Posted: 23 Apr. 2024 15 min. read

Business-to-Business data sharing under the EU Data Act

Delivering to the regulatory requirement to share data in a fair, reasonable and non-discriminatory manner

Our latest report (which can be downloaded at the link below) is designed to help companies navigate the Business-to-Business data sharing provisions of the EU Data Act.

The EU Data Act entered into force in January 2024 and will become fully applicable in September 2025. Under the new rules, connected products across all sectors of the economy will have to be designed and manufactured in a way that empowers EU users to easily and securely access, use and share the data generated by the use of those devices.

The new regime is expected to prompt the development of significant economic opportunities, including the creation of new markets for Business-to-Business data where data will have to be shared on a fair, reasonable, and non-discriminatory (FRND) basis. This is likely to raise a number of practical questions for companies, as the application of FRND obligations to data sharing is novel.

Bringing together experts from across Europe, this report outlines a frame of reference for both business data holders and recipients in all sectors who may be considering such data sharing. Case studies are included to bring this to life, providing insights into how the new regime may affect the health, mobility and agriculture sectors. These are all priority EU Data Spaces.

Finally, we outline the strategic considerations that data holders should consider relevant to commercial data sharing, as well as key steps that companies can take now in order to prepare for Data Act compliance.

Key contacts

Suchitra Nair

Suchitra Nair


Suchitra is a Partner in the EMEA Centre for Regulatory Strategy and helps our clients to navigate the regulatory landscape around technological innovation. She sits on the UK Fintech Executive and leads our thought leadership on topics such as digitsation, cryptoassets, AI, regulatory sandboxes, Suptech, payment innovation and the future of regulation. She recently completed a secondment at the Bank of England, supervising digital challenger banks. Suchitra is a member of various industry working groups on innovation in financial services and has regularly featured in the Top 150 Women in Fintech Powerlist (Innovate Finance). She is a qualified Chartered Accountant and has previously worked in Deloitte’s Audit, Corporate Finance and Risk Advisory teams, where she led large-scale regulatory change projects.

Robert MacDougall

Robert MacDougall


Robert is a Director in Deloitte's EMEA Centre for Regulatory Strategy, where he leads the Centre’s work on regulation in Digital Markets. Prior to joining Deloitte, Robert spent eleven years at Vodafone Group, setting Group policy positions across a wide variety of regulatory initiatives relevant to the promotion of competition and protection of consumers in digital markets. Robert has over a decade's experience working at regulatory bodies relevant to the sector, spending eight years at Ofcom (and its predecessor Oftel) and four years at the UK's competition and consumer protection authority. This included a secondment to the US Federal Trade Commission working on technology topics in the FTC's Bureau of Consumer Protection.

Matteo Orta

Matteo Orta

Senior Consultant

Matteo is a Senior Consultant in the EMEA Centre for Regulatory Strategy, focusing on cyber and operational resilience, digital markets and innovation regulation. Before joining Deloitte, he worked in geopolitical risk consultancy. He is a graduate from the London School of Economics and the University of Huddersfield.