Make Exit Operational Before You Need It
An exit-ready programme is the practical test of the EU Data Act's cloud-switching promise. This chapter asks how a customer keeps the portable surface, provider duties, technical tests, costs, and legal boundaries usable over time, and it turns those elements into an operating loop with owners and evidence rather than a detached compliance checklist. The goal is a defensible readiness judgment before anyone starts the notice period.
Build an exit record that can answer a real question
The first artifact should not be a document called “cloud exit plan” that no team can use. It should be a living record of one service, one customer relationship, and the destinations the customer could realistically choose. Its first question is classification: what data-processing service is being provided, what service type is it, and which parts of the environment does the source provider control? The answer determines whether the relevant technical test concerns infrastructure-level functional equivalence, open interfaces and structured export, or a deliberate change in operating model.
The second question is ownership. Name the customer, source provider, destination provider, and the people or third parties responsible for the target environment. State whether the desired outcome is a full switch, a move to on-premises infrastructure, unbundling of one service, or parallel use of two providers. This prevents an implementation team from assuming that the source provider will rebuild the destination, and it prevents a procurement team from treating a continuing multi-cloud connection as though it were a completed exit.
The third question is what must move. Keep exportable data, digital assets, and protected or excluded material in separate fields. For exportable data, record the inputs, outputs, and use-generated metadata that the service makes available for the switching purpose. For digital assets, record applications, configurations, access and control information, or virtualization artifacts only with the customer's independent right to use them. For every exclusion, record the reason and the replacement consequence. A provider's internal security material may be protected, but the customer still needs to know whether the missing item requires a new control, a different application, or an architectural redesign.
The fourth question is when each action occurs. Put the maximum notice period, transition period, retrieval period, and erasure condition on the same record as the assets. The contract must support the customer's exit strategy, identify portable categories and permitted exclusions, and describe the provider's assistance and continuity commitments. The provider's information must identify available procedures, methods, formats, known restrictions, technical limitations, and the relevant data structures and standards in an up-to-date online register. Those are not separate legal facts to be filed away. Together they form the inputs to a migration runbook.
A practical record for an order-processing service might have a source-side export description, a rights register for the application and deployment artifacts, a destination owner, a list of shared functions to validate, a continuity contact, and a decision about retention and erasure. It should also record what it does not know. If the provider has not identified the format of use-generated metadata, the gap is an information problem. If an application licence cannot be used at the destination, the gap is a rights problem. If no one can state how to recognize a successful outcome, the gap is a validation problem. Naming the gap is more useful than marking the entire service “portable.”
The record should then drive a rehearsal rather than wait for a dispute. A sensible rehearsal begins with a representative export from the source service and ends with an isolated destination validation. The customer and destination provider transform and upload the material; the source provider supplies the source-side procedures, formats, and assistance that the law places within its responsibility.