{"id":124,"slug":"eu-data-act-sept-2025-2027","title":"EU Data Act (Regulation 2023/2854): SaaS switching procedures effective Sept 2025; switching fees abolished by Sept 2027","kind":"reference","scope":"business","status":"current","audiences":["claude-code","candid-team"],"topics":["platform-lock-in","data-portability","regulatory-compliance"],"reference_body":"**Claim:** **EU Data Act** (Regulation 2023/2854) became fully applicable **September 12, 2025**. It mandates cloud/SaaS switching procedures and **eliminates switching fees by September 27, 2027**. Extended interoperability requirements take effect **September 12, 2026**.\n\n**Sources:** Digital Samba 2025 EU Data Act overview; Legiscope 2025 compliance guide; EUR-Lex Regulation 2023/2854.\n\n**Confidence:** Verified (EU primary law).\n\n**Implication for non-EU SMBs:** The Data Act applies to services offered in the EU regardless of provider location. Even a Canadian SMB using AWS or Shopify gets covered. Enforcement record is short — file as a forward-looking signal, not a current lever. Pairs with [[quebec-law-25-data-portability-sept-2024]] and [[bill-c-15-canada-pipeda-mobility-2025]] — **regulators are catching up to platform lock-in faster than the US is**.","rationale_body":null,"metadata":null,"links":{"outgoing":[],"incoming":[{"slug":"gdpr-article-20-portability-narrow","title":"GDPR Article 20: portability is narrow — only user-provided data, only under consent/contract, excludes derived data","kind":"reference","scope":"business","link_type":"relates-to"},{"slug":"bill-c-15-canada-pipeda-mobility-2025","title":"Canadian Bill C-15 (tabled Nov 4, 2025) — proposes data-mobility framework for federal PIPEDA","kind":"reference","scope":"business","link_type":"relates-to"},{"slug":"research-brief-owning-your-stack","title":"Research brief: Owning your stack — why agency-managed platforms cost more than they save (piece 4 of 15)","kind":"reference","scope":"business","link_type":"relates-to"},{"slug":"eu-accessibility-act-enforcement-june-2025","title":"European Accessibility Act enforcement began June 28, 2025 — penalties up to €100k (Germany), 4-5% revenue (France/Italy)","kind":"reference","scope":"business","link_type":"relates-to"}]},"created_at":"2026-05-22T19:17:26.840Z","updated_at":"2026-05-22T19:17:26.840Z"}