What Does Cloud Switching Under The Data Act Require Of Providers Selling To The Public Sector?

In brief

• Chapter VI of the EU Data Act sets binding rules for cloud switching. Customers can give at most two months’ notice, the transition must be completed within 30 days, and customers have at least 30 days to retrieve their data.
• From 12 January 2027, providers may no longer charge switching fees, including data egress fees, to customers in the EU.
• The rules have applied since 12 September 2025 and cover every provider serving customers in the EU, wherever the provider is established. Public bodies in Sweden, Denmark and Finland are protected as customers today.
• The Data Act has not yet been incorporated into the EEA Agreement, so it does not yet apply in Norway or Iceland. Norwegian public buyers are nevertheless moving in the same direction.