Complass
Data Act for manufacturers and operators of connected products: data access, contracts and cloud switching
An email from a customer who wants the data from his machines – and wants it passed straight on to an independent service partner. What the Data Act requires from manufacturers and which rights operators have.
The Data Act (Regulation (EU) 2023/2854) governs who may use data from connected products and related services, and on what terms. It has applied since 12 September 2025; the obligation to design data access into the product applies to products placed on the market after 12 September 2026.
The whitepaper opens with an email from a customer asking for his machine data and from there walks through roles and the SME exemption, timeline, data inventory, design for access, pre-contractual information, data access and the data use contract, sharing with third parties, trade secrets, fair contract terms, cloud switching, and supervision and penalties under the German implementing act. A separate chapter shows operators of connected machines their rights, followed by a 10-step plan and a checklist.
Each obligation chapter includes a short "Implementation in Complass" box; only features already live are named.
16 pages · Version 1.0 · as of 06.10.2026 · Author Marc Linden, Complass GmbH i. G.
Try Complass with your own data
Set up your trial yourself, with a sample project per framework if you like. If you would rather see Complass first, request a demo.