ConfirmedEU-wideData Act

Data Act: new connected products must be designed for user data access (access by design)

5 days from today

Date note: Data Act generally applicable since 2025-09-12; Article 3(1) design duty applies to products and related services placed on the market after 2026-09-12

What changes

Connected products (IoT devices, machines, vehicles, smart appliances) placed on the market from this date must be built so that the data they generate is easily, securely and free of charge accessible to the user, directly on the device where feasible. Since September 2025 users can already request their data and share it with third parties, and pre-contract information about generated data is mandatory.

Who is affected

Medium and large manufacturers of connected products and providers of related services (micro and small manufacturers are exempt from the data-sharing duties as data holders); all businesses that buy connected products gain access rights.

Sizes: medium, large · Sectors: Hardware / electronics, Manufacturing, Software / SaaS, Energy, Transport / logistics, Agriculture / food · Applies if: We make connected hardware / devices; We rely on cloud services; We process personal data

What to do

For products in development, add an export/API path for product data and metadata and document it. Update sales terms with the pre-contract information on data types, volume, storage and access. Set up a process to handle user and third-party data requests and fair (FRAND) terms for B2B sharing.

Penalty

Set nationally; GDPR-level fines where personal data is involved

Sources

Last verified 7 September 2026. Informational only, not legal advice.

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