What the rule says

Article 29 of the Data Act (Regulation (EU) 2023/2854) phases out charges for switching between providers of data processing services, including cloud. Until 12 January 2027 providers may charge reduced fees limited to their direct costs of the switch. From that date, summaries agree, no switching charges may be levied for the switching process, and the Commission's summary lists egress charges tied to switching among those that disappear.

The rule applies to every provider serving customers in the EU, including those based outside it.

Several sources, citing Commission guidance, stress two limits: ordinary operational egress, such as serving data to your own users, is not abolished, and for customers running services in parallel across providers, egress charges limited to cost remain allowed.

What customers should review

Start with an inventory of what you actually depend on: services, data stores, proprietary features, and formats. Then read your contracts for notice periods, transition terms, data export formats, and any fees described as switching or exit costs. Where terms conflict with the new rules, expect providers to update them, and ask when.

Do not wait for the date to find out how hard a move would really be. The cost of leaving is rarely only the egress bill; it is rebuilding integrations, retraining teams, and validating data.

Read exit and export terms

Check formats, timelines, and any charges described as switching or termination fees.

Test an export

Practice extracting a representative dataset and rebuilding it elsewhere to find the hidden cost.

What builders should design for

If you build products on cloud platforms, the best response is to reduce the effort of moving rather than to plan a move. Keep infrastructure defined as code, favor open data formats and standard interfaces, isolate provider-specific services behind your own interfaces, and document how to recreate the environment elsewhere.

This also helps with the EU's wider sovereignty agenda and with resilience obligations such as those in financial regulation.

Want an honest portability assessment of your cloud setup? Talk to our cloud team.

Key takeaways

  • From 12 January 2027 no switching charges may apply to the switching process under Article 29 of the Data Act; reduced cost-based fees apply until then.
  • The ban covers moving away; ordinary operational egress is not abolished, and parallel multi-cloud use can still incur cost-based egress charges according to Commission guidance cited by commentators.
  • Customers should inventory dependencies, read exit terms, and test an export.
  • Builders should reduce provider-specific coupling and keep infrastructure reproducible.
This is general information, not legal advice. Most sources are law-firm and vendor summaries; check Articles 29 and 34 of Regulation (EU) 2023/2854 and the Commission's FAQs.