From 12 January 2027, cloud providers can no longer charge EU customers for leaving. Under Article 29 of the EU Data Act, cloud switching charges, data egress fees for the switch included, drop to zero. Until that date, a provider may bill only what the switch actually costs it.
The timing is awkward. The deadline lands in the middle of renewal season, just as 2027 IT budgets are being locked in, so contracts signed this quarter will run under the new rules almost from day one. Before anyone signs, it helps to know what EU Data Act cloud switching covers and what it leaves alone.
EU Data Act 2027 timeline: what applies and when
The EU Data Act (Regulation 2023/2854) didn’t switch on all at once. The cloud switching rules have been live for over a year. What arrives in January is the end of the fees.
| Date | What happens |
|---|---|
| 11 January 2024 | The Data Act enters into force. Switching charges are allowed only at cost |
| 12 September 2025 | The Data Act applies, including the Chapter VI switching rules and mandatory contract terms |
| 12 January 2027 | Switching charges, including egress for the switch, are banned |
| 12 September 2027 | The rules on unfair contract terms between businesses extend to older contracts |
The scope is wider than many teams assume. “Data processing services” covers IaaS, PaaS and SaaS, not only infrastructure. If a business application runs in someone else’s cloud and holds your data, it is probably in scope.
Which cloud switching charges disappear, and which stay
The Data Act defines switching charges narrowly: fees, other than standard service fees or early termination penalties, that a provider charges for the switching process itself. Data egress for the switch counts. Most other line items on a cloud bill don’t.
| Cost | From 12 January 2027 |
|---|---|
| Egress and other fees for a one-off switch to another provider or on-premises | Banned |
| Egress for serving data to your own users and apps | Still charged |
| Egress between clouds used in parallel (multi-cloud) | Allowed, capped at the provider’s cost |
| Standard service fees during the notice and transition periods | Still charged |
| Early termination penalties | Allowed if disclosed in the contract up front |
So the regulation lowers the cost of leaving. It doesn’t lower the cost of running in the cloud. Anyone expecting the January deadline to cut the monthly egress line will be disappointed.
Data egress fees after 2027: five misconceptions
“Egress fees are banned from 2027.” Only egress tied to switching providers is. Data you send to customers, partners or other systems every day is billed as before.
“Multi-cloud becomes free.” Not quite. When you run workloads across two providers at the same time, Article 34 still lets a provider charge egress for that traffic, as long as the charge doesn’t exceed its costs. Some providers waive it voluntarily. The law doesn’t require them to.
“The fees end in September 2027.” The cut-off for switching charges is 12 January 2027. September 2027 is a different deadline: the unfair-terms chapter reaching contracts signed before the Data Act applied.
“We can leave next week.” The Data Act shortens the exit; it doesn’t make it instant. The provider can ask for up to two months’ notice, followed by a transition period of up to 30 days and a data retrieval window of at least 30 days. If 30 days is technically unfeasible, the provider has 14 working days to say so, justify it and propose an alternative of up to seven months.
“This is only about AWS, Azure and Google.” The hyperscalers dropped exit egress fees back in 2024, so their headline change is small. The bigger shift is often in SaaS contracts, where export formats, retrieval periods and exit support were rarely spelled out before.
Cloud contract checklist before 12 January 2027
A switching right that isn’t written into the cloud contract is hard to use in a dispute. These are the points worth checking with procurement and legal before the next renewal. Treat it as a working list, not legal advice.
- List every service in scope. Include SaaS, not just infrastructure. Note which contracts renew or can be renegotiated in the next six months.
- Find the switching clause. Check that it states a notice period of no more than two months, a transition period of up to 30 days, a retrieval period of at least 30 days and your right to extend the transition once.
- Separate the fees. The contract should show standard service fees, any early termination penalties and, until 12 January 2027, any cost-based switching charges as distinct items. Ask for a written commitment that switching charges fall to zero after that date.
- Define what you can take with you. Ask the provider to list the exportable data and digital assets, in which formats. Configurations, metadata and audit logs are where gaps usually appear.
- Time any planned migration. If you already plan to switch in early 2027, check with counsel whether starting the process after 12 January removes the remaining charges. On large data volumes the difference can be real.
- Price multi-cloud traffic separately. Egress between providers used in parallel stays billable. Model it as a running cost, not something the Data Act will remove.
- Run a test export. Pick one non-critical workload and pull its data out. A dry run shows more about portability than any contract clause.
Cloud exit strategy: switch, or renegotiate?
For most companies the January deadline won’t trigger a migration. It changes the negotiation. A provider that knows you can leave without a switching bill has less room to hold firm on price or terms.
That leverage only works if the exit is credible. A documented cloud exit strategy, with a target platform, an estimated timeline and a tested export, turns “we could move” into something procurement can put on the table.
The Data Act also removes only one layer of vendor lock-in. The contractual and egress barriers shrink. The technical ones stay: proprietary managed services, provider-specific tooling and the skills your team has built around one platform. Untangling those is closer to legacy system modernization than to a contract change, and it takes longer than a two-month notice period.
A practical middle path for 2027: renegotiate the contracts renewing now, and fund portability work, such as containerizing workloads and standardizing data formats, for the systems you’d most want to be able to move.
FAQ about EU Data Act cloud switching
When are cloud switching charges abolished?
On 12 January 2027. From then on, providers can’t charge for the switching process, including data egress for the switch. Until that date, switching charges are allowed only up to the provider’s direct costs.
Does the EU Data Act ban all data egress fees?
No. It bans egress charged for switching providers. Regular egress for serving your users stays billable, and egress between clouds used in parallel can still be charged at cost.
How long does cloud switching take under the Data Act?
Up to two months’ notice, then a transition period of up to 30 days and at least 30 days to retrieve your data. Where 30 days is technically unfeasible, the provider can propose up to seven months.
Does the Data Act apply to SaaS?
Yes. Data processing services include IaaS, PaaS and SaaS, so business applications hosted by a provider are generally in scope.
