3. How does the Data Act interact with data-sharing obligations under other EU legislation?

The Data Act is a horizontal piece of legislation that aims to significantly enhance fair access to and use of data across all sectors of the economy. Chapter III, in particular, establishes a framework regarding the conditions, compensation, and technical protection measures for whenever a data holder is obliged under EU or national law to share data with a data recipient. More concretely, Article 44 of the Data Act addresses two key dimensions that structure the interaction between the Data Act and other EU legislation that include rules on data access and use: time of entry into force (Article 44(1)) and sectoral specificities (Article 44(2)). According to Article 44(1), data-sharing obligations contained in Union legal acts that entered into force on or before 11 January 2024 (the Data Act’s entry into force) remain unaffected, meaning that previous legal obligations (including those laid down in delegated or implementing acts) prevail. If EU legal acts introduce rules on data between 11 January 2024 and 12 September 2025 (the Data Act’s entry into application), best efforts should be made to ensure alignment, but there is no legal obligation to do so. The Data Act sets horizontal rules for data access, sharing and use. However, Article 44(2) allows the Data Act to be complemented by sector-specific legislation, where necessary, with practical and technical modalities (e.g. safety, standardisation, or technical matters) and with specific limits on data holders’ access rights or actions. However, the development of such sectoral rules should be approached cautiously and be consistent with the principles laid down in the Data Act to the greatest extent possible, thus avoiding unnecessary complexity. The principles of the Data Act apply for all matters related to ‘access to data’ that are not specifically regulated in such sectoral rules.