Cloud Migration 2027 – Request Data Export, Dispute Migration Fees, and Plan a SaaS Move | Word/PDF/Excel

Does your company want to change cloud providers, move data out of a SaaS system, or challenge an export fee? With the Cloud Switching 2027 document package, you get five audience-tailored Swedish work letters, two guides, and a nine-tab Excel register to prepare, document, and follow up on an actual supplier switch. The tool focuses on the EU Data Act, Chapter VI, and the switching fees being abolished from 12 January 2027 for covered data processing services.

Quick answer: According to Article 29.1 of Regulation (EU) 2023/2854, data processing service providers may not charge a switching fee for the supplier switch itself from 12 January 2027. Until then, the transitional rules in Articles 29.2–3 apply: as a general rule, the fee may not exceed actual costs directly linked to the switch. This does not mean that regular subscriptions, a reasonable agreed compensation for early termination, or all data transfers are automatically free of charge.

Who Can Use the Package?

Primarily small businesses, sole traders, IT managers, e-commerce businesses, associations, and organizations in Sweden that need to migrate from a cloud service, change SaaS providers, or retrieve their exportable data. The service must first qualify as a data processing service under the Data Act; it cannot be assumed that every digital subscription, web application, or support agreement is always covered by Chapter VI.

Which Document Should You Use?

Scenario 1 – the company's SaaS agreement is unclear: You use a system for customer management, accounting, or digital storage and need to understand whether Chapter VI and its specific exceptions apply. Start with Letter 01 and request a written response regarding classification, contractual terms, and exportable data categories.

Scenario 2 – you want to change cloud providers: Use Letter 02 for a formal switching request, export format, data and digital asset specification, notification period, and joint plan. State the actual desired goal: another data processing service or your own IT infrastructure.

Scenario 3 – the provider charges for data egress after 12 January 2027: Use Letter 03 to specify whether the fee is actually a switching fee for a covered switch and request a correction. A traffic fee for regular or parallel operation is not automatically the same thing.

Scenario 4 – export is available but cannot be imported: Use Letter 04 to request a secure sample export, a complete data catalog, format description, integrity check, and clarification of technical obstacles. Advanced migration also requires technical responsibility and agreed testing – the template does not do the work automatically.

Scenario 5 – no response is received or the fee issue is not resolved: Use Letter 05 for factual follow-up and documentation before a possible contact with PTS. The letter is a working document; it does not constitute a submitted authority complaint.

Complete File List

Excel: Nine Tabs for Data Export, Dates, and Switching Fees

START · Services · Switch · Data Export · Fees · Contacts · Deviations · Overview · READ ME. The Services tab documents the contracting party, SaaS/PaaS/IaaS, any Article 31 assessment, and references. Switch links the technical start, actual transition, and target environment to a unique case ID. Data Export collects data categories, export format, and verified receipt. Fees separate the switching fee from regular service, early termination, and parallel operation.

Controlled Calculations: A request actually sent on November 1 with a response on November 5 shows 4 calendar days; this is not proof in itself that a legal response deadline has been breached. A purely mathematical difference for a specified switching fee of SEK 850 from 12 January 2027 becomes SEK 850 to review, if the service and fee are actually covered by Article 29.1. For a fee of SEK 850 during the transitional period, with SEK 750 in actually verified direct switching costs, SEK 100 to review is shown. The amounts are not automatically legally established claims. The customer file contains no test cases and has no macros or external data links.

Legal Review: EU Data Act and Cloud Provider Switching

Which Services Are Covered? The Data Act defines data processing services in Article 2 and regulates switching in Articles 23–31. This may apply to SaaS, PaaS, and IaaS depending on the service's function and contractual relationship. Article 31 contains specific exceptions and application limitations for, among other things, certain individually tailored services and test/beta services. The exceptions are not general free passes for the provider – which obligations still remain must be checked.

Two Time Periods for Switching Fees: According to Articles 29.2–3, a covered provider may charge a reduced switching fee until 12 January 2027 that corresponds at most to actual costs directly linked to the switch. From 12 January 2027, Article 29.1 prohibits the switching fee itself. The European Commission expressly explains that data egress in connection with a switch is also included in the phase-out.

What Costs May Remain? Article 29 separates switching fees from regular service fees and certain reasonable compensation for early termination. Actual traffic during parallel cloud use may also need to be assessed separately. A fee should not be reclassified merely with a label; assess the actual action, timing, contract, and Article 29.

Notification and Transition Period: Article 25.2(d) states a maximum notification period of two months to initiate the switch. The technical transition should generally be able to be carried out within 30 calendar days after the notification period (Article 25.2(a)). In cases of proven technical complexity, there is a special longer alternative period and a requirement for reasoned information; the customer can under certain conditions extend the transition themselves. This is not a general right to demand complete migration on the day without technical planning.

What Can Be Exported? According to Article 25.2(e), the contract must exhaustively specify categories of exportable data and digital assets. Certain service-specific data categories may be exempted under specified conditions (Article 25.2(f)), without this hindering a real switch. No template promises general access to the provider's source code or all operating systems.

After the Switch: Article 25.2(g) states at least 30 calendar days for data recovery after the transitional period. Thereafter, Article 25 has rules for the deletion of relevant exportable data, with further contractual and legal conditions. Personal data, backup copies, and confidentiality require separate control according to GDPR, processor agreements, and other applicable obligations.

Who Monitors the Rules in Sweden? The Swedish Post and Telecom Authority (PTS) is the competent Swedish authority for the Data Act and receives complaints. PTS states that supervisory powers may be limited while national complementary legislation is being processed. Check the current legal status before drawing conclusions about authority actions.

Six-Step Workflow

1. Review the contract. Identify the data processing service, provider, contract term, and any special service category.
2. Choose Document 01 or 02. First establish applicability; then state concrete data, recipient, target environment, and secure transfer channel.
3. Check the billing. Separate switching fees from normal operation and any early termination. Use Document 03 for a clearly identified incorrect invoice line.
4. Plan technical tests. Document 04 helps to compile sample export, format, access, integrity, and import control.
5. Collect and protect evidence. Enter dates, contract ID, and file references in Excel. Do not put passwords or personal data in open spreadsheets.
6. Follow up. Document 05 provides a structured request for a response and evidence before a possible contact with PTS. Save what was actually sent and received.

Common Questions About Cloud Switching 2027

When Do Switching Fees for Cloud Services Disappear?

From 12 January 2027, Article 29.1 of the EU Data Act prohibits switching fees for covered data processing service provider switches. Always check which operation and service the fee refers to.

Does the Prohibition Apply Already During 2026?

No, during the transition before 12 January 2027, the provider may generally charge a reduced switching fee that does not exceed actual costs directly linked to the switch itself according to Articles 29.2–3.

Can the Provider Still Charge for a Subscription or Termination?

Yes, regular service fees and any contractually reasonable compensation for early termination are other categories. A switching fee may not be hidden under another name, but every invoice line must be assessed factually.

Is All SaaS Software Automatically Covered?

No. The service needs to be assessed against the definition of a data processing service and Chapter VI. Certain individually designed or test/beta services may be covered by special limited exceptions according to Article 31.

How Much Time Does My Cloud Provider Have?

Article 25 generally means a maximum notification period of two months to initiate the switch and thereafter normally at most 30 calendar days for the technical transition. In cases of proven technical complexity, special longer periods may apply; the customer can under certain conditions extend the transition themselves.

How Long Will I Be Able to Retrieve My Data After the Switch?

Article 25.2(g) prescribes at least 30 calendar days for data recovery after the agreed transitional period, with further contractual and legal conditions. Also check when and how the data is to be deleted later.

Must the SaaS Provider Hand Over Its Source Code?

No. The Data Act has rules for exportable customer data and digital assets, but does not give a general right to the provider's internal operating data, trade secrets, or source code. Request a complete specification of exportable data categories according to Article 25.

Does the Fee-Free Status Also Apply to Data Egress and Parallel Use?

The European Commission describes that data egress needed for a covered supplier switch is included in the phase-out of switching fees. Parallel multi-cloud use, normal operation, and other traffic may need to be assessed separately according to rules and contracts.

Can I Dispute the Entire Invoice When a Switching Fee Is Incorrect?

Not automatically. Letter 03 helps you object to a specified line, state the date, amount, and factual basis, and handle undisputed parts separately. Excel only performs arithmetic difference calculations.

Who Do I Contact If the Provider Refuses to Export?

PTS is the competent Swedish authority for the Data Act and provides information about complaints. Check the current complaint process as well as the authority's possibly limited powers while awaiting national supplements.

Are the Documents in English or Are the PDF Files Fillable?

The five work letters and one guide are in Swedish. The separate English User Guide describes how they are used, but the letters are not translated. The PDFs are searchable and printable, not interactive forms.

Related Documents at Mallbutiken

If you need a broader Data Act package for multiple legal areas, there is Data Act Template Package – Contracts and Compliance. For contract work before a new system, there is SaaS Agreement – SLA and GDPR. For general exit planning from other providers, there is Supplier Termination and Handover B2B. The new product complements these by focusing on the transition of switching fees in 2027 and actual cloud data export – not general contractual terms.

Official Sources and Transparency

EUR-Lex – Data Act, Regulation (EU) 2023/2854, Articles 23–31 · European Commission – Data Act Explained · PTS – The Data Act in Sweden.

Version 1.0 · Jurisdiction Sweden/EU · AI-assisted legal source check on November 8, 2026. No independent legal review or authority certification has been carried out. The documents do not guarantee that a certain SaaS service is covered, that a certain amount will be refunded, or that a switch will succeed technically. The customer's actual contract, evidence, data, and security checks must be added. The digital ZIP is linked in a separate process before possible publication; the product is created as a DRAFT.