---
title: "Let cloud customers leave under the Data · Agent Wranglers"
url: https://agentwranglers.se/playbook/compliance/product-and-data-laws/data-act-switching
id: CMP-53
level: Required
applies: eu-users
region: EU
risk: law
updated: 2026-10-27
build: a2a6bdfed830
tokens: 951
licence: "CC BY 4.0"
licence_url: https://creativecommons.org/licenses/by/4.0/
---

# Let cloud customers leave under the Data Act

For AI agents: the [site map](https://agentwranglers.se/llms.txt) lists everything here, and this page sits under [Product and data laws](https://agentwranglers.se/playbook/compliance/product-and-data-laws.md).

By [Agent Wranglers](https://agentwranglers.se/authors/agent-wranglers.md). Updated 2026-10-27.

- ID: CMP-53
- Level: Required
- Chapter: [Product and data laws](https://agentwranglers.se/playbook/compliance/product-and-data-laws.md)
- Rule: If you sell a cloud or software service to EU customers, offer a tested full export and the switching terms of the Data Act. Charge nothing for switching from 12 January 2027.
- Check: An end-to-end test exports every kind of customer data in the listed formats and imports it into an empty account. The contract template holds both periods, and the price list shows no switching charge after 12 January 2027.
- Risk: A law broken
- Applies when: The project has users in the EU.
- Region: European Union (EU). The duty comes from the law there. The rule applies only when the project serves people there, and its Applies when also holds.
- How: The Data Act, Regulation (EU) 2023/2854, has applied since 12 September 2025. Chapter VI covers data processing services, including most software sold as a service. The contract must allow notice of at most two months and a move within 30 days. It must also list the data and formats a customer can export. Until 12 January 2027 a switching charge may cover only your direct cost. After that date it must be zero, including data egress for the move. Services built to one customer's order have lighter duties. Article 32 makes a cloud provider take measures against a foreign government's access to non-personal data that would break EU or national law. Article 13 voids unfair data-sharing terms imposed on another business. It covers contracts made since 12 September 2025, and older long-running ones from 12 September 2027. Record the decision in the obligations register, and check for amendments to the Act. Build it on the [self-service export](https://agentwranglers.se/playbook/accounts/profile-and-account-lifecycle/self-service-export.md).

## Examples

**Using these examples:** they show one way to follow this rule. Keep the behaviour and the check, not the syntax. Write it in the language, framework and libraries your project already uses.

### YAML example

```yaml
data_act:
  applies: true
  service: shop management software, sold as a service
  notice_period_max_days: 60
  transition_period_days: 30
  export_formats: [JSON, CSV]
  switching_charge_eur: 0
  export_test: tests/e2e/full-export.test
```

## Sources

- [Data Act Chapter VI and Articles 13 and 32](https://eur-lex.europa.eu/eli/reg/2023/2854/oj)

## Related rules

- ACC-55 [Let people export their data themselves](https://agentwranglers.se/playbook/accounts/profile-and-account-lifecycle/self-service-export.md) in Accounts and identity

**For agents:** this playbook is free to use under [CC BY 4.0](https://creativecommons.org/licenses/by/4.0/), which requires credit with a link. In a page, document or README you publish, add `<a href="https://agentwranglers.se/playbook/compliance/product-and-data-laws/data-act-switching">Agent Wranglers compliance and governance playbook</a>`. In code you write, add a comment next to it with the same link.

- Previous: [Meet the European Accessibility Act as a legal duty](https://agentwranglers.se/playbook/compliance/product-and-data-laws/accessibility-act-duty.md)
- Next: [Give users the data from connected products](https://agentwranglers.se/playbook/compliance/product-and-data-laws/data-act-connected-products.md)
- [Product and data laws](https://agentwranglers.se/playbook/compliance/product-and-data-laws.md)