The Data Act for transport and logistics: who gets access to your vehicle and supply-chain data?

Transport and logistics run on data: telematics, on-board units, tachographs, reefer sensors, warehouse and terminal systems. Until recently the question "who owns that data?" was largely a matter of contracts and bargaining power. Since 12 September 2025 the Data Act (Regulation (EU) 2023/2854) gives a European answer. This is not AI regulation — it is purely about data: who may access it, on what terms, and how to avoid being locked into a single vendor.

What the Data Act does

The regulation sets harmonised rules for fair access to and use of data in the EU. At its core, data from connected products and related services no longer has to stay exclusively with the manufacturer or service provider, but becomes available to the user — and, at the user's request, to a third party of their choice.

Four elements are decisive for the sector.

1. Access to connected-product data

Whoever uses a connected product — a truck with telematics, a reefer with sensors, an AGV in the warehouse — has the right to access the data the product generates, and may have it shared with a third party of their own choosing. For a carrier or shipper this means vehicle and machine data are no longer a closed box held by the OEM or supplier. At the same time, whoever holds such data carries the duty to enable that access.

2. Fair B2B sharing terms (FRAND)

Where data is shared between businesses, it must be on fair, reasonable and non-discriminatory terms (FRAND). The regulation is explicitly designed to protect smaller parties against sharing terms imposed by dominant players — a familiar pattern in chains where one party owns the data and the standard.

3. Ban on unfair contract terms

The Data Act prohibits contractual provisions that impede fair data sharing. That forces a practical action: existing data, supply and platform contracts must be reviewed for terms that unilaterally block or price access or transfer.

4. Switching between cloud services

The regulation obliges providers of data-processing services to make switching between clouds easier and to remove barriers. For logistics IT — TMS, WMS, port community systems, data-sharing platforms — this reduces lock-in and increases bargaining room when choosing a supplier.

Timeline

The core provisions have applied since 12 September 2025. Application is phased: the design obligation to build new connected products so that data is accessible, and the heavier interoperability and switching requirements, run on in the years that follow. The direction, however, is fixed and already in force: connected-product data is in principle shareable.

What this means for your organisation

Three questions determine your position:

1. Which connected data do you generate or hold, and who is entitled to it?

Without a data inventory you cannot assess or honour requests.

1. Can you share data on request in a common, machine-readable format?

The right of access and onward sharing is worth little if it cannot be done technically.

1. **Do your contracts meet the FRAND requirement and the ban on unfair

terms?** Existing agreements are the most likely source of non-compliance.

Want to know which EU regimes besides the Data Act affect your organisation — eFTI, EMSWe, the AI Act, NIS2 — and where your readiness stands? Take the Transport & Logistics scan.