European Union: European Commission non-binding model contractual terms on data access and use and non-binding standard contractual clauses for cloud computing contracts

Progress

Current status
adopted
19 Nov 2025 adopted
08 Jul 2025 under deliberation
02 Apr 2025 under deliberation

Scope

Implementers
Austria
Belgium
Bulgaria
Croatia
Cyprus
Czechia
Denmark
Estonia
Finland
France
Germany
Greece
Hungary
Ireland
Italy
Latvia
Lithuania
Luxembourg
Malta
Netherlands
Poland
Portugal
Romania
Slovakia
Slovenia
Spain
Sweden
Policy Area
Data governance
Policy Instrument
Data protection regulation
Regulated Economic Activity
infrastructure provider: cloud computing, storage and databases
Government Branch
executive
Government Body
other regulatory body
central government
Implementation Level
supranational

Timeline of events

19 Nov 2025
adopted

European Commission adopted Recommendation on non-binding model contractual terms on data access and use and non-binding standard contractual clauses for cloud computing contracts

On 19 November 2025, the European Commission adopted a Recommendation on non-binding model contractual terms on data access and use and non-binding standard contractual clauses for cloud computing contracts, as provided for in Article 41 of the Data…

Source
Event type outline
Action type adoption
Government branch executive
Government body other regulatory body
08 Jul 2025
under deliberation

European Data Protection Board released statement on European Commission’s Recommendation on draft non-binding model contractual terms on data sharing under Data Act

On 8 July 2025, the European Data Protection Board (EDPB) released a statement on the European Commission’s Recommendation on draft non-binding model contractual terms on data sharing under the Data Act. The EDPB made six recommendations regarding t…

Source
Event type outline
Action type opinion
Government branch executive
Government body other regulatory body
02 Apr 2025
under deliberation

Expert Group on B2B Data Sharing and Cloud Computing Contracts released final report on B2B data sharing and cloud computing contracts

On 2 April 2025, the Expert Group on B2B Data Sharing and Cloud Computing Contracts published its final report, presenting a set of recommended non-binding model contractual terms (MCTs) and voluntary standard contractual clauses (SCCs). These model…

Source
Event type outline
Action type announcement
Government branch executive
Government body central government