Switching SaaS Under the EU Data Act: A Buyer’s Guide to 2027
Switching SaaS Under the EU Data Act: A Buyer’s Guide to 2027
Choosing a European SaaS provider is only half the decision. The harder question often comes later: can you move your records, attachments, permissions, and working processes out of the tool you already use?
A CRM export might contain every contact but none of the relationships between contacts and deals. A project archive might preserve task names while losing comments and file links. Those gaps can turn an apparently straightforward switch into weeks of reconstruction.
The EU Data Act makes this a timely conversation. It has applied since 12 September 2025, and the next important switching milestone is 12 January 2027, when switching charges, including data egress charges associated with switching, are prohibited for covered services. The European Commission’s overview explains the framework, which includes cloud software as well as infrastructure. This guide focuses on preparing a SaaS migration; the practical steps below are our recommendations.
What the switching rules cover
Chapter VI applies to qualifying data processing services offered to customers in the EU, including by providers established elsewhere. Article 31 sets exceptions for certain bespoke services and limited, non-production trials. Check your service’s scope before relying on a particular obligation.
Key provisions include:
- Timing: a maximum two-month notice period, followed by a normally maximum 30-calendar-day transition. A technically justified alternative can extend to seven months; customers can also request an extension.
- Retrieval: at least 30 calendar days to retrieve data after transition.
- Exports: open interfaces for non-infrastructure services; where relevant interoperability standards are absent, structured, commonly used, machine-readable exports on request.
- Fees: before the January deadline, switching charges cannot exceed directly related costs. Standard service fees and early termination penalties are separate categories.
These provisions do not require a SaaS provider to rebuild its application inside a competitor. See Articles 25, 29–31 of the regulation. For implementation questions, the Commission also maintains Data Act FAQs.
Start with the workflow you cannot afford to lose
Before requesting an export, write down three processes your team must complete in the replacement system. Be specific: “create a deal from an enquiry, assign an owner, and send an approved follow-up” is more useful than “sales automation.”
For each process, identify the records, people, integrations, and historical information it depends on. Ask the colleague who actually performs the work to review the list. Administrators often know where settings live; users know which missing detail would stop their day.
This also helps you choose a destination. If you are evaluating European CRM software, compare candidates against those processes before comparing subscription prices. A lower seat price will not compensate for a broken reporting or customer handover process.
Test an export before signing the replacement contract
Ask for a small, representative export while you still have time to investigate omissions. Use a controlled test environment and avoid copying unnecessary personal data into a trial account.
Do not accept “CSV available” as the entire answer. A format describes the container; it tells you little about whether the contents are enough to reconstruct your work.
| System | Include in your test sample | Check after import |
|---|---|---|
| CRM | A company, several contacts, a deal, notes, custom fields, and attachments | Relationships, owners, timestamps, and field types survive |
| Project management | A project with subtasks, comments, dependencies, and archived tasks | Hierarchy, history, and file access remain usable |
| Document collaboration | Linked documents, embedded files, and restricted content | Links resolve and access permissions behave as intended |
| Customer support | A ticket with several replies, attachments, tags, and an assigned agent | Conversation order and customer associations remain intact |
Keep a simple reconciliation sheet: source count, exported count, imported count, and unresolved differences. A matching record count is a useful starting point, but manually inspect a few complex records too. An attachment can exist in the destination and still be connected to the wrong customer.
If documents are central to the move, our document collaboration comparison can help you assess the replacement workflow. Test cross-document links early: repairing them after the whole team moves is frustrating work.
Send both providers the same questions
A migration needs cooperation at both ends. Ask the current provider what it can export and ask the destination provider what it can actually import. Send both the same sample and ask them to identify gaps in writing.
You can adapt this request:
We are evaluating a switch. Please share your switching procedure, export documentation, supported formats, and a list of included and excluded data categories. For our sample, please identify which relationships, attachments, metadata, and permissions can be preserved. Please also separate switching charges from subscription fees, early termination penalties, and optional migration services, and confirm the proposed timetable.
Then assign an owner to every unresolved issue. “The importer supports contacts” is not enough if your business needs account relationships, custom fields, and a complete interaction history.
For a support migration, for example, your customer support shortlist should include a test of old conversations as well as new ticket handling. Agents need to understand what happened before the switch, not simply receive new messages.
Budget for the work around the export
Treat the fee deadline as one input to the budget. Your migration estimate should separately account for:
- Contract costs: overlapping subscriptions, commitments, and any disputed exit charges.
- Data work: extraction, field mapping, cleanup, attachment handling, and reconciliation.
- Integration work: rebuilding automations, webhooks, identity provisioning, and reports.
- People: training, documentation, and temporary productivity loss.
Use estimates from your own sample import. If mapping ten custom fields takes half a day, multiplying that work across a much larger configuration gives a more useful estimate than assuming the importer will handle everything.
Avoid scheduling the move around the deadline alone. Compare the potential fee saving with the cost of waiting: a renewal, another quarter of an unsuitable tool, or a busy seasonal period may matter more. Request an itemised quote with the proposed switching date so you can make that comparison.
Verify the European destination separately
A successful import does not answer your questions about headquarters, hosting, subprocessors, or support access. Record those answers separately when reviewing the destination provider.
Our data residency guide explains the distinctions to investigate. For the migration itself, ask where temporary exports and import logs will be stored, who can access them, and how you will remove those copies afterwards.
Apply the same export test to the new provider. You are choosing a system you may use for years, and your next exit should be part of this purchase decision. Save the documentation and sample results alongside the contract so a future administrator does not have to start from scratch.
Plan a controlled cutover
Pick one team or a bounded set of records for the first import. Have users complete the three essential workflows you identified earlier, then record which checks passed and which need another attempt.
Before the full move, agree on:
- A cutover owner and a contact at each provider.
- A final export time and a method for capturing subsequent changes.
- Acceptance criteria for records, files, access, and critical workflows.
- A rollback decision point and a way to reconcile work created in either system.
- Dates for closing access and removing temporary migration copies.
Keep any rollback copy access-controlled and give it an explicit retention period. Leaving an old export on a shared drive indefinitely creates a maintenance problem long after the migration is finished.
The most useful preparation for January is a tested export, an itemised exit quote, and a replacement that can run your essential processes. Use the European SaaS directory to find candidates, then ask each one to demonstrate a round-trip export and import before making a long-term commitment.
