Turn Chapter VI into an executable exit plan: contracts, portability, fees, and evidence.
Focus: switching between providers of data processing services and moves to on-premises ICT infrastructure.
Structured answer sets in this page tree.
Cited legal and guidance references.
EU Data Act Chapter VI is about removing switching barriers and making exit rights real. If you provide data processing services, you must remove contractual/technical/organisational obstacles and publish specific transparency information. If you buy cloud services, Chapter VI gives you a requirements checklist you can use to renegotiate exit terms and validate whether your vendor's switching process is compliant (including switching charges disappearing from 12 January 2027).
Chapter VI directly binds providers of data processing services, but customers should treat it as a vendor governance instrument. Your exit plan must be service-specific: obligations differ by service type and by what is actually under the provider's control.
A good exit plan starts with a service inventory and a "same service type" mapping: what you're switching from, and what you'll consider an equivalent destination.
Article 23 requires providers to remove pre-commercial, commercial, technical, contractual and organisational obstacles that inhibit switching. Convert that into measurable requirements and testable outcomes.
Think in stages: terminate, port data/assets, achieve functional equivalence, and unbundle where feasible.
Article 25 makes switching contractual. If the contract doesn't include the required clauses, your exit plan is brittle even if the vendor claims to support exports.
The operational numbers to lock down: maximum notice period <= 2 months, mandatory maximum transitional period of 30 days, and minimum retrieval period >= 30 days.
Article 26 requires two deliverables: clear information on switching procedures/methods/formats/limitations and a reference to an up-to-date online register with data structures/formats and relevant standards/open specs in which exportable data is available.
As a customer: treat the online register as a due diligence artifact. If it's missing, you are buying lock-in.
Article 28 adds a procurement-relevant disclosure obligation: providers must publish which jurisdiction their service infrastructure is subject to and a general description of measures to prevent conflicting international governmental access to non-personal data held in the Union.
Make this operational: a public web page, referenced in contracts, with versioned change history.
Article 29 has hard commercial outcomes. Reduced switching charges are allowed only in a limited window and must be cost-based. After the phase-out date, switching charges are prohibited.
Treat this as a billing + contracting project: update pricing, disclosures, and internal billing controls.
Your exit plan should exist even when you don't plan to switch. It reduces renewal lock-in, accelerates incident response, and creates negotiating leverage before long commitments.
Maintain one exit plan per critical service and rehearse it annually.
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