Compliance dates · 12 September 2026 · EU
Data Act access-by-design binds connected products placed on the market after 12 September 2026
Connected products and related services placed on the EU market after 12 September 2026 must be built so users can get at product and related service data directly. The data has to arrive in a structured, machine-readable format.
This is a design duty rather than a paperwork duty. It reaches the product itself, which means the decision that satisfies it is taken well before the product ships. The duty names products placed on the market after 12 September 2026, which makes the placing date the first thing to establish for any product line.
Makers of connected products and related services
Manufacturers and providers of connected products and their related services, from IoT devices to industrial machinery. The date attaches to when the product goes on the market, so a product placed after 12 September 2026 is caught.
Design decisions to settle first
- List the connected products and related services you plan to place on the EU market after 12 September 2026.
- For each one, work out what product and related service data it generates.
- Build the direct user access route into the product rather than around it.
- Fix the structured machine-readable format the data comes out in.
- Record the design decision and the date the product was placed on the market.
The Data Act system
Access-by-design is a Data Act duty, and the Data Act system covers the Regulation it comes from.
Data Act £1,500
Data access and sharing obligations for connected products and related services.
Regulation (EU) 2023/2854 · European Union
Verified 19 August 2026.