EU Data Act: what changes for law firms and businesses

Pursuant to Article 50 of Regulation (EU) 2023/2854, the Data Act applies from 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 design review 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.

The obligations under Chapter VI regarding the switching of data processing services apply from September 12, 2025, subject to the specific exception in Article 29(2), which sets January 12, 2027, as the deadline for the complete abolition of switching charges. Beyond that date, service providers may no longer impose economic or technical barriers to prevent 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 model contractual terms for data sharing. These tools are designed to protect small and medium-sized enterprises from unfair terms imposed by commercial partners with superior bargaining power. Once adopted, using these model terms will facilitate the drafting of compliant and secure agreements for managing corporate information flows.

Chapter V of the Regulation establishes the obligation for private businesses to make data available to public sector bodies in cases of exceptional need (B2G). Harmonized procedures enable the management of 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 a similar methodology using multiple AI agents that analyze legal matters, ensuring verified citations against official databases. Qualitative analysis of thousands of user queries confirms the necessity of automated tools to verify legal bases.

In Italy, the designation of competent national authorities and the framing of sanctions are being implemented via a legislative decree. AGCOM and the Data Protection Authority will be tasked with monitoring compliance with data portability and access obligations. Timely compliance is essential to mitigate legal and regulatory risks.

edit.legal addresses the demand for innovation through an advanced ecosystem that includes a Microsoft Word add-in and MCP servers for integration with Claude or Cursor. The platform offers a free trial without requiring a credit card, allowing users to test the effectiveness of AI across more than one million official documents.