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LAWIT Law × Technology × Business

LAWIT / CHANGES / TECH / DATA ACT / UPDATED 12 October 2026

Changed12 Sep 2026

Data Act: data access “by design” for new connected products

Connected products placed on the market after 12 September 2026 must make data directly available to the user.

AWhat changed

Regulation (EU) 2023/2854 (Data Act) mostly applies from 12 September 2025. The obligation to design connected products and related services so that data are available to the user by default and directly (Article 3(1)) applies to products placed on the market after 12 September 2026.

BWhen

From 12 September 2026 (Article 3(1)). Further milestones: 12 January 2027 (ban on cloud switching charges), 12 September 2027 (unfair contractual terms also for older contracts).

CWho it affects

  • Manufacturers of connected (IoT) devices and providers of related services.
  • Providers of cloud and data processing services.

DWhat to do

  • For new products, check that users can access the data without unnecessary obstacles.
  • Review your contract terms with B2B partners regarding data sharing.

Explanation

The Data Act is a regulation — it applies directly, without a Slovak transposing act.

Sources

  1. Regulation (EU) 2023/2854 (Data Act) — EUR-Lex
  2. Bird & Bird: The EU Data Act — where things stand now

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