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Innopulse Consulting

Data Act readiness for manufacturers and SaaS providers

Manufacturers of connected products, providers of related services, and cloud and SaaS providers with customers in the EU, including those based in Switzerland.

Updated: 2026-11

In short

The EU Data Act has applied since 12 September 2025. Manufacturers of connected products must give users access to the data generated, and for new products from 12 September 2026 this must be built into the design. Cloud and SaaS providers must enable switching, and switching charges disappear from January 2027. We get products and contracts ready.

The Data Act is not a data protection law but a law on access to and use of data. It affects companies that have dealt little with data law so far: machine builders, device makers, app providers for connected products and every SaaS provider that must allow customers to switch.

The duties are technical and contractual: data export, interfaces, pre-contractual information, switching processes and deadlines. Without preparation they are tackled under time pressure when the first customer asserts its rights.

What you get

Applicability by role

Classification as manufacturer, provider of a related service, data holder or provider of a data processing service.

Data inventory

Which product and service data arise, which must be made available and in what form.

Technical concept

Data access for users and third parties, export and switching, aligned with data protection and trade secrets.

Contract and information templates

Pre-contractual information and clauses on data access and switching, for review by your legal advisers.

How it runs

  1. 01

    Roles

    Go through products and services and define roles under the Data Act.

  2. 02

    Inventory

    Capture data types, storage locations and existing export options.

  3. 03

    Concept

    Design the technical solution for access and switching, protecting trade secrets and personal data.

  4. 04

    Delivery

    Build or support interfaces and exports, finalise templates, set up request handling.

Price framing

Readiness analysis with fixed scope per product or service group; technical implementation priced separately after the concept.

Indicative, not a binding quote — the frame is confirmed during scoping.

Parent service: Compliance assessment

FAQ

Does the Data Act apply to Swiss companies?

For connected products and services offered in the EU, yes, regardless of where the manufacturer or provider is based.

What changed on 12 September 2026?

Connected products and related services placed on the market from that date must be designed so that users can access their data easily and securely.

Does the Data Act also cover pure software?

Yes, if it is offered as a data processing service, such as a cloud or SaaS service. Then the rules on switching providers apply.

LM
Reviewed by
Founder & CEO · MSc Innovation Management (FFHS) · PMP · IREB CPRE · Author of “Identity Over Discipline”
Mandates incl. EDA, MeteoSwiss, FSO, SERI, FINMA, Swisscom and BLS
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Data Act readiness for manufacturers and SaaS providers

Manufacturers of connected products, providers of related services, and cloud and SaaS providers with customers in the EU, including those based in Switzerland.