§ Data Act · Article 15
Data Act Article 15: Obligations, Deadlines & Penalties
At a glance
Article 15 of the Data Act imposes 4 obligations on Commission, European Central Bank, Union body and 1 other entity type(s).
§ Obligations
All obligations under Article 15
Obligation 1
An exceptional need to use data must be limited in time and scope and exist only under specific circumstances such as responding to a public emergency or fulfilling a specific public interest task when alternative means are unavailable.
Regulation (EU) 2023/2854, Article 15, Article 15
- Obligated entity
-
public sector body, Commission, European Central Bank, Union body
- Action required
-
limit
- Deadline
-
—
- Penalty
-
—
Obligation 2
When acting on the basis of Union or national law for a specific public interest task, the entity must identify specific data the lack of which prevents fulfilling that task.
Regulation (EU) 2023/2854, Article 15, Article 15
- Obligated entity
-
public sector body, Commission, European Central Bank, Union body
- Action required
-
identify
- Deadline
-
—
- Penalty
-
—
- Exemptions
- microenterprises and small enterprises
Obligation 3
The entity must exhaust all other means at its disposal to obtain non-personal data, including purchase on the market at market rates or relying on existing obligations, before invoking an exceptional need.
Regulation (EU) 2023/2854, Article 15, Article 15
- Obligated entity
-
public sector body, Commission, European Central Bank, Union body
- Action required
-
exhaust
- Deadline
-
—
- Penalty
-
—
- Exemptions
- microenterprises and small enterprises; cases where production of official statistics is the task and purchase is not allowed by national law
Obligation 4
The entity must demonstrate that it was unable to obtain non-personal data by purchasing them on the market, unless exempted.
Regulation (EU) 2023/2854, Article 15, Article 15
- Obligated entity
-
public sector body, Commission, European Central Bank, Union body
- Action required
-
demonstrate
- Deadline
-
—
- Penalty
-
—
- Exemptions
- microenterprises and small enterprises; cases where production of official statistics is the task and purchase is not allowed by national law
§ Deadlines
Data Act compliance deadlines
-
2025-09-12
Data Act applies (Regulation (EU) 2023/2854)
in_force
-
2026-09-12
Data Act Art 3(1) access-by-design for connected products and related services placed on the market after 12 September 2026
in_force
-
2027-01-12
Data Act: data-processing (cloud) switching charges fully abolished (Art 29)
scheduled
-
2027-09-12
Data Act Chapter IV (unfair contractual terms) extends to long-term contracts concluded on or before 12 September 2025
scheduled
§ Frequently asked
Questions about Article 15
Who must comply with Article 15 of the Data Act?
+
Commission, European Central Bank, Union body, public sector body.
What does Article 15 of the Data Act require?
+
limit identify exhaust