Regulation (EU) 2023/2854 (the Data Act) entered into force on January 11, 2024, and applied from September 12, 2025, with certain provisions phased in through 2026 and 2027. The Data Act is intended to create a harmonized framework for fair access to and use of data across the EU, supplementing the GDPR and sector-specific rules. The Data Act also includes specific requirements on providers of a “data processing service” to enable customers to switch to another provider (or to an on-premise solution)—this is likely to have a significant impact on the global cloud market.
