# Your exit fee is disappearing. Your lock-in is not. > From 12 January 2027 a cloud provider cannot charge you to leave. The fee was never what kept you there. Four questions decide whether you can go. - Author: Marlon Trettin - Published: 2026-10-14 · Updated: 2026-10-14 - Language: en - Canonical: https://yowpi.com/en/blog/can-you-actually-leave-your-software-vendor --- From 12 January 2027, a provider of cloud or edge computing services selling into the EU cannot charge you to leave. The exit invoice disappears. The difficulty does not, because what holds an operation inside a product was never the fee. It is that the rules running the operation live inside the product. ## TL;DR - From 12 January 2027, providers of data processing services selling into the EU may not impose switching charges, data egress included. In the transition that started on 11 January 2024 they may charge no more than the costs directly linked to the switch. - What you are entitled to take out is exportable data: your input and output data plus metadata, excluding anything protected by the provider's intellectual property or held as a trade secret. - Functional equivalence, meaning materially equivalent outcomes from the same input after the move, is required only of infrastructure services. Platform and software services owe open interfaces and, on request, a machine-readable export. - The law gives you 30 calendar days to move, and up to seven months where the provider duly justifies that 30 days is technically unfeasible. The distance between those two numbers measures how much of your architecture you actually own. ## What changes in January 2027? The price of leaving goes to zero by law. [Article 29 of the Data Act](https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng) states that from 12 January 2027 providers of data processing services shall not impose any switching charges on the customer, and that during the transition from 11 January 2024 the reduced charges may not exceed the costs directly linked to the switching process. The rest of that chapter has been in force since 12 September 2025, when the [Data Act became applicable](https://digital-strategy.ec.europa.eu/en/policies/data-act-explained). Your contract has to give you a notice period of no more than two months to start the move, a transitional period of 30 calendar days to carry it out, and at least 30 more days to retrieve your data afterwards. Two clauses in Article 25(2) deserve a second reading. Point (e) requires an exhaustive specification of every category of data and digital asset that can be ported. Point (f) requires a separate exhaustive specification of the categories that will be withheld, which is limited to data specific to the internal functioning of the provider's own service where a trade secret is at risk, and only where withholding them does not impede or delay the switch. Few companies have ever asked for those two lists. Meanwhile the operation kept moving into other people's products: among EU enterprises that bought cloud services in 2025, [Eurostat](https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20260203-1) records 58.2% buying finance or accounting software that way, 45.5% database hosting, 30.1% ERP and 27.9% CRM. ## Why the fee was never what kept you Because a fee is the part of a barrier that legislation can remove in one line. The rest of the barrier is built, not priced. The UK competition authority arrived at the same split from the other direction. Its 2025 market investigation into cloud services found customer choice limited by data egress fees and by barriers to interoperability. In [March 2026 the CMA announced](https://www.gov.uk/government/news/cma-announces-package-of-actions-on-business-software-and-cloud-services) that the two leading providers had set out actions on egress fees and interoperability for UK customers, and said in the same statement that further steps are required to help customers multi-home and switch, with a board review in six months. Look at the order of events. Prices moved first, because a price is a decision somebody can make in an afternoon. Interoperability is still open. It is not a decision at all, it is a property of how the systems were built. The regulation is explicit about this. Article 29(5) requires a provider, where relevant, to tell customers when a service is highly complex or costly to switch, or when switching is impossible without significant interference in the data, digital assets or service architecture. Article 25(4) goes further: a provider for whom the 30-day move is technically unfeasible has to notify you within 14 working days, duly justify that unfeasibility, propose an alternative period of no more than seven months, and keep the service running throughout it. The law has a name and a timetable for the case where money is no longer the problem. ## What comes back, and what stays behind You get the records. The behavior stays where it was built. The Data Act defines exportable data as the input and output data, including metadata, generated by your use of the service, and then excludes any assets or data protected by intellectual property rights or constituting a trade secret of the provider or of third parties. Article 30(6) adds that no provider has to develop new technology or hand over protected digital assets to make your move easier. One more line in that chapter decides more than it appears to. Functional equivalence, getting materially equivalent outcomes from the same input after switching, is required only of providers of infrastructure: servers, networks, the raw computing underneath. Every other provider, which includes the platform and software services where your operation actually runs, owes open interfaces under Article 30(2) and, on request and where no common specification or harmonized standard has been published for that service type, an export of all exportable data in a structured, commonly used and machine-readable format. So the customer table arrives intact. The rule that a discount above a certain percentage needs a second approval does not, because that rule is a workflow configured inside a product, and the product belongs to somebody else. ## Where do your operating rules actually live? Picture a distributor with 120 people. This is an illustration, not a measurement. Finance runs in one cloud suite, quotes in a CRM, field service in a vendor app. Nobody ever wrote down how an order becomes an invoice, because three products already know. The CRM export will contain deals, contacts and a discount column. It will not contain the escalation rule, the validation that blocks a quote without a credit check, the list of who may approve what, or the definition behind the number the board sees every month. Those live on configuration screens, and configuration screens do not travel. Four questions separate a company that can move from one that can only absorb the terms. The first is where the source of truth sits for each entity. For customer, contract, order and invoice, name the single system that decides. If the answer is "it depends", the move has no starting point, which is also why the reports disagree today. We covered that failure mode in [data centralization myths and truths](/en/blog/data-centralization-myths-and-truths). The second is whether the rules exist outside the product. A rule that lives only as a setting in a vendor's admin screen is a rule you rent. Written down, or built into a layer you control, it survives the move. Third, who owns identity and permissions? When every product keeps its own list of who approves what, leaving any one of them means rebuilding an org chart from screenshots. Last, has the export ever been loaded anywhere else? A restore nobody tested is not a restore. Pull the export once a quarter, load it into a database you control, and see what arrives without a label. None of those four is a purchase. They are days of senior attention, not a budget line, and they are also the material for the two contract lists you are now entitled to demand. Article 26 goes further and requires the provider to keep an up-to-date online register of the data structures, formats and standards in which your exportable data is available. Ask for the link. The answer, or the silence, tells you where you stand before renewal season does. One caveat, because it cuts against the easy conclusion. Article 31 exempts software custom-built for a single customer and not sold at broad commercial scale from the switching charge rule and from the functional equivalence and standards obligations, though the open interfaces, the export, the contract lists and the register still apply, and the provider has to tell you before signing which obligations do not. Bespoke software is not portable by nature either. What protects you is the same thing anywhere: the contract, and where the data and the rules physically sit. [SuperVida moved contract management off an improvised Airtable base into a custom-built ERP](/en/cases/super-vida), and [Colo Saúde inherited a system built by a previous vendor on a no-code platform and is now migrating it onto its own architecture](/en/cases/colo-saude). In both, the decision that mattered was never which tool. It was who holds the record and who can read the rules. This is a reading of the regulation, not legal advice. Your contract, your jurisdiction and your service type decide what applies to you. ## Frequently asked questions **Our provider is not in the EU. Does any of this reach us?** The provider's address does not decide it. The Data Act applies to providers of data processing services irrespective of where they are established, as long as they serve customers in the Union, so an EU contracting entity carries these rights even with a provider headquartered elsewhere. What falls outside is the case where neither side is in the Union. There, the market still moves: the CMA reported in March 2026 that both leading cloud providers had set out actions on egress fees and interoperability for UK customers after its investigation. Beyond that, what you get is what your contract says, which is the argument for reading it before you renew. **We have no plans to switch providers. Why spend time on this now?** Because the test is not really about leaving. The same four answers determine what happens when a provider raises the price, retires the feature you depend on, gets acquired or has a long outage. Portability measures how much of your operation you can describe outside somebody else's product, and that number drives the [cost of keeping the system running](/en/blog/what-it-costs-to-keep-a-system-running) long before anyone considers a migration. **How do we do this without a qualified technical team?** The first pass is not an engineering project. Listing which system holds the source of truth for each entity, and asking each provider for the two contract lists and the register, is desk work for someone senior who knows the operation. Only after that do you know whether there is anything to build, and how big it is. ## The next step If you cannot say today which system holds the source of truth for your customers and your orders, the [Operational Architecture Diagnostic](/en/contact) is a 30-minute conversation to map that before the next renewal lands on your desk.