--- title: "Cloud Switching and Exit Plans" canonical_url: "https://www.sorena.io/artifacts/eu/data-act/cloud-switching-and-exit-plans" source_url: "https://www.sorena.io/artifacts/eu/data-act/cloud-switching-and-exit-plans" author: "Sorena AI" description: "EU Data Act Chapter VI cloud switching made practical: Article 23 obstacle removal, Article 25 required contract terms (max 2-month notice, 30-day transition." published_at: "2026-02-23" updated_at: "2026-02-23" keywords: - "EU Data Act cloud switching" - "EU Data Act Chapter VI" - "switch cloud provider EU Data Act" - "cloud exit plan EU Data Act" - "switching charges 12 January 2027" - "maximum notice period two months Data Act" - "30 day transitional period Data Act" - "exportable data definition Data Act" - "functional equivalence cloud switching" - "EU compliance" - "data-act compliance" - "Cloud Switching and Exit Plans" - "compliance timeline" - "compliance decision flow" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # Cloud Switching and Exit Plans EU Data Act Chapter VI cloud switching made practical: Article 23 obstacle removal, Article 25 required contract terms (max 2-month notice, 30-day transition. *Artifact Guide* *EU* ## EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching and Exit Plans 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. 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). ## 1) Decide your posture: provider obligations vs customer leverage 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. - Provider: remove switching obstacles (Article 23) and deliver contract + technical obligations (Articles 25-30) - Customer: require proof (contract clauses, switching drill results, register content) before renewal/commitments - Service inventory: classify services you buy/sell and define what "same service type" means in your architecture ## 2) Article 23 obstacle removal - what 'lock-in' looks like in real systems 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. - Termination support: contract termination after maximum notice period and switching completion - Portability: customer can port exportable data and digital assets (including after free-tier usage) - Functional equivalence: provider must facilitate functional equivalence for the new service in a different provider environment - Unbundling: decouple switching-relevant services from unrelated bundled services where technically feasible ## 3) Article 25 contract requirements - the must-have clause list 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 = 30 days. - Switching right: switch to another provider or to on-prem; assistance + continuity + security throughout the process - Exit strategy support: provider must support the customer's exit strategy and provide relevant information - Portability scope: exhaustive list of exportable data + digital assets; exemptions for provider internal-functioning data must not impede switching - Timing: maximum notice period = 30 days - Exception handling: if 30 days is technically unfeasible, provider notifies within 14 working days and proposes alternative period <= 7 months ## 4) Article 26 transparency - procedures + the online register 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. - Online register: schemas, formats, and the standards/open interoperability specs used for exportable data - Known limitations: restrictions and technical limitations disclosed up front - Evidence: register snapshots and change history; contracts pointing to the register URL ## 5) Article 28 international access transparency - jurisdiction + conflict mitigation measures 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. - Publish per-service: jurisdiction information + measures description; keep it up to date - Reference in contracts: the web pages listed in all relevant service contracts - Evidence: internal review cadence, approvals, and change log for updates ## 6) Article 29 switching charges - bake the dates into pricing and billing 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. - Reduced switching charges permitted 11 Jan 2024-12 Jan 2027; capped to costs directly linked to switching - No switching charges from 12 Jan 2027 - Pre-contract disclosure: standard fees, early termination penalties, and any reduced switching charges ## Exit plan template - a vendor-neutral structure you can run 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. - Scope: service type, workloads, data domains, digital assets, and dependencies - Portability: exportable data manifest, formats, tooling, and time-to-export SLOs - Security: encryption, access control, integrity validation, and logging during switching - Continuity: cutover testing, rollback plan, and transitional period runbook - Commercial: fees/penalties/switching charges policy (with the 12 Jan 2027 hard stop) - Evidence: contract clause checklist, register snapshots, and switching rehearsal test reports *Recommended next step* *Placement: near the end of the main content before related guides* ## Turn EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching and Exit Plans into an operational assessment Assessment Autopilot can take EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching and Exit Plans from turning this guidance into an operational assessment workflow to a reusable workflow inside Sorena. Teams working on EU Data Act: Fair Access to Connected Product Data and Cloud Switching can keep owners, evidence, and next steps aligned without copying this guide into separate documents. - [Open Assessment Autopilot for EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching and Exit Plans](/solutions/assessment.md): Start from EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching and Exit Plans and turn the guidance into owned tasks, evidence requests, and review checkpoints. - [Talk through EU Data Act: Fair Access to Connected Product Data and Cloud Switching](/contact.md): Review your current process, evidence gaps, and next steps for EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching and Exit Plans. ## Primary sources - [Regulation (EU) 2023/2854 (Data Act) - Official Journal (ELI)](https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng?ref=sorena.io) - Chapter VI switching obligations (Articles 23-31), including contract requirements (Article 25), online register (Article 26), jurisdiction transparency (Article 28), switching charges (Article 29), and technical aspects (Article 30). ## Related Topic Guides - [Access Rights and Portability | EU Data Act: Fair Access to Connected Product Data and Cloud Switching](/artifacts/eu/data-act/access-rights-and-portability.md): EU Data Act access rights and portability (Chapter II) made practical: direct vs indirect access, "readily available" data. - [Applicability Test | EU Data Act: Connected Products, B2B Data Sharing, B2G Exceptional Need, Cloud Switching](/artifacts/eu/data-act/applicability-test.md): A practical EU Data Act applicability test you can run in 15 minutes: determine if Chapter II IoT access rights apply (connected products + related services). - [B2B Data Sharing Contract Clauses | EU Data Act: Mandatory Sharing, Unfair Terms, Trade Secrets](/artifacts/eu/data-act/b2b-data-sharing-contract-clauses.md): EU Data Act contract clauses for B2B data sharing made practical: clause library for Chapter III access/use (purpose limits, compensation, security. - [B2B Data Sharing Contract Template | EU Data Act: Data Access and Use Agreement (Drafting Checklist)](/artifacts/eu/data-act/b2b-data-sharing-contract-template.md): A practical EU Data Act-aligned B2B data sharing contract template: sections, annexes, and drafting checklist for dataset definition, permitted use. - [B2G Exceptional Need Requests | EU Data Act: Public Emergency Data Requests, Safeguards, Compensation](/artifacts/eu/data-act/b2g-exceptional-need-requests.md): EU Data Act Chapter V B2G 'exceptional need' requests made practical. - [Cloud Switching Compliance Checklist | EU Data Act Chapter VI: Contracts, Exportable Data, Fees, Transparency](/artifacts/eu/data-act/cloud-switching-compliance-checklist.md): A detailed EU Data Act Chapter VI cloud switching compliance checklist: Article 25 contract terms (max notice period, 30-day transition, retrieval period). - [Compliance Program | EU Data Act Implementation Playbook: Governance, Controls, Evidence, Operating Cadence](/artifacts/eu/data-act/compliance.md): Turn the EU Data Act into an implementation program: chapter scoping, roles and ownership, product workflows for Chapter II access. - [Deadlines and Compliance Calendar | EU Data Act](/artifacts/eu/data-act/deadlines-and-compliance-calendar.md): Plan EU Data Act delivery with real dates: Regulation applies from 12 Sep 2025. - [EU Data Act Checklist | Chapter II Access, B2B Sharing, Unfair Terms, B2G Requests, Cloud Switching](/artifacts/eu/data-act/checklist.md): A comprehensive EU Data Act checklist organized by roles and chapters: Chapter II connected product data access (direct vs indirect access). - [EU Data Act vs GDPR | Differences, Overlap, Portability, Lawful Basis, Implementation Playbook](/artifacts/eu/data-act/data-act-vs-gdpr.md): EU Data Act vs GDPR made practical: how Chapter II access/portability for connected product data differs from GDPR data subject rights. - [FAQ | EU Data Act Explained: Key Dates, Access Rights, Trade Secrets, B2G Requests, Cloud Switching](/artifacts/eu/data-act/faq.md): EU Data Act FAQ with practical answers grounded in official sources: when the Data Act applies (Article 50), direct vs indirect access. - [Penalties and Fines | EU Data Act Enforcement: Member State Penalties, GDPR-Linked Fines, Risk Controls](/artifacts/eu/data-act/penalties-and-fines.md): EU Data Act penalties and fines made practical: how Member States set penalties (Article 40), the criteria authorities must consider. - [Requirements | EU Data Act Obligations Explained: Chapter II Access, Chapter IV Unfair Terms, Chapter V B2G, Chapter VI Switching](/artifacts/eu/data-act/requirements.md): A structured EU Data Act requirements breakdown across Chapters II-VI: connected product data transparency and access workflows. - [Scope, Connected Products and Data Types | EU Data Act: Fair Access to Connected Product Data and Cloud Switching](/artifacts/eu/data-act/scope-connected-products-and-data-types.md): EU Data Act scope explained: connected products vs related services, product data vs related service data, readily available data. - [Trade Secrets and Protection | EU Data Act: Confidentiality Measures, Withholding Rules, Evidence Pack](/artifacts/eu/data-act/trade-secrets-and-protection.md): EU Data Act trade secrets protection made practical: how to identify trade secret fields before disclosure, how to agree confidentiality measures (NDAs. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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