Synthetic Law

Guidance on Vehicle Data under EU Data Act

Sep 12, 2025By Dariusz Czuchaj
Dariusz Czuchaj

From today, the Data Act applies across the EU, reshaping how data from connected devices – including vehicles, robots, energy infrastructure – must be shared.

🚗 Just before the deadline the European Commission released 🎈 Guidance on Vehicle Data 🎈 and ... we have already spotted some real issues... 

📡 Personal vs. non-personal data: the same streams may be “technical” in one context, but personal under GDPR in another. The boundary depends on use, not on the nature of the data – especially in the light of the recent judgment (EDPS vs SRB) which underlined the subjective nature of what qualifies as personal data. 

💣 Pre-processed vs. derived data: users are entitled to raw and simple processed data (averages, unit conversions), but not to “derived” outputs (eco-score, ADAS object detection). The line is thin – map-matching GNSS is in scope, while collision trajectory analysis is not. This puts hasztag#ADAS providers in a tricky position, as much of their value is built on exactly the type of “derived” insights that fall outside mandatory sharing.

🌍 Important: these obligations apply not only to EU entities but also to non-EU manufacturers and operators if their vehicles are offered on the EU market. 

Stay tuned for more !

#DataAct #Automotive #VehicleData #SyntheticLaw #RegulatoryCompliance