Practical checklist
EU Data Act Compliance Checklist
Use this checklist as a starting point to identify whether your products, services, contracts or internal processes may need review under the EU Data Act.
1. Identify your connected products and services
- List any connected products you manufacture, sell, lease or operate.
- Identify any related digital services, apps, dashboards or monitoring tools.
- Map what data is generated by each product or service.
- Separate personal data, non-personal data, machine data, sensor data and usage data where possible.
2. Review user data-access rights
- Check whether users can access data generated by their use of a connected product.
- Review whether users can ask for that data to be shared with a third party.
- Document how requests will be received, verified and handled.
- Check whether data can be made available securely and in a usable format.
3. Review B2B data-sharing contracts
- Identify contracts that restrict access to or use of generated data.
- Check whether data-sharing terms are fair, transparent and proportionate.
- Review compensation or pricing mechanisms for making data available.
- Pay particular attention to contracts involving SMEs.
4. Review cloud and data-processing services
- Check whether you provide cloud, SaaS, hosting, platform or data-processing services.
- Review customer switching and exit processes.
- Check whether technical, contractual or commercial barriers make switching difficult.
- Document export formats, migration support and termination processes.
5. Prepare internal processes
- Assign ownership for Data Act requests inside your business.
- Create a simple request-handling workflow.
- Review security, confidentiality and trade-secret safeguards.
- Prepare standard responses for customers, business users and third parties.
Important: This checklist is for general information only. It is not legal advice. Businesses with potential exposure should seek legal or compliance advice.
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