Obligations due by this deadline
For all in-scope entities
- Art 37 — Entities providing data intermediation services as of 23 June 2022 must comply with the obligations set out in Chapter III.
- Art 35 — The Commission shall carry out an evaluation of the Regulation and submit a report on its main findings to the European Parliament, the Council, and the European Economic and Social Committee.
- Art 35 — The Commission shall accompany the report with legislative proposals where necessary.
Checklist — what you need to have done
- Art 37: comply
- Art 35: evaluate and report
- Art 35: propose legislation
What should already be in place — audit framing
24 September 2025 is 249 days behind us. The obligations on this page have been in force since then; treat any gap as an audit finding, not a planning question. The expected baseline under Data Governance Act:
- data intermediation notification to the authority — should be done already
- structural / organisational separation requirements — should be done already
If any of these are missing, the right next step is a gap assessment plus a documented remediation plan — not a re-design of the underlying programme.
Related Fontvera pages
- data governance act article 5 member state
- data governance act vs dma comparison
- data governance act vs dora comparison
- data governance act vs dsa comparison
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