Switching cloud / data processing services seamlessly from an original service provider to a receiving can be a key requirement for certain customers in their respective situations. The Data Act Proposal addresses this. In principle, we support the Commission's objective to remove barriers for cloud-switching, which will help cloud service users to overcome vendor lock-in and dependencies on a single service provider if/where such is present, and to drive down costs of adopting a multi-cloud approach.
However, the technical and operational complexities of migrating data, applications and workloads should be taken into account when enacting such policies. Like every standard, a right to switching is to be balanced meticulously with incentives for innovation and competition for all parties involved, as well as technical possibilities and impossibilities.
It is impossible to draw a robust line between technical details and obstacles – every difference could count as an obstacle, so their significance is key. Also, technically, original service providers are not always able to ensure functional equivalence after a customer switched to a receiving service provider.
In this position paper, we offer detailed thoughts and guidance about many switching and interoperability provisions in the Data Act Proposal.