Europe’s EU Data Act is now applicable, so let's crank up the pressure. If you still face “data extraction fees”, why not put your vendor on the spot?
Following on from our thrilling previous instalments, the EU Data Act is now live. This briefer piece will provide you with some copy-pastable email templates you can use to reach out to your Archive Vendor and see how seriously they are taking the new mandates and broader culture around data ownership.
Cost‑only now; zero by January 12, 2027. Providers must already limit any switching/egress charges to their direct costs (no overheads, no margin).
Switching follows a notice period (max 2 months) and a transition period (max 30 calendar days). An extension is allowed only if the provider proves - within 14 days during the notice period - that 30 days is technically unfeasible (absolute max 7 months).
You’re entitled to all exportable data (input, output, metadata) and the digital assets (configs, access‑rights, VMs/containers where relevant) you need to use that data after the switch - via open interfaces and in structured, commonly used, machine‑readable formats.
👉 Throughout the series, we showed how extraction fees hit $50/GB ($50k/TB) and how markups can top a stunning 55,000%!
That era is ending.
Who wants to write their own emails?
We've done the sort-of-heavy lifting and crafted three templates for you:
EU Firm Template: This template directly invokes your enforceable rights under the EU Data Act (e.g., Articles 25 and 29), requesting full data export at direct cost within 30 days. Ideal for EU-established firms to initiate switching without delay cite the law, request an itemised quote, and escalate if needed.
UK Inquisitive Template: A softer, exploratory approach for UK-only firms, requesting details on current fees, data inventory, and your vendors' Data Act compliance roadmap (including for UK clients). It educates without demanding, leveraging the Brussels Effect to probe for voluntary alignment - perfect for gathering intel before pushing harder.
UK Authoritative Template: This firmer version for UK firms asserts the Data Act as a market benchmark, expecting 30-day switches at direct cost (referencing UK regulators like CMA/Ofcom). It mirrors EU demands but frames them as policy expectations - use it to negotiate strongly, demanding justified quotes and positioning non-compliance as a red flag.
This is pure speculation, but given we're blogging, why not?
We expect requests from EU clients to their Legacy Vendors will initially go something like this:
The Legacy Vendor point clients to their contracts and restate a per GB fee (e.g., $50)
If pushed, they will relax the fee to the ~$20/GB range (they will not provide a direct cost breakdown)
If pushed further, they will offer a lower export rate, as a trade for a longer or extended contract
For UK Clients, I expect that Legacy Vendors will establish a similar runbook, and emphasise that because the client is UK (not EU), such rules don't apply.
However, the great thing about the Data Act (and the 'Brussels Effect' more generally) is the sea of pressure that the Legacy Vendors will come under. It will only take one EU Client to provide what cost quote they have received to create a firestorm of pressure.
I foresee conversations like the below:
UK Client: "How much for my data back?"
Legacy Vendor: "$50,000"
UK Client: "But you're charging EU client ABC $500!"
Legacy Vendor: "Different rules for you, how about $15,000?"
Green Flags
Itemised line items (egress bandwidth, compute) matching real direct costs; no margin/overheads.
A concrete plan hitting notice → 30‑day transition with open interfaces and standard, machine‑readable formats.
Red Flags
Flat “$X/GB extraction fee” with no cost basis; “professional services” hours with no linkage to the export work. (See Part I and Part II for how the old model worked.)
Attempts to re‑label your one‑off switch as an in‑parallel multi‑cloud to keep charging egress after 2027.
Vendors might quote minimal costs (win) or push back with excuses (red flag). EU responses should cite Articles 25 and 29; UK ones may reference global alignment.
Send the email, see what comes back, and tell us.
We’re collecting anonymised responses (good and bad) to help firms benchmark real‑world compliance with the Act’s switching rules. If you want help tuning your request or interpreting a reply, get in touch.
Whatever you get, forward anonymised versions to info@steel-eye.co.uk or use the form below.
We'll compile insights – who's client-first, who's clinging to old ways?
We'll recap the reaction, provide some anonymous insights that we receive back from the community, and keep the pressure building on the Legacy Vendors.