The Data Act turns one on September 12. Check your contracts first.

September 12 will mark one year since the EU Data Act became applicable, per the Commission's official page, bringing regulated switching rights, the wind-down of switching charges, and interoperability obligations to cloud contracts. The anniversary think pieces are inbound. More useful is the audit you can run before they land.

Three questions for your own paperwork. Whether contracts signed or renewed since last September actually reflect the Act's switching provisions, because legal reviews since application report uneven vendor compliance, and the terms you have are the terms you negotiated, not the terms the regulation imagines. Whether your exit-cost model still cites transfer fees that died in 2024, inflating the case against a move nobody has re-priced. And whether anyone has actually tested the export path for your critical data, because a right you have never exercised is a hypothesis.

The builder's read: regulation changed the contract, not the architecture. Portability remains something you build. The anniversary is a fine excuse to check which kind you have.