🇪🇺 Regulation (EU) 2023/2854
Data access and portability obligations for connected products, covering access by design, user data sharing and cloud switching.
Book a free consultation →The EU Data Act (Regulation (EU) 2023/2854) brings new data obligations for connected products: users must be able to access the data their product generates, share it with third parties, and switch between cloud services — with "access by design".
We help determine whether your product is in scope, verify the Art. 3 access-by-design requirement, and compile the user information disclosure checklist and technical evidence.
The Data Act applies from 12 Sep 2025, with obligations phasing in.
User data access and portability are the new compliance focus.
Access by design needs verifiable technical and documentary evidence.
Clarify the product type, target markets and applicable clauses, and define the tests and documents needed.
Map the product's current state to the standard's requirements and produce a gap analysis.
Run the test plan and process audit; add penetration testing and fuzzing where needed.
Consolidate results and evidence, map each item to a clause, and form an auditable record.
Deliver the report and improvement recommendations; for markets that require filing, help prepare the submission.
Tell us the product type and target markets and we will come back with the applicable clauses, test scope and timeline.