The EU Data Act (the Act) applies from today (12 September 2025) and establishes new rights for businesses and consumers to access data they generated using “connected devices,” limiting the exclusive control exercised by many data holders such as manufacturers and cloud service providers. UK businesses operating in the EU must now ensure that they are compliant with the provisions of the Act and be confident in its application; being mindful of the need to review and revise contractual frameworks and data governance strategies to comply with these obligations.
For a summary of the Act, please see our briefing note here from Beverley Flynn and Guy Cartwright: EU Data Act - Stevens & Bolton LLP.
It is important to note some parts of the Act are phased through transitional measures over the next two years, as outlined below:
| Date | Milestone | Provision in Act |
| 11 January 2024 | The Act entered into force. | Article 50 |
| 12 September 2025 | The Act becomes applicable, with some transitional measures below. | Article 50 |
| 12 September 2026 | After this date, the obligation resulting from Article 3(1) of the Act, which relates to the design and manufacturing of connected products and the design and provision of related services, applies. | Article 50 |
| 12 January 2027 | Providers of data processing services can no longer impose any switching charges on a customer for the switching process. | Article 29(2) |
| 12 September 2027 | In relation to contracts concluded on or before 12 September 2025, Chapter IV of the Act (Unfair Contract Terms Related to Data Access and Use between Enterprises) will apply provided that they are:
| Article 50 |
| 12 September 2028 | The Commission is to carry out a review of the Act by this date. | Article 49(1) |
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