For manufacturers and data holders, one of the most important practical issues under the Data Act is how to manage data access in relation to connected products and related services.
A key upcoming obligation is data access by design. Manufacturers need to consider whether they must change their products or services to enable users to directly access data. The answer depends on two concepts: technical feasibility and relevance.
If changes are technically feasible and relevant, the obligation will apply. If not, this may operate as an exception. Businesses need to assess whether changes are technically possible, what the costs would be, whether those costs are proportionate, and what impact changes may have on product security and safety.
These assessments ultimately sit with manufacturers. In practice, they will require input from finance, product, commercial and legal teams, because the question is not purely legal or technical. It is also about what is commercially viable for the business model.
Another major area is user requests. The new rights for users to access data mean that much of the day-to-day compliance work will sit with data holders. Organisations are approaching this from both a technical and process perspective. This may include developing or procuring APIs or other data export tools, as well as establishing internal workflows so that all relevant teams know how to respond when requests come in.
Multi-user scenarios are also attracting attention as an area of complexity. These arise where more than one person or organisation interacts with the same product or service. Examples include shared machinery in industrial environments or devices used by multiple tenants in residential buildings.
The challenge is how access and sharing rules apply where multiple users may have rights or interests in the same data. The Data Act acknowledges these scenarios, and the FAQs provide more detail, including a fleet management example involving a vehicle manufacturer, fleet operator and individual drivers.
The latest FAQs also refer to the concept of a data management system as a necessary measure, although detailed guidance remains limited. Businesses may need to consider account solutions, segregation of data and other mechanisms that allow users to exercise their rights without affecting the rights of others.
The detail remains open, so manufacturers and data holders will need to decide what is technically and commercially viable for their own products, services and operating models.
This article was compiled using insights from our recent webinar: EU Data Act 2026: The Year Compliance Gets Real. If you’d like to view the recording of this webinar, please do get in touch.
