Access by Design: What Changed on 12 September 2026

Since 12 September 2026, a new design obligation applies to connected products placed on the EU market: product data must be accessible to the user by default, easily, securely, free of charge, and where relevant and technically feasible, directly.

What "placed on the market" means

The obligation attaches when a product is placed on the EU market from that date forward. Devices already in the field before the date are not retroactively redesigned, but the moment you ship a new model, a substantially modified version, or new stock into the EU, the clock is running on that product. Treating existing inventory as safe forever is a mistake; treating the rule as applying only to gadgets invented after 2026 is also a mistake.

What the obligation asks of engineering

The regulation does not prescribe a specific interface, but in practice teams satisfy it with one or more of:

• a local access mechanism on the device itself (an API, a port, an on-device export),
• a user-facing export in the companion app or cloud backend, producing structured, machine-readable data,
• documented access procedures where direct access is genuinely not technically feasible, with the justification written down.

"Easily accessible" is doing real work in that sentence: a data request process that takes weeks of support tickets is unlikely to qualify.

Who carries the duty

The manufacturer of the connected product primarily, but related-service providers (the app or platform the device depends on) sit inside the same data-sharing framework, and in many products the software partner is the only party actually capable of building the access path. Contracts between hardware and software partners should say whose job it is.

Pre-contractual transparency

Alongside design duties, users must be told before purchase what data the product generates, how they can access it, and whether the manufacturer intends to use it or share it with third parties. That is a documentation task: a data transparency notice on the product page or in onboarding.

Retrofit is expensive; documentation is cheap

If your product shipped without an access path, the engineering fix has a real cost. But a large share of access-by-design compliance is paperwork, transparency notices, access policies, documented justifications, and that part can be done in days, not quarters. Our free assessment tells you which side of that line your gaps are on, and the pack contains the policy and checklist templates for the paperwork half.