---
title: "EU Data Act Cloud Switching Procurement FAQ"
canonical_url: "https://www.sorena.io/artifacts/eu/data-act/faq/cloud-switching-procurement-checklist"
source_url: "https://www.sorena.io/artifacts/eu/data-act/faq/cloud-switching-procurement-checklist"
author: "Sorena AI"
description: "Procurement checklist FAQ for EU Data Act cloud switching: contract terms, exit support, exportable data, switching charges, interoperability, termination, and supplier evidence."
published_at: "2026-05-06"
updated_at: "2026-05-06"
keywords:
  - "EU Data Act cloud switching"
  - "data processing services"
  - "switching charges"
  - "exportable data"
  - "cloud procurement"
  - "EU Data Act"
  - "Regulation (EU) 2023/2854"
  - "cloud switching"
  - "procurement checklist"
---
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# EU Data Act Cloud Switching Procurement FAQ

Procurement checklist FAQ for EU Data Act cloud switching: contract terms, exit support, exportable data, switching charges, interoperability, termination, and supplier evidence.

*FAQ* *EU* *Data Act*

## EU Data Act Cloud Switching Procurement FAQ

A procurement checklist for buying or renewing cloud and edge data processing services under the EU Data Act.

Use it to test whether supplier terms cover switching rights, exit support, exportable data, interoperability, switching charges, termination, and auditable evidence.

This FAQ turns the EU Data Act's cloud-switching rules into procurement questions for customers reviewing data processing service contracts. It focuses on the buyer-side evidence to request before signature or renewal, while grounding the checks in Chapter VI of Regulation (EU) 2023/2854 and Commission implementation material.

## What should procurement check first under the EU Data Act cloud-switching rules?

Start by confirming that the supplier is providing a data processing service to a customer, such as cloud or edge services using configurable, scalable computing resources. The Commission FAQ explains that the Data Act concept covers common IaaS, PaaS, and SaaS delivery models when the service has the Article 2(8) characteristics.

Then ask whether the contract removes the obstacles listed in Article 23: termination after the permitted notice and successful switch, new contracts with another provider, porting exportable data and digital assets, functional equivalence where applicable, and technically feasible unbundling.

- Record the service model reviewed: IaaS, PaaS, SaaS, edge service, custom-built service, or limited test service.
- Identify the source provider, possible destination provider, and whether the buyer may also switch to on-premises ICT infrastructure.
- Check whether any custom-built or non-production exemption is claimed, and request the supplier's explanation before contracting.

Sources for this answer:

- [Regulation (EU) 2023/2854 (Data Act)](https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng?ref=sorena.io) - Article 23 is the binding source for the obstacles providers must remove to enable effective switching.
- [European Commission - Frequently asked questions about the Data Act](https://digital-strategy.ec.europa.eu/en/library/commission-publishes-frequently-asked-questions-about-data-act?ref=sorena.io) - Commission FAQ support for treating IaaS, PaaS, and SaaS as data processing services when the Article 2(8) characteristics are present.

## Which mandatory cloud-switching contract terms should be visible before signature under the Data Act?

The Data Act context is the starting point for this answer. Article 25 requires the customer's switching rights and the provider's obligations to be clearly set out in a written contract that the customer can store and reproduce before signing. Procurement should therefore reject exit language that is only in a help-center article, commercial slide, or support policy outside the contract pack.

The contract should cover at least switching or porting on request, support for the customer's exit strategy, termination mechanics, a maximum notice period, exportable data categories, provider-internal data exemptions, a retrieval period, erasure after retrieval or an agreed later date, and any permitted switching charges.

- Ask for a clause matrix against Article 25(2)(a) to (i), with contract references for each item.
- Require a maximum notice period for initiating switching that does not exceed two months.
- Confirm that the contract states when termination occurs after a successful switch or after erasure where the customer does not switch.

Sources for this answer:

- [Regulation (EU) 2023/2854 (Data Act)](https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng?ref=sorena.io) - Article 25 lists the minimum written contract content for switching between data processing services.
- [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 material identifies non-binding SCC modules for switching and exit, termination, security and business continuity, and related fair-contract topics.

## What exit and export support should a buyer require from a cloud provider under the Data Act?

The Data Act context is the starting point for this answer. For switching or porting, Article 25 requires reasonable assistance, due care to maintain business continuity, clear information on known continuity risks, and high security during transfer and retrieval. A procurement checklist should ask for named support channels, technical documentation, migration tooling, continuity risk notices, and security controls during the switch.

Article 26 adds a separate information obligation: the provider must give switching and porting procedures, methods, formats, known restrictions, technical limitations, and a reference to an up-to-date online register for data structures, data formats, relevant standards, and open interoperability specifications.

- Request the export runbook, supported export formats, API or interface documentation, and known technical limitations.
- Ask for evidence of the online register covering data structures, formats, standards, and open interoperability specifications.
- Require the supplier to state what assistance is included in the Data Act switching obligation and what extra services would be separately chargeable.

Sources for this answer:

- [Regulation (EU) 2023/2854 (Data Act)](https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng?ref=sorena.io) - Articles 25 and 26 support the procurement checks for assistance, continuity, security, switching procedures, formats, restrictions, and the online register.
- [European Commission - Data Act explained](https://digital-strategy.ec.europa.eu/en/factpages/data-act-explained?ref=sorena.io) - Commission explainer describes cloud-switching barriers such as data egress charges, lengthy procedures, and lack of interoperability.

## What implementation records and review triggers should teams keep after agreeing the Data Act answer?

For cloud switching procurement checklist, the Data Act record should identify the source clause, Commission guidance, affected service, decision owner, and the evidence used to approve the supplier's switching terms. Keep the contract pack, supplier redlines, export tests, fee schedule, and online-register snapshot together so the decision can be checked later.

Review the checklist again when the service architecture, supplier documentation, standards references, or renewal timetable changes. A later reviewer should be able to see what was agreed, why it was acceptable, and what would require a fresh review.

- Save the signed clause set, supplier responses, approval notes, export tests, fee schedule, online-register snapshot, and erasure confirmation requirements.
- Assign procurement, legal, security, architecture, and service-owner sign-off for high-risk services.
- Set a renewal review date and an event trigger for changes to the service model, export path, or provider documentation.

## How should procurement test a cloud provider's switching charges and egress fees under the EU Data Act?

Under the Data Act, Article 29 phases out switching charges, including data egress fees, so that from 12 January 2027 providers cannot impose them, and in the interim period any charge must not exceed the costs the provider actually incurs. Procurement should ask the supplier to confirm which date its contract reflects and how any interim charge is calculated.

A buyer should reject open-ended egress pricing and require the contract to state that switching charges fall away on the statutory date, so the cost of leaving is predictable rather than a lock-in lever.

- Confirm the contract removes switching charges from 12 January 2027 and caps any interim charge at actual cost.
- Ask for the cost basis of any reduced switching charge so it can be checked against the Article 29 limit.

## Which exportable data and digital assets must a cloud provider hand over on exit under the EU Data Act?

Under the Data Act, exportable data covers the data the customer generated or imported and the digital assets it is entitled to, but it excludes assets protected by third-party intellectual property rights or that would reveal the provider's own trade secrets. Procurement should ask the supplier to define the boundary in the contract rather than discovering it during a migration.

The checklist should confirm the formats, the metadata included, and the configuration or schema material needed to make the export usable on the destination service, not just a raw dump that the customer cannot rebuild from.

- Require a written list of exportable data categories, digital assets, and the formats they will be delivered in.
- Clarify which provider-internal data is excluded and why, so the exclusion is not used to gut the export.

## When does the EU Data Act require functional equivalence rather than just a raw data export on switching?

Under the Data Act, functional equivalence applies to switching between services of the same service type, mainly IaaS, where the destination should deliver a materially comparable outcome after the customer has reconfigured the service. For PaaS and SaaS the obligation is the lighter duty to export the data and digital assets in a structured, commonly used, machine-readable format.

Procurement should establish which obligation applies to the service being bought, because expecting functional equivalence from a SaaS provider, or accepting only a raw export from an IaaS provider, both misread the Regulation.

- Classify the service type so the right export or functional-equivalence duty is applied.
- Confirm in the contract whether functional equivalence is owed and what reconfiguration the customer must do.

## What retrieval period and data erasure terms should a buyer require on cloud exit under the EU Data Act?

Under the Data Act, the contract should give the customer a minimum 30-day retrieval period to recover its exportable data after the switch is initiated, after which the provider erases the data unless a longer period is agreed or another legal duty applies. Procurement should make sure the retrieval window and the erasure trigger are both explicit.

A buyer should also confirm how erasure is evidenced, so it can show that the data left the old provider once the migration and any agreed retention period ended.

- Require at least a 30-day retrieval period and a clear erasure trigger in the contract.
- Ask how the provider confirms erasure after retrieval so the customer has evidence of deletion.

## How should procurement check interoperability and the open specifications a cloud provider relies on under the EU Data Act?

Under the Data Act, Article 30 expects providers of the same service type to support interoperability through open interoperability specifications and harmonised standards listed in a central repository, and Article 26 requires the provider to reference an up-to-date register of data structures, formats, and standards. Procurement should ask which standards the export actually uses.

The checklist should confirm that the supplier's stated formats and interfaces map to those open specifications, so the destination provider can ingest the data without a bespoke, supplier-controlled conversion.

- Ask which open interoperability specifications and harmonised standards the export and interfaces follow.
- Verify the online register reference is current and matches the formats offered at exit.

## Which cloud services fall outside the EU Data Act switching rules, and how should a buyer test the exemption?

Under the Data Act, custom-built services not offered at broad commercial scale and services supplied as a non-production test version are treated differently, and providers may claim that some Chapter VI duties do not apply. Procurement should require the supplier to state the exemption it relies on and the factual basis, rather than accepting a bare assertion.

A buyer should treat an exemption claim as a risk to price and document, because a service that genuinely sits outside the switching rules offers far weaker exit protection than a standard data processing service.

- Require the supplier to identify any exemption claimed and the factual reasons for it.
- Record the exemption decision and weigh the reduced exit protection in the procurement risk assessment.

## How should a buyer plan unbundling and parallel running when switching cloud providers under the EU Data Act?

Under the Data Act, switching should be technically feasible and the provider should support a managed transition, which in practice means a buyer can run the old and new services in parallel for a period and unbundle interdependent services where feasible. Procurement should ask how the supplier supports a phased cutover rather than a single hard switch.

The checklist should confirm the assistance, documentation, and continuity measures available during the overlap, so the migration does not force an all-or-nothing move that risks business continuity.

- Ask how the provider supports parallel running and a phased cutover during the switch.
- Confirm what unbundling of interdependent services is technically feasible and contractually supported.

## Which EU Data Act dates and triggers should a procurement team track across a cloud contract's lifecycle?

Under the Data Act, the core cloud-switching obligations apply from 12 September 2025, and switching charges must be removed by 12 January 2027, so procurement should track which obligations a contract already meets and which depend on a future date. A renewal or new signature is the moment to align the contract with the applicable date.

The team should also set event triggers, such as a change of service architecture or supplier documentation, so the contract is re-checked when the underlying service or the applicable obligation changes.

- Track the 12 September 2025 application date and the 12 January 2027 removal of switching charges.
- Set event triggers for architecture, format, or documentation changes that require a contract recheck.

## Primary sources

- [Regulation (EU) 2023/2854 (Data Act)](https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng?ref=sorena.io) - Binding Chapter VI source for cloud-switching obligations, written contract terms, timing, information duties, charges, interoperability, retrieval, erasure, and exemptions.
- [European Commission - Frequently asked questions about the Data Act](https://digital-strategy.ec.europa.eu/en/library/commission-publishes-frequently-asked-questions-about-data-act?ref=sorena.io) - Commission FAQ source for practical interpretation of Chapter VI, including service scope, exportable data, timing, charges, IaaS/PaaS/SaaS distinctions, and functional-equivalence limits.
- [European Commission - Data Act explained](https://digital-strategy.ec.europa.eu/en/factpages/data-act-explained?ref=sorena.io) - Commission explainer source for cloud-switching policy context, data egress charges, interoperability barriers, and Data Act application context.
- [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 voluntary model terms and standard contractual clauses that can support cloud-switching procurement clause review.

## 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 Contract Terms FAQ](/artifacts/eu/data-act/faq/cloud-switching-contract-terms.md): FAQ on EU Data Act cloud switching contract terms: Article 25 clauses, assistance, notice, transition, charges, export, termination, interoperability, and records.
- [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 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.

*Procurement review*

*Placement: after checklist section*

## Review Data Act cloud switching terms before signature

Turn supplier answers into a contract matrix covering Article 25 clauses, export evidence, switching charges, interoperability support, termination, retrieval, erasure, and renewal checks.

- [Open Research Copilot](/solutions/research-copilot.md): Ask cited questions about Data Act cloud switching, procurement clauses, export support, and supplier evidence.
- [Discuss cloud switching procurement](/contact.md): Review supplier gaps across contract terms, technical exit support, charges, interoperability, and evidence.


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