The Data Act entered into force on 11 January 2024 and provides that most of the obligations will apply from 12 September 2025, with some already applicable upon entry into force and others postponed until 2026 or even 2027.

These application stages are outlined below.

11/01/2024  < 12/01/2027 Reduction and limitation of the charges when switching providers of data processing services (charges must not exceed the costs associated with the switching process).
   
12/09/2025
  • Application of most of the Data Act obligations.
  • Chapter III (obligations for data holders in B2B sharing situations) is applicable to the obligations to make data available pursuant to Union law or national legislation adopted in accordance with Union law, entering into force from that date.
  • Chapter IV (unfair contractual terms) is applicable to all contracts concluded after that date. 
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12/09/2026
  • The obligation regarding the direct accessibility of data, by default and free of charge for the user (Article 3(1)) is applicable to connected products and related services that are placed on the market after this date.
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12/01/2027
  • Total withdrawal of the charges to switch data processing service providers.
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12/09/2027
  • Chapter IV (unfair terms) is applicable to contracts concluded before 12/09/2025, under conditions:
    • permanent contracts; or
    • contracts expiring at least 10 years from 11 January 2024.

 

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