Policy Briefing — EU Data Act interoperability implementing acts due
By 12 September 2026, the European Commission must adopt implementing acts detailing interoperability requirements for data spaces, smart contracts, and common schemas under the Data Act, triggering final design work for data intermediaries and industrial platforms.
Executive briefing: Regulation (EU) 2023/2854 (Data Act) instructs the Commission to issue implementing acts on interoperability requirements within 24 months of the regulation becoming applicable on 12 September 2025. The 2026 deadline sets the clock for data space operators and smart contract providers to align APIs, metadata, and certification workflows with harmonised specifications.
Mandatory deliverables
- Schema readiness. Prepare to integrate common European data space schemas, ensuring data holders can share machine-readable datasets with public bodies and business partners.
- Smart contract safeguards. Implement kill switches, logging, and controls referenced in Article 30 so self-executing agreements comply with forthcoming interoperability rules.
- Certification planning. Align governance with upcoming conformity assessment procedures the implementing acts may impose on data intermediation services.
Program actions
- Technical pilots. Prototype API adapters and semantic mapping layers that can be tuned quickly once detailed specifications are released.
- Stakeholder mapping. Coordinate with industry consortia and national competent authorities to preview draft standards and testing frameworks.
- Contract updates. Embed clauses requiring partners to adopt Commission-specified interoperability artefacts on agreed timelines.
Enablement moves
- Integrate Data Act readiness with GAIA-X, Catena-X, and other European data space programs to avoid duplicate engineering effort.
- Update risk registers to cover interoperability non-compliance, including potential suspension of data sharing under Article 33.