2026 annual review · Editorial allocation: 10/2026. Added retrospectively on 13 November 2026. The allocation date is not the original publication date.
The Data Act changes switching conditions for covered data-processing services. Businesses should review export, transition and price components together.
Legal context
Article 29 of the Data Act removes switching charges for the covered switching process from 12 January 2027. Standard service fees and possible early-termination consequences need to be distinguished. A contract review should address actual obstacles, data formats and assistance, rather than merely deleting one fee clause. Assess scope and exceptions for the particular service.
Four practical examples
These illustrative scenarios are not reports of client mandates.
Export
A customer tests whether required data is available in the agreed format.
Price list
A supplier distinguishes switching costs from ongoing service fees.
Transition
A business plans parallel operation and responsibilities.
Specialised service
A complex service is assessed against the relevant statutory scope.
Preparing the next step
Preserve the relevant agreements, technical records and correspondence. Identify the decision required and any deadline. The legal assessment depends on the individual facts and applicable rules.