Predictions for the 2026 edition of data portability unwrapped
January provides a natural break point to reflect on progress and to set new goals and plans for the year ahead. As I do this, it has got me excited about what a transformational year 2026 will be for data portability as a policy area in the tech sector, driven by a combination of regulatory interventions, technological advancements, and market developments. So I thought I would jump on the bandwagon and give you my predictions for portability related developments to look out for in 2026.
So here they are…
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OpenAI will be designated as an ‘emerging gatekeeper’ in the EU. Following the one year review of the Digital Markets Act (DMA), I expect the European Commission to move towards classifying ChatGPT as a “Virtual Assistant”, then applying a targeted subset of the DMA provisions to the service (including Articles 6(9) and 6(10)). As a result, I predict ChatGPT will implement a data portability API, supporting ongoing developer access to daily downloads of users’ data such as conversation histories. In a rapidly evolving technology context, we expect lots of discussion of scope, and anticipate greater visibility into DTI’s AI portability principles. The Virtual Assistant CPS may also be applied more widely to existing gatekeepers that operate AI powered chatbots, thereby expanding the scope of data included in their data portability tools.
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The UK will introduce a Smart Data Scheme for digital markets. This prediction is really about the when rather than the if, and I am expecting a rapid timeline from the Department for Science, Innovation and Technology (DSIT), with the necessary secondary legislation in place before the end of the year (just). That would be an extremely ambitious timeline but, for a government motivated by economic growth (and with no money to spend), it makes sense to move quickly.
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DTI’s Data Trust Registry will reach critical mass on both sides. Perhaps this is a bit of a cheat prediction. After all, it is something I am looking to influence directly, and we have already made significant progress in this direction. But nonetheless it feels sufficiently noteworthy for inclusion. I estimate that the tipping point for overcoming the ‘chicken and egg’ effects of this two-sided platform we are building will be three large platforms relying on our Registry for verification, and 30+ services registered and listed and set up for annual review. I am confident we will get there comfortably in 2026.
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Data portability use cases will be proven as commercially viable. I’m certainly not predicting an explosion of use cases with billions of users - I will save that prediction for 2027! But in this coming year I expect to see two very important developments for data portability use cases. First, a few of the most promising startups built on top of data portability APIs will become profitable and/or attract major inward investment (though we may be too early to start talking about exits). Second, a handful of existing businesses with established userbases will incorporate portability as a new feature into their offerings to enhance personalisation of their service. These early success stories will provide useful for regulators around the world examining digital market regulation.
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Portability will be trialled to support consented personalisation of ads. Perhaps as a subset of the prediction above, I foresee some ad-funded apps will trial the use of data portability APIs to power their ad targeting as a replacement for cross-site or cross-app tracking. For example, apps might request that their users share their personal data from other platforms such as Facebook, YouTube or the App Store, with explicit consent that it could be used to serve them relevant ads. Gaming seems a strong candidate for this move, given that games providers could incentivise users to share their data by giving them non-financial rewards such as extra lives or other in-game features that players might otherwise purchase through in-app payments.
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Personalised audio content will grow in popularity. The shift towards AI generated audio content going mainstream started last year, with AI generated music entering the charts and capturing headlines. While I’m sure that controversial trend will continue this year, I expect another (slightly conflicting) shift to take place that could make charts less relevant altogether. People are going to start creating and listening to their own music and podcasts, produced at the click of a button by AI powered services to their own tastes and interests. This development will drive new demand for data portability from major streaming platforms, with new AI powered content creation services seeking access to their users’ past listening, viewing and searching data to support creation of highly personalised content.
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Europe will continue to lead the way on data portability. Somewhat disappointingly, unless prediction four comes to fruition much sooner than expected, I don’t think we will reach the tipping point in 2026 where it is a no-brainer for all major tech platforms to support global availability of data portability APIs. Instead, I think we will see continued divergence between Europe (EU and UK) and the rest of the world. There will be some progress elsewhere (I hope to see at least one more existing portability API made available in the US for example) but regulatory uncertainty will stifle incentives, and the demand from developers and users in key markets such as the US will not be vocal enough (yet). As we strive to build a thriving global data portability ecosystem, this is one prediction we will be actively looking to disprove.
I look forward to returning to these at the end of the year to see how well I did. In the meantime, get in touch to let me know what you think, or even to share some predictions of your own!