Data Strategy Briefing — November 25, 2025
Article 50 of the Data Act makes the user-access obligation in Article 3(1) apply to connected products placed on the market after 12 September 2026, so November 2025 is the moment to lock product roadmaps and support tooling for that cutover.
Executive briefing: The Data Act applies from 12 September 2025, and Article 50 clarifies that the Article 3(1) user-access obligation hits connected products and related services placed on the market after 12 September 2026. Organisations releasing devices, vehicles, or industrial platforms in 2026 need to harden telemetry access, user dashboards, and dispute workflows now so the post-cutover launches satisfy the Act’s data-sharing rights.
Key governance checkpoints
- Product portfolio mapping. Catalogue 2026 product launches and feature updates to confirm which offerings will cross the September 2026 threshold and therefore require Article 3 data-access enablement from day one.
- User rights design. Align data access, retrieval formats, and metadata requirements with Article 4 safeguards, ensuring users (or third-party recipients) can request near-real-time telemetry without breaching trade secret protections.
- Contract refresh. Update customer agreements and partner terms to reflect the new access rights, dispute procedures, and security obligations, coordinating with the Commission’s model contractual clauses.
Operational priorities
- Engineering backlog. Prioritise API development, logging, and secure consent flows that will deliver user access while enforcing role-based controls.
- Support enablement. Train frontline teams on handling Article 5 request denials, timelines, and documentation so they can evidence proportionality when refusing abusive requests.
- Compliance testing. Execute simulations covering cross-border access, cybersecurity incident response, and trade secret redaction to validate readiness ahead of factory acceptance tests.
Enablement moves
- Build dashboards that track request handling SLAs, user satisfaction, and appeals outcomes for launches after September 2026.
- Brief suppliers and ecosystem partners on their downstream obligations when they provide related services that process the shared data.
Sources
Zeph Tech orchestrates Data Act product readiness programmes, user-access service design, and partner alignment workshops.