On 12 September 2025, Regulation (EU) 2023/2854 — the EU Data Act — became applicable. Twelve months later, with the automotive sector having structured to respond to the new regulatory framework, it’s a good moment for a pragmatic balance: what kept its promises, where it worked less well, and what to expect for the coming months.
This article looks at the application year from the European fleet manager’s perspective — those who run a commercial fleet, choose telematics providers, and have a budget to justify. Not a legal analysis, but an operational check: was the Data Act useful? In what form? Which aspects are worth pushing harder?
What actually happened in twelve months
Summarising September 2025 - September 2026 in essence, three dynamics dominated.
First dynamic: Cloud OEM activation exploded. Between October 2025 and March 2026, the main automotive groups — Stellantis (via Mobilisights), Volkswagen Group, BMW, Mercedes-Benz, Ford, Renault, Hyundai — completed their API infrastructure to expose telematics data to third-party providers. Stellantis Mobilisights, according to published data, saw cumulative activations move from a few thousand VINs at end-2025 to over 800,000 VINs activated by summer 2026 — a 100x factor in nine months. Similar numbers, though not always published, for VW Group and BMW.
Second dynamic: third-party providers flourished. On the wave of the opening, dozens of European fleet management systems integrated Cloud OEM feeds into their platforms. Optivo did so for the main 12 automotive groups in the first half of 2026. Cargoful, Targa Telematics, Geotab — all major players followed similar trajectories. Competition between providers on Cloud OEM is today significantly higher than in 2024-25.
Third dynamic: the aftermarket OBD market held on pre-2019 vehicles but slowed on new ones. Aftermarket hardware installations on post-2019 vehicles progressively declined — not for ideological choice, but for economic evidence: if data is available in the cloud without installation, OBD adds cost without differential value (except for specialist use cases requiring CAN bus). The aftermarket OBD segment isn’t dead — it continues to serve pre-2019 vehicles and use cases needing dedicated hardware — but it’s in a consolidation phase.
Where the Data Act kept its promises
Three areas where the Regulation worked as expected.
Data access: achieved
The right to access operational connected-vehicle data is today effectively exercisable for most mainstream brands. For a fleet manager with a Stellantis or VW Group fleet, requesting data access and nominating a third-party provider is a structured practice, with predictable timing and costs. In 2024 it was a case-by-case negotiation; in 2026 it’s almost a commodity.
Concretely, on a fleet of 30 Fiat Ducato vans from 2022 on operational lease, the data access request and activation of the flow to Optivo today takes 5-10 business days end-to-end, against the weeks (often months) of 2023.
Portability: respected
The right to data portability — the ability to export historical data and port it to another provider — has been implemented by telematics providers as standard. Changing fleet management provider in 2026 is today a technically feasible operation in a few weeks, without loss of historical data collected. The proprietary lock-in on which old-style providers based their retention has largely fallen.
For a company, this means the choice of a provider is today more reversible than it used to be — which paradoxically lowers the entry barrier for those who want to start using a serious system (I know that if I make a mistake I can change).
FRAND competition: started
Manufacturers, with exceptions, have structured a data-access offering with FRAND (fair, reasonable, non-discriminatory) prices and conditions. Public or semi-public tariffs for Mobilisights’ Fleet Plus Data Pack, VW Group APIs, BMW data feeds are not “punitive prices” designed to shut out competition — they’re aligned with real infrastructure costs and generate competition between third-party providers on added value (not on data access itself).
In coming months this aspect will need monitoring — the incentive to discriminate at worst efficiency exists — but the first application year hasn’t seen the serious enforcement cases some feared.
Where promises were partial
Three areas where the Data Act worked less well than expected.
Manufacturers resistant on specific segments
Not all automotive groups were equally collaborative. Some manufacturers — especially those with their own premium telematics service they directly monetised — structured the Cloud OEM offering with slower timing and higher tariffs than the sector benchmark. Without naming names, there are at least two mainstream European automotive groups where activation takes 2-4 weeks per vehicle (vs the 3-5 days of Stellantis and VW), and where tariffs are 30-50% above benchmark.
This doesn’t break the Data Act — tariffs remain in FRAND territory — but highlights that the regulation alone doesn’t solve competitive dynamics. Market pressure (the fact that customers choose telematics providers leaning on the more collaborative manufacturers) does more than regulation in levelling service quality.
Sector guidelines still incomplete
The European Commission published the Vehicle Data Guidance in late 2024 and issued additional sector clarifications during 2026, but some areas of uncertainty remain:
- What exactly falls within “operational data” of the vehicle (e.g., EV energy consumption data for ESG purposes: is it accessible as operational data? Is it “derived data” requiring licensing?)
- How revoked consent is handled when a vehicle is on multi-stakeholder lease (user A revokes, co-user B maintains — who prevails?)
- What happens to data after vehicle disposal on the second-hand market (does historical data stay with the company that collected it, or revert in some form to the new owner?)
These are areas where practical cases are clarifying standards, but case law is still limited and providers apply slightly different interpretations.
Uneven adoption across EU countries
The EU Data Act is a directly applicable regulation in all EU countries — no national transposition required. But operational adoption has been very uneven: Italy, Germany, France, the Netherlands saw rapid activations and structured market; some Eastern and Southern European countries had longer cycles, both due to local telematics market maturity and scarcity of local third-party providers.
For cross-border fleets, this means the Data Act advantage is today full only if the fleet operates predominantly in countries where the market has structured. In less mature ones, Cloud OEM is theoretically available but operationally less fluid.
What early movers learned
Companies that started activating Cloud OEM in the early months after September 2025 accumulated twelve months of practical experience. Three recurring lessons.
Lesson one: Cloud OEM value scales with size. On small fleets (5-10 vehicles), Cloud OEM operational advantage is real but marginal — it doesn’t dramatically depart from aftermarket OBD. On medium-large fleets (30-100+ vehicles), the difference becomes significant: turnover scalability, multi-brand management, dashboard consolidation. Companies that tried Cloud OEM on 5 vehicles were often indifferent; those who tried it on 50 became promoters.
Lesson two: consent chain is the bottleneck. Almost all activation difficulties, over twelve months, came from the contractual side — tripartite leases with ambiguous consent chains, hard-to-deactivate rental-provider telematics contracts, formalisation of the authorised company representative. The technical side was rarely the problem. Those starting today can avoid half the delays simply by sorting contracts before starting activation.
Lesson three: mixed mode is operational reality. Almost no fleet in 2026 is “100% Cloud OEM”. Operational reality is mixed mode: Cloud OEM on natively connected vehicles, plug & play OBD on pre-2019 vehicles, CAN bus on specialist cases (anti-theft, cold chain, heavy telemetry). Companies looking for “all-in-one” mode clash with exceptions and waste time; those accepting mixed mode (with a single dashboard handling all three sources) are operationally more efficient.
What to expect in the next 12 months
September 2026 - September 2027: reasonable anticipations.
Coverage expansion: automotive groups not yet active (Mazda, Honda, Subaru, Chinese manufacturers entering the EU market) should structure the Cloud OEM offering in coming months. Total coverage of post-2019 models on the EU market should move from current 75-80% to over 90% by end-2027.
Reference legal cases: the first significant disputes on Data Act interpretation are expected in the 2026-2027 period. Typical cases: manufacturers applying tariffs perceived as non-FRAND, lease contracts with data exclusivity clauses deemed incompatible with the Regulation. Decisions will serve as clarification for the sector.
Data format standardisation: today, every manufacturer exposes data in its own proprietary format; the third-party provider handles normalisation. The Commission is working with sector stakeholders (ISO, ACEA, third-party providers) to standardise formats — full standardisation won’t happen, but a base level of interoperability will lower costs for third-party providers.
Perimeter extension to heavy and off-highway vehicles: the first year was dominated by passenger cars and light commercial vehicles. Heavy vehicles (trucks >3.5t) and off-highway (agricultural, construction) have more fragmented and less structured native connectivity. Cloud OEM integration on these segments is coming but is 12-24 months behind the car/LCV segment.
For fleet managers: where to act now
Putting it all together, for the European fleet manager in 2026 the operational message is:
- Census the fleet against the Cloud OEM perimeter (how many post-2019 vehicles, which manufacturers). Know exactly how many of your vehicles are candidates.
- Sort contracts of lease/LTR before activating. A clear “Data Act compliance” clause saves weeks of limbo.
- Plan a mixed mode instead of seeking all-in-one. One dashboard, three modes (OBD/CAN/Cloud OEM) depending on the fleet part.
- Don’t wait for perfection: the Data Act is in dynamic equilibrium, more clarifications will come in coming months. Waiting means paying double telematics costs in the meantime.
To take a first step with an initial census — understand how many of your vehicles are activatable today on Cloud OEM and which aren’t — see Optivo’s three tracking modes or book a VIN assessment. The first balance on your fleet arrives within 24 business hours.
Read next:
- EU Data Act for fleets: what changed on 12 September 2025 — the original May 2026 article explaining the regulatory framework, fleet owner rights, and steps to start exercising them
- Fleet tracking without hardware: the complete 2026 guide — overall picture of Cloud OEM, the mode that drove activations in the first year post-Data Act
- Cloud OEM Stellantis with Mobilisights — deep dive on the most frequent operational case in Europe
- Cloud OEM for leased fleets: 5 things to know — the contractual points to clarify to accelerate activations