Commission C/2025/5026 — Vehicle data

Commission guidance on how Chapter II of the Data Act applies to vehicle data and automotive-sector access rules.

Authority	European Commission
Reference	C/2025/5026
CELEX	52025XC05026
Legal basis	Chapter II Data Act; Regulation (EU) 2023/2854
Status	Published Commission guidance; non-binding
Published	15 September 2025
Source	EUR-Lex
Documents	Commission page; PDF

Scope

This Commission guidance explains Chapter II of the Data Act as it applies to vehicle data in the automotive sector. It addresses original equipment manufacturers, suppliers, aftermarket service providers, insurance providers and other automotive stakeholders.

The guidance is sector-specific. It should not be treated as a general Chapter II interpretation for every connected-product sector without a separate source check.

Key points

• The guidance focuses on data generated through the use of connected vehicles and related services.
• It explains how user access, third-party data sharing and data-holder obligations under Chapter II apply in an automotive context.
• It distinguishes the Data Act's vehicle-data access rules from sectoral type-approval, repair and maintenance, data-protection, trade-secret and cybersecurity frameworks.
• It treats Chapter II as horizontal legislation, but applies it to automotive facts and terminology.
• It supports implementation after the Data Act application date of 12 September 2025.

Implementation boundaries

The guidance is useful for classifying vehicle-data scenarios, but it is not a general-purpose checklist for every connected product. Product output should use it only where the detected facts show an automotive context or where an assumption is explicitly labelled as automotive-sector specific.

For a vehicle-data workflow, the relevant facts normally include the actor's role in the vehicle ecosystem, whether the data is generated by use of a connected vehicle or related service, whether the user is asking for direct access or third-party sharing, whether trade-secret or cybersecurity restrictions are invoked, and whether the requested access sits inside an existing sectoral access regime.

The guidance should be read with the Data Act itself. It does not create a new standalone right outside Chapter II, and it does not settle every interface with GDPR, trade-secret law, type-approval law, repair-and-maintenance access rules, or cybersecurity duties. Where those regimes overlap, downstream compliance output should preserve the overlap rather than collapsing it into a single "Data Act permits/forbids" conclusion.

Product use

For Legal Pack generation, this page is a source for automotive connected-product data access and sharing analysis. It can support review-ready prompts and checklists for:

• identifying whether the facts involve vehicle data generated by use of a connected product or related service;
• separating user access requests from user-directed third-party sharing requests;
• asking whether an OEM, supplier, aftermarket service provider, insurer or other automotive stakeholder is the relevant actor;
• flagging when GDPR, trade secrets, cybersecurity, type approval or repair-and-maintenance rules need a parallel review;
• preserving the non-binding status of Commission guidance.

The page must not be used to state that a product is compliant. It can only ground a review item, cited assumption or provision-linked draft artifact.

Source-use posture

When this guidance is cited in generated work, the citation should identify it as Commission guidance accompanying the Data Act and not as a delegated or implementing act. The stronger source for mandatory obligations remains the relevant Data Act article.

Pre-adoption note

This is the only Data Act guidance located in the July 2026 survey that is both OJ-published and specific enough to ingest as a Level 3 object. Other Commission support pages remain useful survey sources, but they are not adopted Level 2 acts.

Relevant Data Act articles

• Article 3 — Obligation to make product data and related service data accessible to the user
• Article 4 — Rights and obligations of users and data holders to access, use and make available product data and related service data
• Article 5 — Right of the user to share data with third parties
• Article 6 — Obligations of third parties receiving data at the request of the user
• Article 7 — Scope of business-to-consumer and business-to-business data sharing obligations

Full document

Available on EUR-Lex.