EU Data Act checklist
EU Data Act checklist for SMEs: connected product data, user access, third-party sharing, cloud switching, contract terms and evidence.
Direct answer
An EU Data Act checklist should cover connected-product data, related-service data, user access, third-party data sharing, trade secret protection, unfair contract terms, cloud-switching provisions, public-sector access scenarios, and evidence showing how data requests are handled.
What should be on an EU Data Act checklist?
An EU Data Act checklist should cover connected-product data, related-service data, user access, third-party data sharing, trade secret protection, unfair contract terms, cloud-switching provisions, public-sector access scenarios, and evidence showing how data requests are handled.
- Data categories
- Access rights
- Trade secrets
| Primary asset | Generated data inventory |
| Customer-facing output | Data access and sharing process |
| Contract focus | Fair terms and cloud switching |
An EU Data Act checklist should cover connected-product data, related-service data, user access, third-party data sharing, trade secret protection, unfair contract terms, cloud-switching provisions, public-sector access scenarios, and evidence showing how data requests are handled.
Data access workflows should be operational before users or partners request data.
EU Data Act checklist checklist
Action checklistIdentify raw, processed, inferred and user-generated data.
Define request identity, eligibility, format, limits and timeline.
Document protection measures where shared data could reveal confidential information.
Key deadlines
| Date | Requirement | Source |
|---|---|---|
| Ongoing | Request readinessData access workflows should be operational before users or partners request data. | European Commission Data Act guidance |
30/60/90-day action plan
First 30 days
Confirm scope and assign an owner
Evidence needed: Applicability note, business owner, systems or product list, and source links.
EU Data Act checklist
Days 31-60
Close the evidence gaps
Evidence needed: Policies, supplier records, data maps, technical notes, training records, or process owners.
EU Data Act checklist
Days 61-90
Prepare for audit or customer review
Evidence needed: Versioned compliance file, action log, exception register, and next review date.
EU Data Act checklist
Evidence to retain
Applicability decision
Shows whether a Data Act checklist applies and why the SME made that decision.
Retain: Scope memo, trigger criteria, country notes, owner approval, and review date.
Action owner list
Regulators and enterprise customers expect named accountability, not generic intent.
Retain: Owner, backup owner, due date, status, and unresolved blocker notes.
Evidence folder
The fastest way to answer customer due diligence is a single audit-ready evidence file.
Retain: Policies, screenshots, registers, exports, supplier responses, and training records.
SME questions answered
What is the core Data Act evidence file?
A data inventory, access workflow, sharing contract terms and cloud-switching terms form the core evidence file.
How does the Data Act interact with GDPR?
The Data Act does not remove GDPR duties. Personal data sharing still needs GDPR-compatible handling.
Turn this guide into a tracked action plan
Start with the Regulation Checker, save the result, and import the action plan into your EuroComply dashboard when you are ready to assign owners.
Informational only. This page is not legal advice and does not replace a qualified legal review of your business, systems, products or employment practices.