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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.

Cover page of the whitepaper “Data Act for manufacturers and operators of connected products: data access, contracts and cloud switching”

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.

Auch auf Deutsch erhältlich

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