Data Act cloud switching charges and exit

This screen looks only at switching charges, egress charges for switching, contract terms, a 30-calendar-day transition, export and open interfaces, IaaS functional equivalence, multi-provider obstacles, and an exit procedure. It does not replace a general Data Act readiness review.

Transition period

From 12 January 2027 a provider must not impose a charge for the switching process. Before that date a reduced charge may remain only when it is limited to cost directly incurred for switching. Standard recurring service fees and early termination penalties stay separate.

Switching charges

A switching charge is the charge for the switching process. A disclosed standard service fee, by itself, is not treated as that charge.

Switching charges

A data egress charge imposed so that the customer can switch is kept in the same charge review. It is not mixed with an ordinary service fee.

Transition period

The written contract has a maximum transitional period of 30 calendar days, subject to the statute's own conditions. A longer period that is not aligned is a contract gap.

SaaS / PaaS

For SaaS or PaaS, export of exportable data and digital assets uses an open interface and, where applicable, a commonly used machine-readable format. A missing export or a missing open interface is its own gap.

IaaS

For IaaS, functional equivalence covers shared functions when the customer switches to the same service type. A missing equivalence measure is a technical switching gap.

Multi-provider use

The customer should be able to use more than one provider at the same time, or move to on-premises infrastructure, without a prohibited obstacle. An obstacle is a review, not a finding that the contract fails every other test.

Contract disclosure

The contract states the switching rights, the provider's obligations, standard fees, early termination penalties, and any reduced switching charge that still applies before 12 January 2027.

Examples

On 1 February 2027 a switching charge is still imposed: switching-charge removal required.
On 1 December 2026 a switching charge is imposed and it is not limited to directly incurred cost: transitional charge review.
SaaS is used and a machine-readable export is missing: data portability gap.
IaaS is used and functional equivalence is missing: technical switching gap.
The applicable controls are present. That does not establish Data Act compliance.

Limits

This does not establish Data Act compliance. There is no numeric score. The screen does not decide that a charge is lawful, and it does not invent duties beyond Articles 23 to 27, 29, and 30. Later Commission guidance is a manual review.

Data Act cloud switching charges and exit