Manufacturing connected products: what data must you give customers from September 2026?

The European Union Data Act requires, from 12 September 2026, certain connected products and related services placed on the market after that date to be designed to allow access to data in accordance with Article 3(1). For manufacturers, this means planning how customers will view and retrieve data generated by their equipment during development, rather than treating access as an extra feature to add at the end.

The solution may include a customer portal, an API or a combination of both. The key requirement is that access must be easy, secure and free of charge, with data provided in a machine-readable format, subject to the applicable requirements.

Check whether your product is affected

Start by identifying what you sell and the role your business plays. The access-by-design obligation applies to manufacturers of connected products and providers of related services. Businesses acting solely as distributors are not covered by this obligation simply because they distribute the product.

If you manufacture machinery, industrial equipment or devices that generate operational data, review what information the equipment produces and how customers can access it. You should also assess the digital services linked to the product, as these may fall within the scope of the obligations.

The date matters: the design requirement applies to connected products and related services placed on the market after 12 September 2026. This provision does not require you to retrofit everything sold before that date.

There are also exemptions for micro and small enterprises under Chapter II. Check whether your business meets the relevant conditions before deciding how to approach the requirement.

What does data access by design mean?

Article 3(1) needs to be translated into specific technical decisions. It is not enough for the manufacturer to be able to access the data internally. You need to consider how the user will access the data to which they are entitled.

Review these criteria alongside the equipment’s characteristics and the data it generates. The obligation does not mean publishing all device information indiscriminately on the internet. Access must be designed in line with the applicable requirements and necessary security measures.

How can you build access through a portal or API?

A typical implementation can combine a customer interface with a backend service that manages permissions, retrieves data and delivers it in the required format.

The customer portal allows users to sign in, select their equipment and view or download available data. This is useful when you need an accessible experience for customers without specialist technical knowledge.

The API allows the data to be integrated into other systems. For example, a customer may need to use it in maintenance, analytics or industrial management tools. The API should define how requests are authenticated, which data can be retrieved and how errors are handled.

The data backend connects the device or its related services to the access mechanism. You need to decide how data is stored, how it is linked to each device and what happens when a connection fails or information is missing.

Document these decisions before development:

• Identify the data generated by the product and where it is stored.
• Define which users can access each device.
• Decide whether to offer manual downloads, API access or both.
• Establish output formats and validation rules.
• Design authentication, permissions and access logging.
• Plan for errors, incomplete data and service interruptions.

If you are turning a technical demonstration into a real product, our guide to moving from an AI demo to a project can help you organise architecture and development decisions.

What should you decide before your next product launch?

Do not leave data access until the final stage of the project. If the product architecture does not account for this requirement, adding it later may require changes to firmware, the backend, user management or associated digital services.

Include data access in the product specifications and coordinate the hardware team with those developing the software and connected services. Also define who will maintain the API or portal, how changes will be managed and which tests must be completed before the equipment is placed on the market.

Data access can form part of a wider integration architecture. If your product needs to exchange information with other applications or services, read our guide to MCP in 2026: the standard and the NSA guide to distinguish integration choices from the specific requirements for data access.

What decision should you make this week?

This week, select the connected product you plan to launch and map the journey of its data from the device to the user. Check whether your business falls within the scope of the obligation, identify any relevant exemptions and decide whether access will be provided through a portal, an API or both. This article provides general technical information, not legal advice; confirm the scope of the Data Act and the requirements applicable to your circumstances with a specialist.

If you need to design a data portal, develop an API or automate the integration of connected equipment, tell us how your product works and which data your customers need to access.