EU Data Act: what changes for law firms and businesses

Pursuant to Article 50 of Regulation (EU) 2023/2854, the Data Act applies fully as of September 12, 2025. However, the obligation regarding product design (accessibility by design) under Article 3(1) applies from September 12, 2026. Businesses must ensure that data generated by IoT products is accessible to users; this requires a structural review of product design so that information extraction occurs in real time and free of charge for the user, while allowing for reasonable compensation for making data available to third parties.

Obligations under Chapter VI regarding the switching of data processing services apply from September 12, 2025, subject to the specific exception under Article 29(2), which sets January 12, 2027, as the deadline for the total abolition of switching charges. Beyond that date, service providers may no longer impose economic or technical barriers preventing migration to other operators. This development enhances freedom of choice for professional firms seeking to optimize their digital infrastructure.

Pursuant to Article 41, the European Commission is required to develop official model contractual terms for data sharing. These tools are designed to protect small and medium-sized enterprises against unfair terms imposed by partners with stronger bargaining power. Once adopted, using these models will facilitate the drafting of compliant and secure agreements in managing corporate information flows.

Chapter V of the Regulation establishes the obligation for private entities to make data available to public sector bodies in cases of exceptional need. Harmonized procedures are in place to address public health emergencies or natural disasters through access to industrial data. Law firms must assist businesses in properly handling these requests to avoid sanctions or confidentiality breaches.

The Publications Office of the European Union has integrated AI systems into EUR-Lex to map the intersections between the Data Act, GDPR, and AI Act. Edit.legal applies the same methodology using multiple AI agents to analyze cases, ensuring verified citations against official databases. Qualitative analysis of thousands of real user queries confirms the need for tools that automatically verify the applicable legal bases.

In Italy, the designation of competent national authorities and the implementation of the sanctions framework are currently being finalized via an adapting legislative decree. AGCOM and the Data Protection Authority will be responsible for monitoring compliance with data portability and access obligations. Timely compliance is essential to mitigate future legal risks and administrative sanctions.

Edit.legal responds to the demand for innovation through an ecosystem that includes a Microsoft Word add-in and MCP servers for integration with Claude or Cursor. The platform offers a free trial with no credit card required, allowing users to test the effectiveness of AI across over one million official documents.