EU Data Act

 The EU Data Act entered into application on 12 September 2025. The Data Act introduces extensive obligations related to data accessibility, sharing, and cloud service terms. It applies particularly to technology companies with connected devices and to cloud service providers, who must now enable service switching and data portability for their customers. The aim of the Data Act is to promote data utilization within the EU internal market, increase transparency, and ensure a fair data economy for all stakeholders.

The Data Act significantly impacts the contractual practices, technical solutions, and business models of companies within its scope. It requires, among other things, that users have the right to access data generated during the use of connected devices and to share it with third parties. Companies must also ensure that their contractual terms are fair and transparent. In the context of cloud services, providers must enable customers to switch to other service providers both technically and contractually.

Applex assists organizations in complying with the Data Act in all roles – whether you are a data holder, a data user, or a data recipient. We help identify your organization’s position within the framework of the regulation and clarify the obligations and rights associated with that role. Based on this, we design the necessary operational models and documentation to support both data protection (e.g., personal data and trade secrets) and business-oriented data utilization (e.g., developing new services or products based on data).

Our services include:

• Mapping roles and responsibilities under the Data Act: We determine your organization’s role under the regulation and the obligations that apply to it.
• Reviewing and updating contracts: We assess your existing data-related agreements and identify necessary changes. The Data Act requires clear information on data collection, usage, sharing, and disclosure in contracts. We also ensure that contractual terms meet the fairness requirements set by the Data Act.
• Updating cloud service agreements: We help cloud service providers in adapting to the new obligations introduced by the Data Act. We evaluate contract terms and implement the required changes.
• Designing data sharing processes and ensuring data security: We develop processes that enable compliant data sharing within your organization. We ensure that trade secrets and personal data are appropriately protected and that data sharing is carried out in a controlled and documented manner.
• Training and compliance support: We organize training sessions and workshops on the key obligations and practical implications of the Data Act. We also provide practical tools for compliance, such as checklists, templates, and guidance materials.

If the EU Data Act raises questions or you need assistance with related matters, Applex is here to help. You can reach us here!