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Data Act cloud switching checklist

EU Data Act cloud switching checklist for SMEs: vendor lock-in, exit terms, data portability, migration support, fees, security and evidence.

Direct answer

For Data Act cloud switching, SMEs should check exit terms, data export formats, migration support, lock-in risks, switching fees, deletion, continuity, security and responsibility split. The goal is to prove the business can move services without losing access, integrity or operational control.

What should SMEs check for Data Act cloud switching?

For Data Act cloud switching, SMEs should check exit terms, data export formats, migration support, lock-in risks, switching fees, deletion, continuity, security and responsibility split. The goal is to prove the business can move services without losing access, integrity or operational control.

  • Export format
  • Migration support
  • Deletion and continuity
Primary riskCloud lock-in
EvidenceExit plan and export test
Best ownerIT, operations or procurement
Source: European Commission Data Act guidanceReviewed:
Data Act cloud switching checklistEuropean Commission Data Act guidance

For Data Act cloud switching, SMEs should check exit terms, data export formats, migration support, lock-in risks, switching fees, deletion, continuity, security and responsibility split. The goal is to prove the business can move services without losing access, integrity or operational control.

Before renewalReview cloud contract

Cloud switching terms are easiest to fix before contract renewal.

Source: European Commission Data Act guidance

Data Act cloud switching checklist checklist

Action checklist
Export format

Confirm which data can be exported and in what format.

Migration support

Record provider support, timelines, cost and responsibilities.

Deletion and continuity

Define deletion proof, parallel run, rollback and downtime tolerance.

Key deadlines

DateRequirementSource
Before renewalReview cloud contractCloud switching terms are easiest to fix before contract renewal.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.

Data Act cloud switching

Days 31-60

Close the evidence gaps

Evidence needed: Policies, supplier records, data maps, technical notes, training records, or process owners.

Data Act cloud switching

Days 61-90

Prepare for audit or customer review

Evidence needed: Versioned compliance file, action log, exception register, and next review date.

Data Act cloud switching

Evidence to retain

Applicability decision

Shows whether Data Act cloud switching readiness 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

When should SMEs review cloud switching terms?

Before procurement, renewal or architecture changes, because negotiation leverage is weaker after lock-in.

What is the best cloud switching proof?

A tested export plus documented migration steps and deletion confirmation is stronger than a contract promise alone.

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.

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