EU Data Act Connected Products Compliance Check

Why this matters

The EU Data Act became applicable from 12 September 2025, giving any business or consumer user of a “connected product” — smart appliances, wearables, connected machinery, vehicle telematics, IoT sensors and similar internet- or Bluetooth-connected devices — the right to demand access to the data that device generates, including requiring it to be shared with a third party of their choosing. From 12 September 2026, a further design obligation takes effect: connected products and their related services (apps, dashboards, cloud portals) placed on the EU market must be built so that users can access their own product data directly, easily, securely and free of charge, in a structured, commonly used, machine-readable format, without needing to submit a request — wherever this is relevant and technically feasible. The Act applies extraterritorially: any UK manufacturer or service provider placing connected products on the EU market, or serving EU-based users, is in scope regardless of where the business itself is established.

Alongside the connected-product rules, the Data Act also renders certain unfair contract terms in business-to-business data-sharing agreements unenforceable, and introduces new rights making it easier for businesses to switch between cloud and data-processing service providers. For a UK business exporting smart devices, connected equipment, or software tied to physical products into the EU or Northern Ireland, non-compliance risks enforcement by EU member state authorities, contractual disputes with EU distributors and customers, and reputational damage with commercial partners who are themselves required to check their supply chain’s compliance. With the design-by-default obligation landing on 12 September 2026, businesses that only handled ad hoc data-access requests over the past year now need product-level changes in place.

What you'll need

• Whether your business manufactures, sells, or licenses connected/IoT products or related services (apps, dashboards) into the EU or Northern Ireland
• Whether you currently have a mechanism for users to request or access data generated by your product
• Any business-to-business data-sharing contracts you hold with EU-based suppliers, distributors or customers
• Whether your products are sold directly or via third-party EU marketplaces/distributors

What you'll get

A personalised compliance report covering: a score out of 100, an executive summary, a list of findings ranked by severity, and a prioritised action plan with timeframes.