A procurement- and audit ready checklist for Chapter VI switching obligations.
Use it as a vendor due diligence list (customer) or an implementation checklist (provider).
Structured answer sets in this page tree.
Cited legal and guidance references.
EU Data Act Chapter VI requires providers of data processing services to remove switching obstacles and make portability real. This checklist translates Articles 23-30 into concrete controls and evidence. If you're a customer, use it to validate vendors before renewal. If you're a provider, use it to build an audit ready switching posture and to avoid "we support exports" claims that don't survive scrutiny.
Start with contracts. If the contract doesn't contain the required rights and obligations, switching becomes a discretionary support request instead of a guaranteed process.
Maintain a clause matrix per service type and publish a customer-facing summary aligned to the contract.
Assessment Autopilot can take EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching Compliance Checklist from turning this checklist into an operational 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.
Start from EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching Compliance Checklist and turn the guidance into owned tasks, evidence requests, and review checkpoints.
Review your current process, evidence gaps, and next steps for EU Data Act: Fair Access to Connected Product Data and Cloud Switching Cloud Switching Compliance Checklist.
A compliant switching posture requires a real workflow: owners, SLAs, and a runbook. Article 27 explicitly requires parties to cooperate in good faith to make switching effective and timely.
Procurement will ask for proof. Build a switching rehearsal program and keep artifacts.
Article 26 requires an up-to-date online register with the data structures and formats (and relevant standards/open interoperability specifications) used for exportable data.
Treat this as a customer-facing exportability specification and keep a change log.
Providers must publish jurisdiction information and a general description of measures designed to prevent conflicting international governmental access to or transfer of non-personal data held in the Union.
Operationally: keep a dedicated web page per service and reference it in contracts.
Switching charges have a hard phase-out: from 12 January 2027, switching charges are prohibited. In the interim period, reduced charges are allowed only if they are cost-based.
Implement billing controls so invoices don't accidentally reintroduce prohibited switching charges.
Article 30 requires open interfaces (free of charge) for portability and interoperability, and compatibility with common specifications or harmonised standards once published in the central repository (with a compliance window after publication).
If standards/specs aren't available yet for a service type, exportable data must still be exportable in structured, commonly used, machine-readable formats on request.
Treat Chapter VI as both compliance and sales. Most enterprise buyers will request proof: contract language, registers, drill outcomes, and public disclosures.
Keep a standard evidence pack per service type and keep it current.