What the E.U. Data Act Means for IoT Businesses Operating in Europe

In the European Union, under the E.U. Data Act (Act), IoT data now belongs to users. Most provisions of the Act, which sets new rules for U.S. and other non-E.U. companies that do IoT-related business in Europe, came into force in September 2025. Together with other E.U. laws and sector regulations, the Act creates a complex and multilayered compliance landscape in the E.U., presenting companies with GDPR-level financial risk, as well as exposure to class actions and legal claims from competitors. This article, distilling insights offered by Baker Botts and Faegre Drinker Biddle & Reath partners during a BARBRI program, analyzes key elements of the Act and offers compliance guidance. See our two-part series on Cybersecurity Obligations in E.U.’s digital laws: “AI Act, CRA and NIS2” (Sep. 4, 2024), and “Data Act, DORA and Compliance Steps” (Sep. 11, 2024).

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