RM
Ryan Malek
/

EU Data Act

A working tool for lawyers advising on the EU Data Act (Regulation (EU) 2023/2854). Hand it the facts of a matter and it returns a classification memo, a drafting starter, a verbatim regulation lookup, an applied legal analysis, or a gap audit. Every output quotes verbatim from the bundled regulation and the European Commission's FAQ rather than paraphrasing from memory. Sixteen drafting templates cover what lawyers actually draft against: Art. 3(2) and 3(3) pre-contract notices, Art. 25 data-processing-service clauses, Art. 26, 28, and 29 public pages, the three-part trade-secret refusal pack, a safety and security restriction clause, and a third-party data-sharing request. Output goes to chat by default. A one-click Word export styled for client work is available after the chat answer, with a verified-as-of stamp and live EUR-Lex and FAQ links so currency is always visible on the page.

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EU Data Act Skill

A workflow-oriented skill for lawyers advising on the EU Data Act
(Regulation (EU) 2023/2854).

The skill produces lawyer-style Word output across five workflows —
classification, drafting, lookup, analysis, and audit — citing verbatim
from bundled source texts (Regulation 2023/2854 and EC FAQ v1.4) and
pointing to the Commission's model contractual terms (Recommendation,
19 November 2025) for direct consultation.

Author: Ryan Malek
Feedback / questions: LinkedIn
Distributed via: Github, Counselcoder.com, Lawvable
Project site: counselcoder.com
License: AGPL-3.0 (see LICENSE)
This is not legal advice. See LICENSE for the full disclaimer.


Who this is for

In-house counsel and external practitioners advising on EU Data Act
compliance — including industrial IoT, automotive, medical device,
SaaS, financial services, and cloud clients.

The skill assumes the user is a qualified lawyer. It does not explain
GDPR basics, what SaaS means, or other concepts a lawyer already knows.

What it does

Five workflows, each with its own reference file:

Mode Trigger Output (Word)
classify "Is this offering a connected product / related service / DPS / overlap?" Classification memo with reasoning
draft "Draft me [pre-contract disclosure / Art. 25 clauses / refusal letter / etc.]" Editable Word document, marked as starting point
lookup "What does Article X say?" or "What is the deadline for Y?" Verbatim quote + FAQ tie-ins + cross-refs
analyze "Can my client refuse on trade-secret grounds here?" Structured legal analysis applying the framework
audit "Compare this offering against the regulation" Gap-analysis checklist with severity flags

The skill always:

  • Asks for matter-specific facts (side advised, sector, member state) before drafting, rather than relying on global config.
  • Surfaces a sectoral overlay warning when facts trigger automotive / medical / DORA / NIS2 / AI Act / CRA / other sectoral law.
  • Cites verbatim from assets/source/* (no paraphrase from memory).
  • Frames the Commission FAQ as non-authoritative in every output that relies on it.
  • Appends a short disclaimer to every Word output.

What it does not do

  • No legal advice. The skill produces drafts the lawyer reviews.
  • No sectoral lex specialis. Adjacent regimes (Reg. 2018/858, MDR, DORA, NIS2, AI Act, CRA, etc.) are flagged, not covered.
  • No member-state implementing law. Skill points to Art. 37 competent authorities; national overlays must be checked independently.
  • No multilingual output. English only. Use your own LLM for translation.
  • No automatic source updates. The skill is a versioned static snapshot. Currency is checked through the verified-as-of stamp and new Lawvable releases.

Install

Claude Code (one command)

git clone https://github.com/counselos/eu-data-act ~/data-act-skill
cd ~/data-act-skill
bash install.sh

The script symlinks the folder to ~/.claude/skills/data-act-ryan-malek/ (auto-trigger by description) and adds ~/.claude/commands/data-act-ryan-malek.md (explicit /data-act-ryan-malek slash command). Set COPY=1 to install a fixed copy instead of symlinks.

Verify with bash install.sh --check. Uninstall with bash install.sh --uninstall.

Other platforms

  • Claude Agent SDK — same folder layout; register via the SDK's skill directory.
  • Codex CLI — no native skill discovery; either cd into the folder when running codex, or open the prompt with Use the skill at /path/to/data-act-ryan-malek/SKILL.md ....
  • No agent at all — open templates and reference files directly. Python scripts run standalone.

Dependencies

Pandoc (for Word export):

# macOS
brew install pandoc

# Linux
sudo apt-get install pandoc

Word export uses pandoc with a reference template (assets/styles/lawyer-reference.docx) for proper Calibri / navy heading / page-number / table-grid styling. Without pandoc, /data-act-ryan-malek works for chat answers and lookups but the Word export step fails with a clear install message.

Python (3.10+) and these packages (only when scripts run):

pip install python-docx pypdf

The skill works offline. No network access is required for any end-user feature.

How to use

Two invocation styles, both supported:

Slash command (explicit)

/data-act-ryan-malek                                      ← shows the mode menu
/data-act-ryan-malek classify [offering description]      ← classify mode
/data-act-ryan-malek draft [what to draft]                ← draft mode
/data-act-ryan-malek lookup [Art. 25(2)(a)]               ← verbatim lookup
/data-act-ryan-malek analyze [scenario]                   ← apply law to facts
/data-act-ryan-malek audit [existing offering]            ← gap analysis

Auto-trigger (implicit)

Just describe the task. The skill's description matches phrases like:

> "I need to classify my client's connected meter under the Data Act."
>
> "Draft me an Article 25 contract clause set."
>
> "What does Article 25(2)(g) say?"
>
> "Can my client refuse this access request on trade-secret grounds?"

The model invokes the skill automatically.

There is no setup. The skill is zero-config out of the box.

The deliverable lives in chat by default. After the chat answer, the skill offers to export to Word. Word files are saved to the lawyer's current working directory under ./Data Act outputs/{date}_{type}.docx by default — never inside the skill folder. The lawyer can persist a different location with:

/data-act-ryan-malek save-here          # always save to current folder, don't ask
/data-act-ryan-malek save-to-desktop    # always save to ~/Desktop/Data Act outputs/
/data-act-ryan-malek ask-where-to-save  # ask each time (default)

Update model

This skill is a versioned static snapshot of Regulation (EU) 2023/2854, the Commission Data Act FAQ, and related sources. It does not auto-update on your machine. Updates flow through new Lawvable releases.

How you stay current:

  1. A new release is published when the European Commission ships a new FAQ version, when the Council adopts amendments, or when sectoral guidance changes affect the bundled materials. Each release updates CHANGELOG.md and the _versions.json verified-as-of date.
  2. Lawvable distributes new versions. Update notifications surface in your Lawvable client. To get the latest, redownload through Lawvable. Your matter folders and Word outputs are untouched.
  3. Every deliverable stamps a "Sources verified [date]" line. This appears at the end of every chat answer and Word memo, with the live EUR-Lex and EC FAQ URLs. If the stamped date looks old to you (more than a few months), redownload the skill before relying on the output. The verified-as-of stamp is the only signal you need; you do not have to monitor anything.

The static-snapshot model is deliberate: it keeps installation simple, never lets a background process touch your work, and puts the staleness signal directly into the work product where you can see it.

Each downloader is the maintainer of their copy

The original creator does not maintain, update, monitor, or support copies of the Skill after distribution. Each downloader:

  • Is solely responsible for the currency and accuracy of their copy.
  • May freely modify, fork, and redistribute under the AGPL-3.0 license. Note that AGPL-3.0 is strong copyleft: derivative works (including those run as a network service) must be released under AGPL-3.0 with source available to users.
  • Should remove the original creator's name from outputs they produce for clients (the Word footer is already clean of attribution).

This is by design — the skill is a starting point for your practice, not a service you are subscribing to.

Folder layout

data-act/
├── SKILL.md                # Orchestrator (read first)
├── LICENSE                 # AGPL-3.0 + legal-advice disclaimer
├── README.md               # This file
├── CHANGELOG.md            # Version-only entries
├── install.sh              # One-command install for Claude Code
├── config.json             # output_dir preference (cwd / desktop / custom path)
├── commands/
│   └── data-act-ryan-malek.md   # Slash-command definition (/data-act-ryan-malek)
├── references/             # Knowledge layer, read on demand
├── assets/
│   ├── source/             # Verbatim regulation, FAQ; SCC pointer
│   ├── templates/          # Drafting starters (md → Word via pandoc)
│   ├── styles/             # lawyer-reference.docx for pandoc styling
│   ├── decision-trees/     # Walkable Q&A
│   └── examples/           # Worked examples
└── scripts/                # Python helpers

Sources bundled

  • Regulation (EU) 2023/2854 of 13 December 2023 (the Data Act) — verbatim text
  • European Commission FAQ on the Data Act, v1.4, 22 January 2026 — verbatim text
  • Commission "Data Act Explained" page — snapshot
  • Commission Recommendation on standard contractual clauses / model contractual terms (annex), 19 November 2025 — structured pointer only (assets/source/model-contractual-terms.md); the canonical PDF is at the Commission's site and should be consulted directly for clause text

The first three are redistributed under their respective public-information regimes. The Recommendation is referenced but not redistributed.

Versioning

Semantic versioning. Major version bump on substantive FAQ revisions, regulation amendments, or scope changes. Minor for added templates, examples, references. Patch for typos and clarifications.

This release: v1.0.0. See CHANGELOG.md.