EU Data Act (Regulation 2023/2854): SaaS switching procedures effective Sept 2025; switching fees abolished by Sept 2027
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.
Sources: Digital Samba 2025 EU Data Act overview; Legiscope 2025 compliance guide; EUR-Lex Regulation 2023/2854.
Confidence: Verified (EU primary law).
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 effective Sept 22, 2024; penalties up to C$25M / 4% of worldwide turnover and Canadian Bill C-15 (tabled Nov 4, 2025) — proposes data-mobility framework for federal PIPEDA — regulators are catching up to platform lock-in faster than the US is.
Referenced by (4)
- reference GDPR Article 20: portability is narrow — only user-provided data, only under consent/contract, excludes derived data relates-to
- reference Canadian Bill C-15 (tabled Nov 4, 2025) — proposes data-mobility framework for federal PIPEDA relates-to
- reference Research brief: Owning your stack — why agency-managed platforms cost more than they save (piece 4 of 15) relates-to
- reference European Accessibility Act enforcement began June 28, 2025 — penalties up to €100k (Germany), 4-5% revenue (France/Italy) relates-to