Does the EU Data Act make cloud switching free in 2027?

Yes, but only for standardized cloud services. Article 29 of the EU Data Act bans cloud switching and egress charges outright from 12 January 2027. Article 31 excludes any system that was built specifically for one customer, which describes most of what a software studio actually ships.

Checked against Regulation (EU) 2023/2854 and the European Commission's own Data Act explainer on 1 September 2026.

What does Article 29 actually ban, and from when?

Article 29 phases out switching charges over three years rather than banning them outright on day one. From 11 January 2024, a cloud provider could still bill a customer for leaving, but only for costs "directly linked to the switching process concerned": bandwidth for the transfer, engineer time, export tooling. Profit margin on top is not allowed, and never was.

Period	What a provider may charge
11 Jan 2024 to 12 Jan 2027	Cost-covering switching and egress charges only
From 12 Jan 2027	Nothing. Switching charges are banned outright

That second date is the one worth putting in a calendar. From 12 January 2027, a cloud provider cannot charge a customer to leave, full stop, for any standardized data processing service sold in the EU. Article 30 adds the other half: the provider has to supply documentation and technical support to make the move possible, not just cheap.

Didn't the big three already make switching free?

Google announced free data-transfer-out for customers switching providers in January 2024. AWS followed about two months later. Microsoft matched the offer on Azure a week after that. Every announcement named the Data Act as the reason.

None of the three changed their standard contract terms to do it. Each runs the waiver as a request: a customer opens a support ticket, the provider reviews the case, and a credit lands afterward if the request is approved. That is a company being generous ahead of a deadline, not the law taking effect early. A provider's blog post is not Article 29. The obligation that applies to every customer automatically, without a ticket or a review, only starts on 12 January 2027.

Which cloud services are exempt from the ban?

Article 31 carves out two categories, and the first one is the one that matters for a studio. A data processing service is exempt where most of its features were custom-built for one customer and the service is not sold commercially at scale. The second exemption covers non-production test environments.

A managed database tier that ten thousand companies buy off the same price list is exactly what Article 29 protects. askHermis and OFFSET are not that. We built askHermis to answer hotel guest messages, and OFFSET to file Greek short-term-rental declarations to the ΑΑΔΕ portal, and each runs on cloud infrastructure scoped for one workflow. Article 29 does not reach either of them, because neither was ever a shelf product.

The law protects the shelf product. It does not protect the one built for you.

Who does this help, and who is still on their own?

A company running its CRM or its email on a standard commercial tier gets a real, dated right: after 12 January 2027, leaving costs nothing beyond the transfer itself, and the provider has to help. That company can wait for the law.

A company that had an agent or a platform custom-built for its own workflow gets nothing from this article, because Article 31 was written to say so directly. Whatever exit terms that company has are whatever it negotiated before signing. Most contracts for custom software say nothing about exit costs, because nobody asked. Waiting for January 2027 to fix that does not work. The law was never going to.

What should you check before January 2027?

Two different actions, depending on which category a contract falls into. For a standard commercial cloud tier, confirm the provider's stated compliance plan for Article 29, and ignore anything that describes a 2024-era waiver program as if it already satisfies the law. For an agent or a platform custom-built on top of a hyperscaler, read the exit clause now. Article 31 means one might not exist, and the deadline that would have forced the question never arrives.

We have not yet had a client invoke Article 31 in a live negotiation, so this is a reading of the regulation's text against what providers have announced, not a story about how one responded when asked. If your contract already has an exit clause for a custom build, we would rather hear what it says than guess at the market norm.

Which of your cloud contracts leaves January 2027 out of the picture entirely, because the system on the other end was built only for you?