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ARTICLE · 16 SEPTEMBER 2026

Who Holds The Data? The EU Data Act's Access By Design Rules Take Effect

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The EU Data Act introduces new access by design requirements for connected products and related services, fundamentally changing how IoT providers must handle product data accessibility. As the first anniversary of the Act's general applicability approaches, manufacturers and service providers face critical compliance deadlines that will reshape data access standards across the smart device market.

United KingdomTechnology
Alex Taylor
Alex Taylor
Richard Stebbing
Richard Stebbing
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The EU Data Act (Regulation (EU) 2023/2854) (the 'Act') came into force on 11 January 2024, before becoming generally applicable on 12 September 2025. The Act ushered in new rules for digital economy providers and users, primarily by granting users more control over data generated by 'smart' products and devices, whilst also adding additional flexibility around data switching and portability for customers of data processing services. 

To mark the first anniversary of the Act's general applicability, one of the deferred areas of the Act – the access by design rules for connected products and related services (Article 3(1)) comes into effect, applying to any connected products or related services placed onto the EU market after 12 September 2026. 

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