for qualifying workloads.
Portability interfaces. Article 30 mandates open, well-documented APIs that permit functionally equivalent deployment; the European Commission’s Switching and Interoperability Guidelines (July 2025) clarify evidence expectations.
Supervisory pressure. France’s CNIL and Germany’s BfDI issued joint statements in September 2025 confirming audits will focus on contract clauses restricting portability for public-sector data.

Control alignment

EU Data Act Articles 23–30. Maintain contract libraries showing removal of switching fees and document the portability APIs available per workload tier.
ISO/IEC 27001 A.12.1.2. Ensure change management plans include Data Act exit testing checkpoints before production cutovers.

Detection and response priorities

Monitor billing telemetry for residual egress or termination line items after September 12 to trigger remediation with the provider’s Data Act compliance team.
Alert architecture leads when managed services (databases, messaging) lack feature parity APIs or export tooling documented in the provider’s interoperability attestation.

Enablement moves

Conduct semi-annual exit simulations covering identity, observability, and data residency controls to generate auditable artefacts for EU regulators.
Negotiate Data Act addenda that spell out incident assistance obligations when switching providers under supervisory direction.

Sources

Zeph Tech’s infrastructure desk executes controlled exit drills, reconciles billing data, and hardens portability APIs so EU Data Act compliance strengthens multi-cloud resilience.