---
title: "Data Act Cloud Switching Contract Terms FAQ"
canonical_url: "https://www.sorena.io/artifacts/eu/data-act/faq/cloud-switching-contract-terms"
source_url: "https://www.sorena.io/artifacts/eu/data-act/faq/cloud-switching-contract-terms"
author: "Sorena AI"
description: "FAQ on EU Data Act cloud switching contract terms: Article 25 clauses, assistance, notice, transition, charges, export, termination, interoperability, and records."
published_at: "2026-05-06"
updated_at: "2026-05-06"
keywords:
  - "EU Data Act"
  - "Regulation (EU) 2023/2854"
  - "cloud switching contract terms"
  - "data processing services"
  - "exportable data"
  - "switching charges"
  - "cloud switching"
  - "standard contractual clauses"
---
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---

# Data Act Cloud Switching Contract Terms FAQ

FAQ on EU Data Act cloud switching contract terms: Article 25 clauses, assistance, notice, transition, charges, export, termination, interoperability, and records.

*FAQ* *EU* *Data Act*

## EU Data Act Cloud Switching Contract Terms FAQ

What cloud and SaaS contracts need to say about switching under the EU Data Act.

Use this FAQ to check Article 25 contract clauses, switching assistance, notice and transition periods, charges, exportable data, termination, interoperability duties, and evidence records.

The Data Act requires providers of data processing services to make cloud switching rights and provider obligations clear in written contracts. For procurement, legal, cloud architecture, and compliance teams, the practical task is to turn Chapter VI into reviewable clauses, operational switching playbooks, public charge information, export inventories, and records that show how a customer request was handled.

## Which Data Act cloud switching contract terms are mandatory in a provider contract?

Data Act Article 25 requires the customer switching rights and provider obligations to be clearly set out in a written contract that the customer can store and reproduce before signing. The contract must cover switching to another provider, porting to on-premises ICT infrastructure, or erasing exportable data and digital assets when the customer does not switch.

The clause set should not be a generic portability statement. It needs specific terms for reasonable assistance, business continuity, known continuity risks, security during transfer and retrieval, exit strategy support, termination, notice, exportable data and digital assets, exempt internal-functioning data, retrieval, erasure, and any switching charges allowed under Article 29.

- Maintain a clause matrix for each data processing service contract mapped to Article 25(2)(a) through Article 25(2)(i).
- Confirm the contract is available before signature in a form the customer can keep and reproduce.
- Check customer options at termination: switch provider, move to on-premises ICT infrastructure, or erase exportable data and digital assets.

## When does the Data Act treat a cloud or SaaS service as a data processing service for switching terms?

The Data Act cloud switching chapter applies to providers of data processing services. The Commission FAQ explains that this concept covers IaaS, PaaS, and SaaS where the service has cloud-computing characteristics such as on-demand network access to configurable, scalable, elastic computing resources provided to a customer.

Do the scope check before redlining clauses. A consumer-facing app feature that merely relies on cloud infrastructure may not be the same as a customer contracting for a data processing service, while an enterprise SaaS, PaaS, or IaaS service can fall into Chapter VI when the customer relationship and service characteristics are present.

- Record the service model, customer relationship, and computing resources in the contract review file.
- Do not limit the review to IaaS; PaaS and SaaS can also need Article 25 switching clauses.
- Flag custom-built or testing services separately because Article 31 can change which Chapter VI obligations apply.

## What Data Act switching assistance must be promised in cloud contract terms?

Data Act Article 25 requires the source provider to provide reasonable assistance to the customer and customer-authorised third parties during switching. The same clause should require due care to maintain business continuity, continued provision of contracted functions or services during the transition, clear information on known source-provider continuity risks, and a high level of security during transfer and retrieval.

For IaaS, Article 30 adds a technical assistance layer: providers must take reasonable measures to help the customer achieve functional equivalence in the destination service covering the same service type, including capabilities, information, documentation, technical support, and where appropriate tools. For PaaS and SaaS, the Commission FAQ says the duty does not require rebuilding the customer service inside the destination provider environment.

- Separate general Article 25 switching assistance from IaaS functional-equivalence support.
- Name the support channel, required customer inputs, destination-provider coordination path, and escalation owner.
- Keep evidence of assistance provided, known risks disclosed, continuity actions taken, and security controls used.

## How should Data Act cloud contracts handle notice periods and transition periods?

Data Act Article 25 caps the notice period for starting switching at two months. After that notice period, the mandatory maximum transitional period is 30 calendar days, during which the provider must perform the actions needed to enable switching while the contract remains applicable.

If a 30-day transition is technically unfeasible, the provider must notify the customer within 14 working days of the switching request, justify the technical unfeasibility, and identify an alternative transition period that does not exceed seven months. The customer also has a right to extend the transitional period once for a period the customer considers more appropriate.

- Put the two-month notice cap, 30-calendar-day transition rule, and technical-unfeasibility branch directly into the contract or switching schedule.
- Require a dated technical-unfeasibility notice and written justification before using the longer transition path.
- Track customer-elected extensions separately from provider-justified technical extensions.

## What Data Act rules apply to cloud switching charges and egress charges in contract terms?

Data Act Article 29 allows reduced switching charges from 11 January 2024 to 12 January 2027, but those charges must not exceed the costs directly linked to the switching process. From 12 January 2027, providers must not impose switching charges on customers for the switching process.

The Commission FAQ treats egress charges as included in switching charges for a switching operation. It also explains a separate in-parallel-use rule: where a customer uses services in parallel, such as multi-cloud deployment, providers may still pass on data egress costs incurred after 12 January 2027, provided they do not exceed those costs.

- List standard service fees, early termination penalties, and any reduced switching charges before contract signature.
- Keep a cost basis for any reduced switching charge used before 12 January 2027.
- Separate one-off switching egress from ongoing in-parallel-use egress in billing and customer notices.

## What Data Act data export terms should cloud contracts include for exportable data and digital assets?

Data Act Article 25 requires an exhaustive specification of all categories of data and digital assets that can be ported during switching, including at least all exportable data. The Commission FAQ explains exportable data as input and output data plus metadata generated or co-generated by the customer's use of the data processing service, while excluding data protected as provider or third-party intellectual property or trade secrets.

Digital assets are broader than customer records. The Commission FAQ describes them as elements the customer needs to effectively use its data in the new provider environment, including configuration metadata, security and access-control material, applications, virtual machines, and containers where the customer has the right to use them.

- Create a service-specific export inventory for data categories, metadata, configurations, virtualisation assets, and access-control material.
- Identify exempt internal-functioning data separately and explain why the exemption does not impede or delay switching.
- Tie each export category to the available format, interface, retrieval path, and responsible service owner.

## How should Data Act contract terms describe retrieval and erasure after cloud switching?

Data Act Article 25 requires a minimum retrieval period of at least 30 calendar days after the agreed transitional period ends. The contract also needs a clause guaranteeing full erasure of exportable data and digital assets generated directly by, or directly relating to, the customer after the retrieval period expires or after a later agreed period, provided switching has completed successfully.

Retrieval and erasure should be operationally distinct. Retrieval terms should say how the customer accesses the data and digital assets after transition, while erasure terms should say what gets erased, when erasure starts, which evidence is generated, and which legally retained or non-exportable material is outside the erasure commitment.

- Use a retrieval calendar that starts after the transition period, not from the initial switching notice.
- Prepare an erasure certificate or equivalent record tied to the exportable-data inventory.
- Explain any retained material by reference to the contract, legal duty, security need, or Article 25 exemption.

## When does the Data Act say the cloud contract terminates during switching or erasure?

Data Act Article 25 requires the contract to state when it is considered terminated and when the customer is notified. Termination occurs, where applicable, upon successful completion of the switching process, or at the end of the maximum notice period where the customer does not switch but instead wants exportable data and digital assets erased on service termination.

The termination clause should be linked to the switching workflow. A provider should not treat termination, retrieval, and erasure as a single event, because Article 25 gives them different functions and clocks.

- Define the evidence for successful switching completion before contract termination is confirmed.
- Separate termination notice, retrieval-period start, retrieval-period end, and erasure completion dates.
- Record the customer's selected path: destination provider, on-premises ICT infrastructure, or erasure without switching.

## What Data Act interoperability and interface terms should cloud contracts reference?

Data Act Article 26 requires providers to give customers information on switching and porting procedures, methods, formats, restrictions, and technical limitations. It also requires a reference to an up-to-date online register with the data structures, data formats, relevant standards, and open interoperability specifications in which Article 25 exportable data is available.

For PaaS and SaaS, Article 30 requires open interfaces for customers and destination providers free of charge to facilitate switching, with enough service information to enable software communication for data portability and interoperability. Compatibility with published common specifications or harmonised standards applies after the Data Act repository trigger and the Article 30 compliance clock.

- Reference the provider's online register in the contract and assign an owner for keeping it current.
- Document open interfaces, formats, known restrictions, technical limitations, and standards status by service type.
- Monitor the central Union standards repository because compatibility duties depend on published references.

## How do Data Act custom-built and testing-service exceptions affect cloud switching clauses?

Data Act Article 31 creates a specific regime for services whose main features are custom-built for one customer or whose components were developed for one customer and are not offered at broad commercial scale through the provider's service catalogue. It also excludes non-production testing and evaluation services provided for a limited period from Chapter VI obligations.

The Commission FAQ cautions that custom-built services are not fully outside Chapter VI. Some obligations can still apply, including open interfaces and structured, commonly used, machine-readable export where relevant. Before relying on Article 31, providers must inform the prospective customer which Chapter VI obligations do not apply.

- Keep a written classification for custom-built, catalogue, free-tier, beta, and production services.
- Tell the prospective customer before contract signature which Chapter VI obligations do not apply.
- Do not use Article 31 to remove export or interface commitments that still apply to the service.

## Can Data Act standard contractual clauses replace a provider's own cloud switching review?

The Commission has published non-binding standard contractual clauses for cloud computing contracts to help parties implement the Data Act. The Commission material says the clauses are voluntary and can be adapted, so they are a drafting aid rather than a substitute for checking the provider's actual services, export inventory, charges, interfaces, and transition process.

The Commission describes cloud SCC coverage for switching and exit, termination, security and business continuity, non-dispersion, non-amendment, and liability. Those themes are useful checkpoints for a Data Act contract review, especially where a legacy cloud agreement spreads switching obligations across order forms, service descriptions, online policies, support terms, and pricing pages.

- Use the SCC themes as a clause coverage checklist, then adapt them to the contracted service.
- Avoid inconsistent switching language across the main agreement, service schedule, pricing page, online register, and support policy.
- Record which SCC language was adopted, changed, or rejected, and why.

## What evidence records should Data Act cloud switching contract owners keep?

Data Act evidence for cloud switching should prove both contract coverage and operational performance. Keep the signed contract version, Article 25 clause matrix, export inventory, online-register snapshot, switching notice, transition calendar, assistance log, customer and destination-provider communications, charge calculation, retrieval confirmation, erasure record, and any technical-unfeasibility justification.

The record should also show why exceptions or limits were used. For example, keep the basis for exempting internal-functioning data, the reason a service was treated as custom-built or testing-only, the cost evidence for reduced charges before 12 January 2027, and the standards or interface status used for interoperability decisions.

- Assign one record owner for each switching request and one control owner for the contract template.
- Store time-stamped evidence for notice, transition, retrieval, erasure, charge, and assistance decisions.
- Review records after contract renewals, material service changes, standards-repository updates, and customer complaints.

## Primary sources

- [Regulation (EU) 2023/2854 (Data Act)](https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng?ref=sorena.io) - Binding source for Chapter VI cloud switching duties, including Article 23 obstacle removal, Article 25 mandatory contract clauses, Article 26 information duties, Article 29 charges, Article 30 technical switching, and Article 31 specific regimes.
- [European Commission - Frequently Asked Questions on the Data Act](https://ec.europa.eu/newsroom/dae/redirection/document/108144?ref=sorena.io) - Commission FAQ source used for practical explanations of data processing service scope, exportable data, digital assets, switching and egress charges, notice and transition periods, interoperability repository process, SCC status, and IaaS/PaaS/SaaS distinctions.
- [European Commission - Model contractual terms and cloud SCCs](https://digital-strategy.ec.europa.eu/en/library/draft-recommendation-non-binding-model-contractual-terms-data-access-and-use-and-non-binding?ref=sorena.io) - Commission source for the non-binding model contractual terms and standard contractual clauses, including cloud SCC coverage for switching and exit, termination, security and business continuity, non-dispersion, non-amendment, and liability.
- [European Commission - Data Act explained](https://digital-strategy.ec.europa.eu/en/factpages/data-act-explained?ref=sorena.io) - Commission overview source for Data Act application context and its policy objective of making data more accessible while encouraging innovation.

## Topic Guides

- [Data Act and Common European Data Spaces](/artifacts/eu/data-act/data-act-and-common-european-data-spaces.md): How Data Act Article 33 connects data-space participation with metadata, vocabularies, APIs, access terms, data quality, governance, and standards monitoring.
- [Data Act and Data Governance Act Overlap FAQ](/artifacts/eu/data-act/faq/data-governance-act-overlap.md): FAQ explaining where the EU Data Act and Data Governance Act overlap, how they differ, and how to route product, cloud, public-sector reuse, intermediary, and data altruism workflows.
- [Data Act and GDPR Personal Data Overlap FAQ](/artifacts/eu/data-act/faq/gdpr-personal-data-overlap.md): FAQ on how the EU Data Act works when connected-product or related-service data includes personal data, mixed datasets, GDPR roles, lawful basis, trade secrets, and third-party sharing.
- [Data Act Audit Evidence And Request Logs FAQ](/artifacts/eu/data-act/faq/audit-evidence-and-request-logs.md): FAQ for Data Act request logs covering user and third-party access, B2G exceptional need requests, cloud switching records, contract terms, trade secrets, and GDPR boundaries.
- [Data Act B2B Data-Sharing Contract Clauses](/artifacts/eu/data-act/b2b-data-sharing-contract-clauses.md): Clause guide for EU Data Act B2B data sharing: FRAND terms, compensation, trade secret safeguards, recipient limits, termination, logs, and GDPR boundaries.
- [Data Act B2B Data-Sharing Contract Template](/artifacts/eu/data-act/b2b-data-sharing-contract-template.md): A usable EU Data Act B2B data-sharing template outline covering access requests, data schedules, permitted use, trade secrets, security, compensation, GDPR boundaries, audit records, and termination.
- [Data Act B2G Exceptional-Need Requests](/artifacts/eu/data-act/b2g-exceptional-need-requests.md): A grounded guide to EU Data Act Chapter V requests from public bodies: exceptional need, public emergencies, request contents, limits, safeguards, costs, and records.
- [Data Act Cloud Switching Compliance Checklist](/artifacts/eu/data-act/cloud-switching-compliance-checklist.md): A grounded EU Data Act checklist for cloud and data processing service providers covering switching clauses, notices, export formats, charges, interoperability, and evidence.
- [Data Act Cloud Switching Fees And Deadlines FAQ](/artifacts/eu/data-act/faq/cloud-switching-fees-and-deadlines.md): FAQ on EU Data Act cloud switching charges, 2027 fee removal, notice periods, transition windows, data retrieval, contract terms, and evidence records.
- [Data Act Complaints and Dispute Settlement FAQ](/artifacts/eu/data-act/faq/complaints-and-dispute-settlement.md): FAQ on EU Data Act complaints, competent authorities, dispute settlement bodies, B2B data-sharing disputes, B2G requests, cloud switching disputes, and evidence records.
- [Data Act Exportable Data and Metadata FAQ](/artifacts/eu/data-act/faq/exportable-data-and-metadata.md): FAQ explaining which product, related service, metadata, and cloud switching data must be exportable under the EU Data Act, and which data can be excluded.
- [Data Act FAQ for Aftermarket Repair and Mobility Services](/artifacts/eu/data-act/faq/aftermarket-repair-and-mobility-services.md): FAQ on EU Data Act vehicle-data access for repairers, independent service providers, fleets, insurers, and mobility services.
- [Data Act Functional Equivalence FAQ](/artifacts/eu/data-act/faq/functional-equivalence.md): FAQ on Data Act functional equivalence for cloud switching: IaaS scope, customer outcomes, export support, interoperability duties, limits, and evidence.
- [Data Act Indirect Access Request Flows FAQ](/artifacts/eu/data-act/faq/indirect-access-request-flows.md): FAQ for Data Act teams handling user and third-party data requests when direct connected-product access is unavailable, incomplete, or limited.
- [Data Act International Government Access FAQ](/artifacts/eu/data-act/faq/international-government-access.md): FAQ on EU Data Act safeguards for non-EU government access to non-personal data held in the Union by data processing service providers.
- [Data Act Interoperability Standards FAQ](/artifacts/eu/data-act/faq/interoperability-standards.md): FAQ on EU Data Act interoperability standards for data spaces, cloud switching, smart contracts, harmonised standards, common specifications, and M/614.
- [Data Act Model Contractual Terms FAQ](/artifacts/eu/data-act/faq/model-contractual-terms.md): FAQ on the EU Data Act non-binding model contractual terms for data access and use, cloud switching clauses, B2B use, unfair terms, and evidence.
- [Data Act Public Emergency Requests FAQ](/artifacts/eu/data-act/faq/public-emergency-requests.md): FAQ on EU Data Act public emergency requests: exceptional need, request content, timing, data holder response, compensation, confidentiality, and records.
- [Data Act Smart Contracts for Data Sharing](/artifacts/eu/data-act/smart-contracts-for-data-sharing.md): Data Act Article 36 smart contract guide for data-sharing agreements: scope, robustness, access control, termination, interruption, archiving, standards status, and conformity evidence.
- [Data Act SME Exceptions and Startups FAQ](/artifacts/eu/data-act/faq/sme-exceptions-and-startups.md): FAQ on where the EU Data Act gives micro, small, medium-sized, startup, and SME actors narrower treatment for access duties, compensation, and B2B terms.
- [Data Act Trade Secret Technical Protection Measures FAQ](/artifacts/eu/data-act/faq/trade-secret-technical-protection-measures.md): FAQ on how EU Data Act data holders can protect trade secrets with confidentiality safeguards, technical measures, limited withholding, suspension, refusal, and evidence.
- [Data Act Trade Secrets and Protection Measures](/artifacts/eu/data-act/trade-secrets-and-protection.md): Data Act guide for protecting trade secrets during access and sharing: classification, safeguards, refusal thresholds, notices, evidence records, and reviews.
- [Data Act Unfair Contractual Terms | Article 13 B2B Contract Review](/artifacts/eu/data-act/unfair-contractual-terms.md): Review B2B data-sharing clauses under EU Data Act Article 13: unilateral terms, always unfair examples, presumed unfair terms, model clauses, evidence, and remediation.
- [Data Act Vehicle Data Guidance](/artifacts/eu/data-act/vehicle-data-guidance.md): Commission-grounded guide to Data Act vehicle data access: connected vehicles, vehicle-related services, raw and pre-processed data, aftermarket use cases, access routes, safeguards, and GDPR boundaries.
- [Data Act vs GDPR: connected-product data access](/artifacts/eu/data-act/data-act-vs-gdpr.md): Compare EU Data Act connected-product access duties with GDPR personal-data rules: scope, roles, lawful basis, data subject rights, third-party sharing, trade secrets, and conflicts.
- [EU Data Act and Common European Data Spaces FAQ](/artifacts/eu/data-act/faq/data-act-and-common-european-data-spaces.md): FAQ on how EU Data Act interoperability duties, Data Governance Act rules, and sector data-space governance fit together without treating participation as a general obligation.
- [EU Data Act Applicability Test](/artifacts/eu/data-act/applicability-test.md): Check whether a product, related service, data holder, cloud service, data-space role, smart contract, or B2G request is in scope of the EU Data Act.
- [EU Data Act Application Dates And Transition FAQ](/artifacts/eu/data-act/faq/application-dates-and-transition.md): FAQ on when the EU Data Act applies, which obligations are delayed, and what product, contract, cloud, and evidence records teams should maintain.
- [EU Data Act Article 3 Pre-Contract Information](/artifacts/eu/data-act/pre-contractual-information-obligations.md): What Article 3 of the EU Data Act requires before connected-product purchase, rent, lease, or related-service contracting: data categories, access, data holder identity, third-party sharing, complaints, and evidence.
- [EU Data Act Article 36 Smart Contract Controls FAQ](/artifacts/eu/data-act/faq/article-36-smart-contract-controls.md): FAQ explaining when EU Data Act Article 36 applies to smart contracts for data-sharing agreements and what controls, conformity evidence, and limits it requires.
- [EU Data Act B2B Data Sharing Compensation FAQ](/artifacts/eu/data-act/faq/compensation-for-b2b-data-sharing.md): FAQ on when Data Act data holders may charge B2B data recipients, what reasonable compensation can include, SME limits, unfair terms, disputes, and trade secret safeguards.
- [EU Data Act B2G Compensation and Costs FAQ](/artifacts/eu/data-act/faq/b2g-compensation-and-costs.md): FAQ on when Data Act B2G exceptional-need requests are free, when fair compensation may be claimed, which costs can be included, and what records to keep.
- [EU Data Act B2G Exceptional Need FAQ](/artifacts/eu/data-act/faq/b2g-exceptional-need.md): When public-sector bodies can request business-held data under the EU Data Act, what a valid request must contain, and how data holders handle limits, trade secrets, compensation, and evidence.
- [EU Data Act Checklist for Product, Cloud, and Contract Teams](/artifacts/eu/data-act/checklist.md): A grounded EU Data Act checklist for connected-product data access, third-party sharing, B2G requests, cloud switching, unfair terms, smart contracts, personal data boundaries, evidence, and owners.
- [EU Data Act Cloud Switching and Exit Plans](/artifacts/eu/data-act/cloud-switching-and-exit-plans.md): A grounded EU Data Act guide for data processing service exit plans: switching contracts, exportable data, assistance, charges, interoperability, retrieval, erasure, and records.
- [EU Data Act Cloud Switching Procurement FAQ](/artifacts/eu/data-act/faq/cloud-switching-procurement-checklist.md): Procurement checklist FAQ for EU Data Act cloud switching: contract terms, exit support, exportable data, switching charges, interoperability, termination, and supplier evidence.
- [EU Data Act Compliance Program](/artifacts/eu/data-act/compliance.md): Build a Data Act compliance program for connected-product data access, contracts, B2G requests, cloud switching, smart contracts, GDPR boundaries, records, and ownership.
- [EU Data Act Connected Product Scope and Data Types](/artifacts/eu/data-act/scope-connected-products-and-data-types.md): Classify EU Data Act connected products, related services, product data, related-service data, readily available data, metadata, and excluded derived outputs.
- [EU Data Act Connected Product Scope FAQ](/artifacts/eu/data-act/faq/scope-connected-products.md): FAQ explaining when connected products, related services, generated data, EU market placement, and SME exceptions fall within EU Data Act scope.
- [EU Data Act Data Processing Service Switching](/artifacts/eu/data-act/data-processing-services-switching.md): A grounded EU Data Act guide for provider and customer switching duties: exit assistance, exportable data, contract clauses, charges, interoperability, retrieval, and erasure.
- [EU Data Act data spaces interoperability FAQ](/artifacts/eu/data-act/faq/data-spaces-interoperability.md): FAQ explaining Article 33 Data Act interoperability requirements for data-space participants, common European data spaces, standards, APIs, metadata, and architecture evidence.
- [EU Data Act deadlines and compliance calendar](/artifacts/eu/data-act/deadlines-and-compliance-calendar.md): A source-linked calendar for EU Data Act application dates, product design timing, contract remediation, cloud switching charges, response periods, standards work, and evidence records.
- [EU Data Act Direct Access by Design FAQ](/artifacts/eu/data-act/faq/direct-access-by-design.md): FAQ for product and legal teams designing user access to connected-product and related-service data under the EU Data Act.
- [EU Data Act Enforcement And Competent Authorities FAQ](/artifacts/eu/data-act/faq/enforcement-and-competent-authorities.md): FAQ on who enforces the EU Data Act, how complaints work, how Member States set penalties, when dispute settlement can be used, and when GDPR authorities remain responsible.
- [EU Data Act FAQ: scope, access rights, B2G, cloud switching, GDPR, and dates](/artifacts/eu/data-act/faq.md): Grounded EU Data Act FAQ index covering connected-product data access, third-party sharing, B2G exceptional need, cloud switching, smart contracts, GDPR boundaries, unfair terms, trade secrets, and application dates.
- [EU Data Act Non-Emergency Public-Sector Requests FAQ](/artifacts/eu/data-act/faq/non-emergency-public-sector-requests.md): FAQ on EU Data Act requests where a public body claims exceptional need outside a public emergency, including scope, request contents, limits, compensation, confidentiality, and evidence.
- [EU Data Act Non-Personal Data and Mixed Datasets FAQ](/artifacts/eu/data-act/faq/non-personal-data-and-mixed-datasets.md): FAQ on how the EU Data Act treats non-personal data, mixed datasets, GDPR precedence, user and third-party access, trade-secret limits, and evidence records.
- [EU Data Act Penalties and Enforcement](/artifacts/eu/data-act/penalties-and-fines.md): Grounded guide to Data Act penalties under Article 40, Member State enforcement, penalty factors, complaints, judicial remedies, and the GDPR enforcement boundary.
- [EU Data Act Pre-Contractual Information FAQ](/artifacts/eu/data-act/faq/pre-contractual-information.md): FAQ on EU Data Act Article 3 pre-contract information for connected products and related services, including data categories, access methods, data holder identity, third-party sharing, and GDPR boundaries.
- [EU Data Act Product Data vs Related Service Data FAQ](/artifacts/eu/data-act/faq/product-data-and-service-data.md): FAQ explaining how the EU Data Act separates connected product data, related service data, readily available raw and pre-processed data, metadata, and inferred or derived outputs.
- [EU Data Act Readily Available Data FAQ](/artifacts/eu/data-act/faq/readily-available-data.md): FAQ on what counts as readily available data under the EU Data Act, including product data, related service data, metadata, inferred data, and access mechanics.
- [EU Data Act Related Services FAQ](/artifacts/eu/data-act/faq/related-services.md): FAQ explaining when software is a Data Act related service, how it links to connected products, which product and service data are in scope, and what exclusions apply.
- [EU Data Act requirements](/artifacts/eu/data-act/requirements.md): Source-grounded EU Data Act requirements for connected-product data access, B2B sharing terms, B2G exceptional needs, cloud switching, smart contracts, interoperability, GDPR boundaries, and records.
- [EU Data Act Smart Contracts for Data Sharing FAQ](/artifacts/eu/data-act/faq/smart-contracts-for-data-sharing.md): Answers on Article 36 Data Act smart-contract requirements for data sharing: scope, robustness, access control, termination, archiving, conformity assessment, contract terms, and standards status.
- [EU Data Act Third-Party Data Sharing FAQ](/artifacts/eu/data-act/faq/third-party-data-sharing.md): FAQ on user-directed third-party data sharing under the EU Data Act, covering data holder duties, recipient limits, trade secrets, security, GDPR, and gatekeepers.
- [EU Data Act Trade Secret Safeguards FAQ](/artifacts/eu/data-act/faq/trade-secrets-safeguards.md): FAQ on protecting trade secrets when handling EU Data Act user and third-party data access requests, including safeguards, withholding, suspension, refusal, notices, and records.
- [EU Data Act Unfair Contractual Terms FAQ](/artifacts/eu/data-act/faq/unfair-contractual-terms.md): FAQ on Article 13 of the EU Data Act: B2B unfair contract terms, unilateral take-it-or-leave-it clauses, always-unfair terms, presumed-unfair terms, SMEs, model terms, and review evidence.
- [EU Data Act User Access and Portability Rights](/artifacts/eu/data-act/access-rights-and-portability.md): Practical guide to EU Data Act user access, connected-product data portability, third-party sharing, trade secret safeguards, and the GDPR boundary.
- [EU Data Act Users, Data Holders, and Recipients FAQ](/artifacts/eu/data-act/faq/users-data-holders-and-recipients.md): FAQ explaining Data Act users, data holders, data recipients, connected products, related services, user access, third-party limits, and GDPR boundaries.
- [EU Data Act Vehicle Data Guidance FAQ](/artifacts/eu/data-act/faq/vehicle-data-guidance.md): FAQ on EU Data Act vehicle data guidance for connected vehicles, aftermarket repair, mobility services, third-party access, trade secrets, security, and GDPR boundaries.
- [EU Data Act vs Data Governance Act](/artifacts/eu/data-act/data-act-vs-data-governance-act.md): Compare the EU Data Act with the Data Governance Act: connected-product access, cloud switching, B2B/B2G duties, protected public-sector reuse, intermediaries, altruism, governance, and enforcement.

*Recommended next step*

*Placement: after evidence section*

## Review Data Act cloud switching clauses

Map your cloud and SaaS agreements against Article 25 clauses, Article 29 charges, export inventories, transition clocks, interoperability records, and customer-facing switching procedures.

- [Open Research Copilot](/solutions/research-copilot.md): Get cited answers on Data Act cloud switching clauses, charges, export, and interoperability duties.
- [Discuss cloud switching terms](/contact.md): Review Data Act impacts across procurement, legal, cloud architecture, support, and compliance records.


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