Essay · 8 November 2026 · 5 min read
Your exit page is a sales page
From 12 January 2027, providers of data processing services cannot charge customers to leave. Not a reduced fee, not an egress line dressed up as infrastructure cost. Article 29 of the EU Data Act says that from that date providers "shall not impose any switching charges", and it reaches any provider serving customers in the EU, wherever the provider itself is based.
The expensive part is not the lost fee. It is that the same regulation makes you publish how leaving works, in your own words, where anyone can read it. Article 26 requires you to give customers the available switching and porting procedures, the methods and formats, and the restrictions and technical limitations known to you. Article 29 requires the charges information to be publicly available, for example in a dedicated section of your website. So within about two months, every serious provider in this category will have a page explaining how hard it is to get out, and your buyers will read yours alongside three others.
The page about leaving is the one page on your site that nobody suspects of being marketing.
What the Data Act makes you publish
Article 25 gives the exit a shape rather than a sentiment. A maximum notice period of two months to start a switch. A transitional period of 30 calendar days to complete it, which the customer may extend once. If 30 days is not technically feasible, 14 working days in which to say so, justify it and propose a longer period of up to seven months. After the transition, at least 30 calendar days in which the customer can still retrieve their data. Article 26 also asks for an up to date online register of the data structures, formats and open interoperability specifications that your exportable data comes in.
Read that as a brief and it is oddly familiar. Dates, states, a countdown, a destination, a real file at the end, and an honest account of what will not travel. It is onboarding, played backwards. Most providers have spent years designing the first and almost no time on the second.
Two honest caveats. This is a design argument, not legal advice: your counsel owns the wording, you own the page. And the rules are still moving at the edges, since a Council compromise text in the Digital Omnibus package would add narrow transitional exemptions for contracts concluded on or before 12 September 2025, and is not final.
Buyers read the exit before they buy
You cannot inspect a server from a browser, so buyers judge the things they can see: the panel, the pricing page, the forms. The exit belongs on that list, and technical buyers put it there early, because they have been stuck before and the memory is specific. The export that produced a format nothing else would read. The ticket queue that got slow in the last fortnight of the contract. The invoice for retrieving data they had already paid to store.
A free migration offer is a promise about arriving, and everybody makes it. A clear account of leaving is a promise about the end of the relationship, and it is the more credible of the two, because it is the one that costs something to write.
The two exit pages this category is about to ship
The first will be written by counsel, filed in the footer beside the acceptable use policy, and set as numbered clauses with the word "shall" in them. It will satisfy the regulation. It will also tell a prospect that leaving is a legal event rather than a supported one, which is not the impression you want left with somebody who is still deciding.
The second will be written as product documentation, because leaving is part of the product. It answers what a person actually wants to know: how I start, how long it takes, what comes out, in what format, what does not come out, who does which part, and what happens to my data afterwards. Those are the same questions the regulation makes you answer. The only difference is the reader you had in mind.
What belongs on the page
- The procedure, as steps with real timings, including your own notice period rather than the maximum the law allows.
- The export: formats, the register of data structures, and a link to documentation a competent engineer could work from.
- The known limitations, named. The configuration that will not port. The feature with no equivalent anywhere. The logs that only go back as far as your retention policy.
- What happens after. The retrieval window, and the date you delete.
The third of those is the one that sells. Any provider can publish a procedure. Writing down the three things that will not come with you reads like somebody who has done this for a customer, recently, and is not pretending it was tidy.
Documenting the exit does not cause churn
The worry is that explaining the way out teaches people to use it. Churn in this category is almost never decided on your website. People leave because something broke, or the product stopped fitting, or the panel made a routine job slightly worse every day for a year. A switching fee never fixed any of that. It delayed the paperwork and bought resentment, and from January it is not on the table in any case.
What the fee did hide was how bad the exit was. That part is about to be written down, in public, by you. All that is left to decide is whether it reads like a supplier who expects to see the customer again.