EuroComply
Zarejestruj się
Data Act

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 assetGenerated data inventory
Customer-facing outputData access and sharing process
Contract focusFair terms and cloud switching
Source: European Commission Data Act guidanceReviewed:

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.

OngoingRequest readiness

Data access workflows should be operational before users or partners request data.

Source: European Commission Data Act guidance

EU Data Act checklist checklist

Action checklist
Data categories

Identify raw, processed, inferred and user-generated data.

Access rights

Define request identity, eligibility, format, limits and timeline.

Trade secrets

Document protection measures where shared data could reveal confidential information.

Key deadlines

DateRequirementSource
OngoingRequest 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.

EU Data Act compliance for SMEsEU Data Act compliance for SMEs: connected products, user data access, B2B sharing, cloud switching, contracts and evidence checklist.Data Act cloud switching checklistEU Data Act cloud switching checklist for SMEs: vendor lock-in, exit terms, data portability, migration support, fees, security and evidence.GDPR checklist for SMEsA practical GDPR checklist for SMEs covering processing records, lawful basis, privacy notices, processors, DPIAs, DPO checks, DSARs and breach response.

Informational only. This page is not legal advice and does not replace a qualified legal review of your business, systems, products or employment practices.