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Data Act and cloud switching: can I switch cloud providers more easily?

Adopted 2026-06-14 ยท ≈ 1 min read ยท Dirk Baaijen

Yes. The Data Act (Regulation (EU) 2023/2854), applicable since 12 September 2025, makes switching between cloud and data-processing services easier through mandatory switching support and a ban on unfair contract terms.

Short answer: Yes, switching between cloud services becomes easier. The Data Act requires providers of data-processing services to support switching to another provider and bans contract terms that lock you in unfairly.

What does the Data Act regulate?

The Data Act is Regulation (EU) 2023/2854 and has been applicable since 12 September 2025. It governs access to and the sharing of data from connected products and related services. The user is central: that is the owner, renter or lessee of such a product. For a transport and logistics organisation this touches, among other things, vehicle telematics, sensors in cargo and the cloud platforms in which that data is processed and stored.

Data sharing is subject to FRAND conditions: fair, reasonable and non-discriminatory. In addition, the Data Act prohibits unfair contract terms that are unilaterally imposed. Where the data contains personal data, the GDPR continues to apply in full alongside these rules.

What does this mean for cloud switching?

The Data Act makes switching cloud services โ€” and more broadly, data-processing services โ€” explicitly easier. Providers must support the move to another provider and may not lock you in with unfair terms. The aim is that you can take your data and applications with you, so that lock-in decreases and you retain freedom of choice over where your logistics data is processed.

What should you watch for?

Review your current contracts with cloud and platform providers for terms that hinder switching or that are not FRAND. Note that from 12 September 2026 a design obligation applies to new connected products: they must be designed so that data is accessible. If your transport and logistics chains process personal data, align your Data Act approach with your GDPR obligations.

Read the main file: Data Act for transport & logistics. Or take the Transport & Logistics scan.

Sources

  1. https://eur-lex.europa.eu/eli/reg/2023/2854/oj
    Regulation (EU) 2023/2854 (Data Act); applicable since 12 September 2025.

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Dirk Baaijen

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