Key compliance deadline
The 12 September 2026 EU Data Act deadline explained
From 12 September 2026, connected products and related services newly placed on the EU market must let users access the data they generate by design and by default — not only on request. This guide explains what changes, who it affects and how to prepare.
What changes on 12 September 2026?
This is the date the Data Act's "access by design" obligation (Art. 3(1)) starts to apply. Connected products — and their related services — placed on the EU market after 12 September 2026 must be designed and manufactured so that the data they generate is, by default, easily, securely and, where relevant and technically feasible, directly accessible to the user.
In practice the data should be available to users continuously and in real time, in a structured, commonly used and machine-readable format, and free of charge. Access can no longer be bolted on only when someone asks — it has to be built into the product from the start.
How is this different from September 2025?
The Data Act became generally applicable on 12 September 2025. From that date, data holders already have to make product data available to users on request, and the cloud-switching rules apply.
12 September 2026 raises the bar for newly marketed connected products specifically: access must be designed in from the outset, not just provided reactively. Products placed on the market before that date are not caught by the design obligation, though the on-request access rules still apply to them.
Who does the deadline affect?
- Manufacturers of connected products placed on the EU market — regardless of where the manufacturer is established.
- Providers of related services — apps, dashboards, monitoring and management software — linked to those products.
- Businesses designing new IoT devices, vehicles, machinery, smart appliances or sensors for launch after the deadline.
- Importers and distributors bringing connected products into the EU market.
- Product, engineering and legal teams making design decisions now for 2026 launches.
The bigger picture
EU Data Act key dates
11 January 2024
The Data Act (Regulation (EU) 2023/2854) entered into force.
12 September 2025
Most obligations became applicable, including on-request data access and cloud-switching rules.
12 September 2026
The access-by-design obligation applies to connected products newly placed on the EU market (Art. 3).
12 January 2027
Switching charges, including data egress fees, are fully prohibited (Art. 29).
Preparing now
How to get ready before September 2026
Map your data
Document what data each connected product and related service generates, and which of it users are entitled to access.
Design access in
Build default, real-time access routes — dashboards, APIs or exports — into products slated to launch after the deadline.
Protect trade secrets
Put safeguards in place so required access does not expose trade secrets or compromise security.
Update pre-sale information
Prepare the pre-contractual information users must receive about what data the product generates and how to access it.
Check your exposure
See where your products stand
Answer a few questions for a free indication of how ready your connected products are for the 12 September 2026 deadline.