The chapter of the Data Act that reaches an ordinary business first is not about connected products. It is about leaving your cloud provider: a two-month notice cap, a thirty-day transition, switching charges that disappear in January 2027, and terms about data that stop binding you when they are unfair.
The part that already applies
The EU Data Act has been in force since 12 September 2025. Most of what is written about it concerns data from connected products. The parts that reach an ordinary business first are somewhere else: the rules on moving from one cloud provider to another, and the rules that stop certain contract terms from binding you at all.
What your cloud contract now has to say
Your rights and the provider's duties when you leave have to be set out in a written contract, given to you before you sign, in a form you can keep. These numbers come from the Act itself and cannot be negotiated downwards.
| Term | What the law fixes |
|---|---|
| Notice to start moving | No longer than two months |
| Time to complete the move | No longer than 30 calendar days, with the contract still running |
| Time to collect your data afterwards | At least 30 calendar days from the end of the move |
| What you can take with you | A complete list of categories, covering at least all data that can be exported |
| Deletion | Guaranteed in full once the move is done and the collection period has passed |
While the move is happening, the provider has to help you properly, keep your business running, tell you about any known risks to that, and keep security tight throughout. Behind all of it sits a simple rule: obstacles to leaving — commercial, technical, contractual or organisational — have to be removed, not just priced.
The date that changes the economics
Exit fees are being phased out in two steps. Until 12 January 2027 a provider may charge a reduced fee, limited to the costs directly caused by that particular move. From 12 January 2027 no exit fee may be charged at all. So a fee schedule you agree today already has a date on which it stops being enforceable.
Unfair terms, between businesses
The Act does something business contracts rarely see. A term about access to and use of data, or about liability and remedies if data obligations are broken or the contract ends, which one company has imposed on another without negotiation, does not bind that other company if it is unfair — meaning its use departs grossly from good commercial practice, against good faith and fair dealing. A term that simply repeats what EU law requires is not unfair.
So “that is our standard form” is no longer the end of the conversation when the term is about data.
Which contracts this reaches, and when
The unfair-terms rules apply to contracts signed after 12 September 2025.
They reach older contracts from 12 September 2027, but only where the contract runs indefinitely or expires at least ten years after 11 January 2024. A fixed three-year contract from 2024 will have ended before this touches it; an open-ended one will not.
The rules about data from connected products apply to products put on the market after 12 September 2026.
Two things worth doing
Read your main cloud contract against the table above. If there is no exit clause, or the notice period is longer than two months, or there are fees that survive January 2027, the contract is behind the law — and renewal is the moment to fix it.
Ask for the complete list. “Your data” is not a specification. The categories have to be named, including what the provider intends to hold back and why.
Enforcement and penalties are set nationally, so which Latvian authority supervises which part of this is worth settling locally.