Infrastructure · Credibility 94/100 · · 5 min read
Infrastructure Strategy Briefing — September 12, 2025
Zeph Tech details how the EU Data Act’s cloud switching rules now in force reshape multi-cloud architecture, interoperability contracts, and exit testing across regulated workloads.
- EU Data Act
- Cloud portability
- Interoperability
- Multi-cloud governance
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
- Regulation (EU) 2023/2854 (Data Act)
- European Commission switching guidance
- CNIL/BfDI joint statement on cloud switching
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.