Article 29 bars cloud switching charges from 12 January 2027, but other fees stay

Moving data out of a cloud provider can carry charges, and the EU Data Act's switching rule addresses charges for the switching process. The Act, Regulation (EU) 2023/2854, governs how customers switch between providers of data-processing services. The European Commission says it applies from 12 September 2025, after entering into force on 11 January 2024.

The key date for switching charges is 12 January 2027. Until then, providers may still charge for switching, but only reduced fees capped at the costs of the switch. From that date, Article 29 bars providers from imposing charges on the customer for the switching process. The rule covers charges for the switching process itself, and it does not ban other service fees.

What Article 29 allows until 12 January 2027

The Commission describes the Act as creating a framework for customers to switch between providers of data-processing services. Article 29 is the part that deals with money. It sets a transitional period that began on 11 January 2024. During it, providers may impose reduced switching charges, but those may not exceed their costs directly linked to the switching process concerned.

Because the figure is a ceiling, a reduced charge can be lower than the cap but not higher. Article 29 addresses charges for the switching process itself, and it does not cap or ban other service fees.

From 12 January 2027, providers may not impose charges on the customer for the switching process. That date ends the transitional period and removes the option of reduced fees for the switch.

The disclosure duties before a contract is signed

Before a contract is concluded, providers must disclose their standard service fees and any early termination penalties. Where reduced switching charges apply during the transition, those must be disclosed too.

Where relevant, providers must also tell customers about services that involve highly complex or costly switching, or switching that cannot happen without significant interference with data, digital assets or service architecture. Where applicable, that information must be publicly available.

Article 29 also allows the Commission to adopt delegated acts that create a monitoring mechanism for switching charges.

How AWS, Microsoft and Google have set their exit terms

AWS has updated its page on free data transfer out when moving off its service, referencing the Data Act. The page gives eligible customers outside the EU 180 days to complete a move, and says anyone who needs more than 180 days must notify AWS Customer Support immediately. EU customers are directed to the process in the AWS EU Data Act Addendum, section 2.3.

The page also records that, from 30 September 2025, AWS dropped a condition that required contacting support for transfers above 100 GB a month.

Microsoft's exit waiver, reported by CIO Dive in March 2024, covers data sent over the internet to another cloud or to an on-premises site. Under the terms reported then, customers had to cancel their Azure subscriptions and complete the move within 60 days. Azure Support applied the credit only after the transfer finished and every linked subscription was cancelled.

CIO Dive reports that Microsoft referenced the EU Data Act in announcing the change. Those are the 2024 terms, and current Azure conditions are not confirmed in this article.

Google Cloud announced Data Transfer Essentials on 10 September 2025. It offers no-cost transfers between Google Cloud and other cloud providers for customers in the EU and UK. Customers opt in by following a configuration guide. Qualifying traffic appears at zero charge on the bill, while other traffic is billed at existing Network Service Tier rates.

The qualifying traffic covers workloads of one organisation that are distributed across two or more clouds and processed in parallel. Google says it is not passing through costs for this service, even though the Act permits providers to pass them on.

Dates and contract points for enterprise customers

Three dates frame the rule. The transitional period opened on 11 January 2024. The Act applied from 12 September 2025. Switching charges become prohibited on 12 January 2027. The Commission's page lists a draft recommendation on non-binding model contractual terms for data access and use and on non-binding standard contractual clauses for cloud computing contracts. Its page gives no date for that draft.

The AWS and Microsoft exit windows differ. AWS's current text gives eligible non-EU customers 180 days, while Microsoft's 2024 terms gave 60 days. AWS and Microsoft also attach conditions to their windows. AWS asks customers who need more time to notify AWS Customer Support, and Microsoft's terms required subscription cancellation before the credit was applied.

Under Article 29, standard service fees and early termination penalties must be disclosed before signing. A customer comparing providers can look at those disclosures alongside each provider's exit terms.

What remains open for European and US providers

This article does not cover how European cloud providers have set their own switching terms, so it makes no comparison between them and the three US providers.

Its page sets 180 days for eligible non-EU customers, and the terms for EU customers sit in the addendum, which this article does not summarise.