Deloitte Legal Update 07/2026 – The EU Data Act and Cloud Switching

The EU Data Act has applied directly in all Member States since 12 September 2025 and significantly reshapes the rules for certain data processing services. The new requirements affect contracts relating to certain cloud services in the area SaaS, PaaS and IaaS. Their aim is to reduce lock-in effects and facilitate switching between providers.

For providers, this means that technical, contractual and organisational barriers to so-called cloud switching must be removed. For customers, the key question is what rights they will have in the context of switching providers, terminating contracts and migrating services and data.

The topic is therefore relevant for almost every company – both on
the provider side and on the customer side.

Our webcast

In our webcast, our experts Christopher Bösch (IT Law) and Martin Geber (Cloud & Data Migration) will provide you with a concise overview of the new requirements of the EU Data Act and their practical implications for contracts, cloud strategies, and compliance processes.

What to expect:

• Scope of application of the EU Data Act – which services and companies are affected
• Cloud switching in practice – process, requirements and typical hurdles when changing providers
• Obligations for providers of data processing services – technical, contractual and organisational
• Customer termination rights – in particular in relation to existing and new contracts
• Switching charges and early termination fees – what will no longer be permitted and what may remain possible
• Exemptions and current developments – including potential changes under the Digital Omnibus Regulation
• Technical requirements and sourcing strategies – what companies should now prepare from an organisational and contractual perspective.
   

Your benefits:

• Practical insights into how the EU Data Act affects cloud contracts
• Concrete recommendations for both providers and customers
• Guidance for reviewing and adapting existing contract frameworks
• Direct answers to your questions during the Q&A session.
  
  

Who should attend?

• Legal departments and compliance officers
• Providers of data processing services, particularly SaaS, PaaS and IaaS providers
• Procurement, IT, sourcing and vendor management professionals
• Data protection and digital transformation professionals
• Anyone dealing with the new cloud switching requirements and their practical implications.

Your questions are welcome!

Following the presentations, the speakers will be available for an
extensive Q&A session.

Please feel free to submit your questions already as part of your
registration so that we can address them in a targeted and practical manner. Of
course, spontaneous questions during the webcast are also very welcome.


We look forward to welcoming you on 29 April 2026!

Reach out!