From September 12, 2025, the EU Data Act will redefine the rules for data access in all industries where connected products and services are becoming widespread. The HVAC industry will be no exception.

Understanding the full implications of the Data Act is not just a regulatory compliance, but a real strategic necessity for all stakeholders operating in the HVAC industry.

The entities involved by the Data Act in the HVAC Industry

In the HVAC industry, as in all others, the Data Act mainly involves 3 types of actors:

• Data holders, typically manufacturers of connected HVAC products and systems (boilers, heating plants, air conditioners, heat pumps, ventilation systems, etc.) sold in the EU market, even if they are headquartered outside the EU.
• ‍Users of connected HVAC products and systems sold in the EU market. This includes both private individuals (users of domestic products) and businesses (users of high-power systems). Users are not only customers who own the products, but anyone who has a contractual right to use the product. Users will have the right to access raw data and to ask data holders to share it with third parties.‍
• Third parties who may be recipients of the data, at the user's request, such as:
  
  • Providers of Apps and software for Smart Home or Smart Building / BMS (Building Management Systems)
    
  • Providers of software and services for energy consumption analysis and efficiency‍
  • Providers of installation, assistance, and maintenance services (TAC) for HVAC products and systems
  • Suppliers of spare parts for HVAC systems and products subject to periodic replacement (e.g., filters)
  • Energy providers / Utilities
  • Insurance companies

The broader purpose of the Data Act

The Data Act is not simply another European regulation we must comply with. It is a fundamental pillar of a broader strategic initiative: the European data strategy.

The European Commission conceived this law to stimulate an economy of data and data-based services. It does so by establishing clear rules, in line with EU values, to protect all involved parties and encourage them to invest in the production, sharing, and transformation of data into added value.

The most significant effect will be the expansion of entities enabled to provide data-driven services. The law guarantees third parties designated by users access to raw data without discrimination, ensuring each entity has the same opportunities and eliminating dominant or monopolistic positions on data. In this scenario, users will be free to choose who provides them with services, which, thanks to free market dynamics, will lead to a proliferation and continuous improvement in the effectiveness and value of those services.

In the HVAC industry, this will concretely translate into increasingly effective, high-performing, and competitive offers for assistance, maintenance, system management, energy efficiency advisory, and much more.

To learn more about the strategic pillars of the Data Act, you can read our post: EU Data Act, a strategic choice.

Obligations, threats, and opportunities for data holder manufacturers in the HVAC Industry

Data holders, typically manufacturers of connected HVAC products and systems or other entities to whom the management of the centralized IoT system is delegated, are at the base of the data ecosystem. The Data Act poses significant challenges for them, but simultaneously opens the door to significant new strategic opportunities.

Main Obligations

The Data Act imposes several obligations on data holders, which can be classified as follows:

• ‍Definition of contractual terms between all involved parties, primarily with users and third parties.‍
• Design of connected products and systems to ensure data access to users "by design."‍
• Production of clear documentation to allow data recipients to correctly interpret shared data.‍
• Technical implementation of data sharing functions with users, third parties, and public bodies.‍
• Management of the collection of fees established for data sharing with third parties  (this is not really an obligation, but an opportunity that would be a shame to waste).

The core of the Data Act is Article 5.1, which gives the user of a connected product the right to ask the data holder to share raw data with a third party of their choice.

To learn more about on specific obligations, you can read our guide: EU Data Act Implementation.

Threats

• Loss of exclusive access to data: The most direct threat for data holder manufacturers is the end of exclusive access to raw data generated by their connected HVAC products and systems. The regulation requires opening access to third parties, at the request of users, who can then exploit the data even outside the manufacturers' service channels and digital platforms.
• New competition in digital and connected after-sales services: By liberalizing data access, the Data Act will favor the expansion of entities enabled to provide digital and connected after-sales services, which will compete with those provided by data holder manufacturers.
• Technical complexity and adaptation costs: Adapting the IoT system to allow third parties easy, secure access to data in standardized and interoperable formats requires investments in API development, authorization management systems, new workflows, and user interfaces.

Opportunities

• Monetization of raw data sharing: The first and most direct opportunity is the possibility of monetizing sharing of raw data with third parties, distinguishing between SMEs (e.g., small TACs) and Large Enterprises (e.g., utilities), as provided by law.
• Upselling of processed data with value-based pricing: Manufacturers can leverage their unique expertise and investments already made in data processing and analysis to offer third parties processed data (e.g., detailed energy consumption analyses). This approach, with value-based pricing, can generate potentially much higher revenues than just raw data sharing.
• Upselling of remote control and configuration functions: Offering third parties also remote control and configuration functionalities for systems, in full compliance with security rules and with the transparent consent of the user.
• Upselling of a complete management system: Offering third parties not just raw and processed data, but a comprehensive system for managing HVAC product-related workflows (e.g., advanced digital diagnostics, troubleshooting, digital maintenance logbooks, digital product passports).
• Playing the role of the third party: Manufacturers who have already invested in digital and connected services have the opportunity to extend their offering also to users of connected products and systems from other manufacturers.

In summary, far from being in antithesis, the sharing of raw data with third parties and the parallel development of their own value-added digital and connected services represents the main strategic opportunity for data holder manufacturers. The key is to adopt an integrated vision that leverages the Data Act as a catalyst for developing and strengthening their connected services strategy.

Action plan for HVAC data holder manufacturers

To address the challenges and seize the opportunities of the Data Act in a structured way, data holder manufacturers in the HVAC industry should activate three working groups: strategic, legal, and technical.

Strategic Working Group

This group focuses on the long-term vision and business-impacting decisions. The choices of the legal and technical groups will depend on the decisions made in this group.Key points are:

• Define the connected services strategy. To learn more about defining a connected services strategy, you can read our guide: How to design a Connected Services strategy.
• Define the types of digital offerings to third parties.
• Evaluate the extension of connected services to users of products from other manufacturers.

Legal Working Group

This group deals with regulatory compliance and the definition of contractual agreements.Key activities are:

• Update existing contracts with customers.
• Define the new contracts with third parties.

Technical Working Group

This group is dedicated to the analysis and implementation of all technical functions necessary for managing sharing requests to third parties, authorizations, data sharing, and monetization.Important activities are:

• Map raw data and prepare technical documentation.
• Extend the functionalities of the IoT system based on decisions made in the strategic and legal groups.

In this context, the adoption of ready-made and compliant platforms, such as Servitly, can represent a significant competitive advantage. It allows dedicating most of the energy and resources to important strategic decisions that will directly impact the success of one's connected services strategy, without wasting time on complex developments whose sole purpose is to achieve regulatory compliance.

Opportunities for third parties in the HVAC Industry

For the numerous third parties operating in the vast ecosystem of the HVAC industry – from small local maintainers (TAC) to large utilities, from building automation system providers to smart home App developers – the Data Act presents a great opportunity to expand their data-driven services, improve operational efficiency, and compete on a more level playing field.

The main opportunity for these entities lies in the possibility of accessing operational, performance, and diagnostic data from a wide range of HVAC systems, from any manufacturer, and leveraging such data to create added value.

Here are some specific types of third parties in the HVAC industry and the concrete opportunities that the Data Act enables for each:

• Providers of Apps and software for Smart Home or Smart Building / BMS (Building Management Systems) → they can integrate data from HVAC products and systems of different brands into their solutions; in this way, they can enrich analysis tools and offer users unique interfaces to view the status and data of all their products/systems, regardless of the manufacturer.
• Providers of software and services for energy consumption analysis and efficiency → they can have direct access to detailed data on energy consumption, usage habits, and environmental parameters of HVAC products and systems; in this way, they can make their solution or consultancy much more accurate.
• Providers of installation, assistance, and maintenance services (TAC) for HVAC products and systems → they can radically transform their operating model; access to real-time or historical data of a system (error codes, operating parameters, operating hours) allows for more precise and faster remote diagnostics, reducing the probability of wasted trips and reducing intervention times; this improves service reliability, reduces downtime for the customer, and optimizes the planning and use of technical resources; furthermore, real-time remote monitoring allows them to offer and sell "premium" assistance services to their customers, where the customer completely delegates the monitoring of the HVAC system/product to the service center, which will intervene proactively in case of faults or anomalies.
• Suppliers of spare parts for HVAC systems and products subject to periodic replacement (e.g., filters for air conditioning systems or ventilation systems) → they can leverage operational data from connected products and devices to offer users recurring supply services in line with the actual use of the system; this simultaneously ensures peace of mind for the customer, who will no longer have to worry about the ideal moment for replacement, and a more robust and regular supply over time.
• Energy providers / Utilities → they can leverage access to detailed data on the use of HVAC systems to offer innovative services to their customers, such as personalized energy tariffs based on usage habits.
• Insurance companies → they can use usage, operation, and maintenance data to more accurately assess the risk associated with a system; this could lead to the offering of more personalized insurance policies (for instance with reduced premiums for well-maintained or monitored systems) or facilitate claims management by having access to objective data on the system's status at the time of the fault.

Action plan for third parties

To best capitalize on the opportunities offered by the Data Act before others, third parties should:

• Identify existing connected products used by customers that generate raw data relevant for their services.
• Contact data holders of these products to understand the conditions and methods for sharing raw data.
• Based on the available data, define their connected services strategy. To learn more about defining a connected services strategy, you can read our guide: How to design a Connected Services strategy.
• Equip themselves with a DPS (Digital Product-Service system) (such as Servitly) specifically designed to harness data to implement and offer connected services.

Conclusion: the data-driven future of the HVAC industry

In summary, the EU Data Act is not just a new regulation, but a powerful catalyst for data-driven innovation and growth in the HVAC industry. For manufacturers, the challenge is to transform a potential obligation into an economic growth strategy, exploring new forms of monetization and collaboration. For third parties, unprecedented opportunities open up to innovate and offer value-added services based on data. All of this will lead to growth in the entire HVAC industry and tangible benefits for end-users.

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