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ARTICLE · 29 APRIL 2025

EU Data Act Preparedness–Last Minute Fire Drill Exercise

K&L Gates
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In less than six months, on 12 September 2025, most provisions of EU Regulation no. 2023/2854 (the EU Data Act) will go into effect.

United StatesCorporate/Commercial Law
Ulrike Elteste
Ulrike Elteste
Andreas Müller
Andreas Müller
Thomas Nietsch
Thomas Nietsch

In less than six months, on 12 September 2025, most provisions of EU Regulation no. 2023/2854 (the EU Data Act) will go into effect. In light of the challenging compliance efforts, from legal and contractual points of view as well as from operational and product development perspectives, affected companies should act soon to avoid liability and administrative fines and to update their contractual frameworks.

The below checklist provides initial level guidance to assist in companies in assessming their risk exposure and identifying mitigation steps.

While the EU Data Act covers many different data-related topics, topics that are most relevant for private companies are obligations regarding collection and use of Internet of Things (IoT) data (Section 1) and switching between cloud storage/service providers (Section 2).

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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