ARTICLE · 27 OCTOBER 2025
Market Intelligence Thought Leadership Award WinnerAction Required For Providers Of Connected Devices: Challenges Under The EU Data Act
The EU Data Act (Regulation (EU) 2023/2854), applicable as of Sept. 12, 2025, introduces a user‑centric access and sharing regime for both personal and non-personal data generated by IoT (Internet of Things) products, with a profound impact on how "data holders" design products, structure contracts, and monetize data.
The EU Data Act ( Regulation (EU)
2023/2854), applicable as of Sept. 12, 2025,
introduces a user‑centric access and sharing regime for both
personal and non-personal data generated by IoT (Internet of
Things) products, with a profound impact on how "data
holders" design products, structure contracts, and monetize
data. The Data Act shifts control of the data to the user,
including the right to use and to commercialize non‑personal
data. This is a paradigm change in EU data law with significant
implications across business sectors.
Broad Scope of Application
- Functional Scope: The new rules in Chapter II
of the Data Act apply to data generated by "connected
products." These include virtually any IoT device that
collects and transmits data such as smart home appliances,
connected vehicles, industrial machinery, and wearable devices. The
obligations also extend to "related services," meaning
digital services that are necessary for the product to perform
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