EU Data Act: Field guide for legal, IT & operations and Precisely’s alignment

Key Dates for EU Data Act: 11 January 2024: Regulation entered into force. 12 September 2025: Main obligations are now applicable: switching rights, interoperability, transparency. 12 January 2027: Switching and egress fees prohibited.

Why This Matters

The EU Data Act is now fully in effect. It strengthens customer rights to switch between cloud services, access their own data, and benefit from interoperable systems. For organisations that rely on cloud-based contract management, this regulation has direct implications: your CLM vendor must be able to support data portability and switching rights, and you need contracts with cloud providers that reflect the Act’s requirements.

This sits alongside a broader set of EU data regulations shaping how organisations manage contracts and data. For GDPR-specific contract requirements, see GDPR & Contract Management: 6 Must-Have Features. For the implications of the EU AI Act on AI-enabled contract tools, see The EU AI Act: What We Know So Far. For Precisely’s approach to data sovereignty and EU hosting, read Why Data Sovereignty Matters for Contract Management and What It Means for AI.

Implications for contract management

The EU Data Act requires that contracts with cloud service providers include provisions on: data access and portability, switching rights and exit procedures, interoperability standards, and transparency about where data is processed and stored. Organisations that manage these vendor contracts through a CLM platform can enforce clause standards systematically, ensuring compliance is built into the contract creation process rather than checked manually after the fact.

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You may be wondering...

What is the EU Data Act and when does it apply?
The EU Data Act is a regulation strengthening user rights to access and switch between data services, including cloud platforms. Its main obligations became applicable in September 2025. For organisations using cloud-based contract management, it has direct implications for data portability, switching rights, and contract terms with cloud vendors.
What should organisations check in their CLM vendor contracts under the EU Data Act?
Organisations should confirm that CLM vendor contracts include provisions for data portability, exit assistance, and interoperability. They should also check that contracts with cloud providers include required switching and egress terms, particularly as egress fees become prohibited from January 2027.
How does the EU Data Act affect CLM vendors?
CLM vendors operating in the EU must support data portability — customers must be able to export their contract data in a usable format. Vendors must also respect switching rights and cannot impose unreasonable barriers when a customer moves to a different platform.
How does the EU Data Act interact with GDPR?
GDPR governs how personal data is processed and protected. The EU Data Act governs access rights and portability for all data. For organisations managing contracts in the cloud, both regulations apply simultaneously.
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