On 12 January 2027, 106 days from now, it becomes unlawful for a cloud provider to charge an EU customer for leaving. Article 29(1) of the EU Data Act is one sentence and admits no exceptions: providers of data processing services “shall not impose any switching charges on the customer for the switching process”. Most commentary has rendered this as “egress fees are abolished”, which is wrong in one direction and far too small in the other.
We read the two documents that will govern your exit: the AWS EU Data Act Addendum and Section 16 of Google Cloud’s General Service Terms. They implement the same regulation. They do not implement the same deadline, the same form, or the same consequence for getting it wrong. If you intend to move anything in 2027, the number that matters is not a price per gigabyte. It is how many days before the move you have to say so.
TL;DR
- From 12 January 2027, Article 29(1) bans switching charges outright. Egress charged because you are switching is named in the definition. Your day-to-day egress bill is a standard service fee and does not change.
- AWS requires the switching request at least two months before you plan to start. Google’s Initiation Period is 14 calendar days. Same law, a 90-day process against a 44-day one.
- Both exits fail quietly. AWS can reclaim switching credits if you do not file a completion notice and delete the data. Google deems your exit notice withdrawn if you miss the window.
- Google excludes Pre-GA offerings from Chapter VI entirely. AWS requires an EU Member State account country. Article 31 excludes custom-built platforms.
- The 30-day transitional period is rarely a bandwidth problem. At a sustained 1 Gbps it moves roughly 316 TB. The problem is rebuilding what the data plugged into.
What actually goes to zero
The definition does the work. Article 2(36) defines switching charges as charges “other than standard service fees or early termination penalties” imposed for the actions the Regulation mandates for switching “to the system of a different provider or to on-premises ICT infrastructure, including data egress charges”.
Two things follow. Egress charged because you are switching is caught; egress charged because you are serving your own users is a standard service fee and is untouched, so the line item that dominates most cloud bills will look exactly the same on 13 January. And on-premises counts. A move to your own racks or a colocation cage is a switch in precisely the same terms as a move to a competitor, which is not how most exit clauses have been drafted.
From the AWS price list API for eu-west-1 (version 20260916132208, published 16 September 2026), data transfer out to the internet lists at $0.09 per GB for the first 10 TB per month, tapering to $0.05 above 150 TB. Moving a 50 TB estate out of Dublin therefore lists at about $4,400: a real number, and not why anybody stays.
Same regulation, two different clocks
Article 25 sets the frame. The contract must specify a notice period for initiating the switch, capped at two months, followed by a transitional period of no more than 30 calendar days in which the move happens. Where 30 days is technically unfeasible the provider must say so within 14 working days, justify it, and offer an alternative capped at seven months. The customer may extend once.
AWS sets its notice period at the ceiling. Clause 2.2 of the addendum requires a Switching Request to AWS Customer Support “at least two months prior to your planned Switch initiation date”, and that request is only deemed received “on the date you have provided all information that may be requested”. Add the 30-day Transitional Period and the statutory path from first ticket to completed move is roughly 90 days, with the start of the clock partly in AWS’s gift.
Google set its notice period at 14 days. Section 16 defines the Initiation Period as 14 calendar days from submission of an Exit Notice, which is a web form, followed by a 30-day Migration Period and a Data Recovery Period of at least 30 further days. End to end, 44 days.
Neither is a breach. Both are choices, and worth discovering before you need them.
Both exits can fail silently
AWS’s addendum carries a clawback. Clause 2.7 requires a Switch Completion Notice and then either account closure or deletion of all Switching Data. If you do not, you will “be required to reimburse AWS for any switching-related credits or fee waivers previously provided to you in connection with your Switch”. A free migration becomes a billed one because somebody left a bucket behind and nobody closed the ticket. The credit is contingent on tidiness in the closing phase of a project, the phase every migration under-resources.
Google’s failure mode is quieter still. You must initiate the switch inside the 14-day Initiation Period, giving at least two working days’ notice to an assigned support agent. Miss it and you are “deemed to have withdrawn” the Exit Notice, and the agreement simply remains in force. The Completion Notice has its own window, within 180 calendar days of the Migration Period ending, and missing that is a deemed withdrawal too.
Nothing alarming happens in either case. No failed build, no alert. The entitlement lapses and the billing carries on.
Check whether you are covered at all
AWS requires an Eligible Account: the designated payer account, with “an EU Member State as its Account Country”. An Irish company billing through a US or UK parent’s payer account does not obviously qualify. Google’s Section 16 applies only where the customer’s billing address is in the EEA, and only to services on its published portability list.
Google also excludes Pre-GA Offerings from Chapter VI outright, stating twice that it has “no obligations under Chapter VI of the EUDA” in respect of them. Preview services are where much current AI and data tooling lives, and teams routinely run them in production for years. Article 31(2) does carve out non-production versions used for testing “for a limited period of time”, but a preview you have depended on for two years is not obviously that.
Finally, Article 31(1) disapplies Article 29 entirely for services custom-built for a single customer and not offered at broad commercial scale. If a provider built your platform for you, your exit is not free.
The constraint is not bandwidth
The instinct is that 30 days is a copying problem. It usually is not. Thirty days of a sustained 1 Gbps link moves roughly 316 TB, or 158 TB at a realistic 50 per cent utilisation. Most estates fit with room to spare.
What does not fit is the rebuild, and Article 30 is unusually honest about this. Functional equivalence, meaning a materially comparable outcome on the destination service, is owed only by providers of “scalable and elastic computing resources limited to infrastructural elements such as servers, networks and the virtual resources necessary for operating the infrastructure”. For everything above that line, Article 30(2) requires open interfaces free of charge, and nothing more.
Your managed database, your queue, your identity layer and your serverless runtime owe you an export and an API. They do not owe you a working replacement. The free exit buys you your data in a “structured, commonly used and machine-readable format” under Article 30(5), plus the documentation to interpret it. Turning that into a running system inside 30 days is an engineering project, and AWS clause 2.6 is explicit that it is yours: you are responsible for “deciding the means of, and performing the identification, extraction, export, import and implementation” of the data.
What to do before January
Find out which of your accounts qualifies. Account country and billing address are the gate, and in group structures the answer is often no.
Write the notice period into your risk register as a number. If your provider wants two months, your fastest lawful exit is about 90 days, and any continuity plan that assumes otherwise is wrong.
Retrieve the exit forms now and put the URLs somewhere findable: both processes begin with a form and a support agent, not a console button. Then inventory what sits outside the regime: preview services, custom-built platforms, anything billed through a non-EU entity.
Then run the part nobody schedules. Take one non-trivial service, export it through the interfaces you are actually entitled to, and try to stand it up somewhere else. The gap between the export and the running system is your real switching cost, and it is the only number here that the Regulation cannot reduce for you.
REPTILEHAUS builds and moves infrastructure for companies across Ireland and the EU, covering cloud migration, DevOps and the unglamorous exit-readiness work that turns a switch into a decision rather than a crisis. If you want to know what your 30 days would genuinely look like, get in touch.
📷 Photo by Tolga Ahmetler on Unsplash
