Programmable Money in Data Spaces

A manufacturer of injection moulding machines has forty units installed at a plastics processor. Each one continuously reports temperatures, pressures and cycle times to the manufacturer. Now the customer wants the same data to go to an independent maintenance provider. Since September 2025 the customer can demand this, and the manufacturer must in principle deliver. What remains open is what the manufacturer may charge, and how many small requests turn into a payment and an invoice.

What the Data Act Says About the Price

The EU Data Act has applied since 12 September 2025. It gives the user of a connected product the right to access the data of their machine and to have it shared with a third party (Articles 4 and 5). Both are free of charge for the user. From the third party, however, the manufacturer as data holder may ask for compensation. Article 9 requires it to be non-discriminatory and reasonable, and it expressly allows a margin.

Whether the margin may stay depends on the recipient. If the third party is a small or medium-sized enterprise (SME) without large partner or linked enterprises, the compensation must not exceed the cost of making the data available. This covers above all formatting, electronic dissemination and storage of the data. The amount may vary with the volume, format and nature of the data. The manufacturer must also disclose the basis of the calculation in enough detail for the recipient to check it (Article 9(7)). Either side can take a dispute over the terms to a certified dispute resolution body (Article 10).

These rules apply only where a law requires the data to be made available (Chapter III). If the manufacturer sells data voluntarily, for example on a marketplace, the price is a matter of negotiation. For the maintenance provider in the example, an SME, the cost ceiling applies. Billing therefore becomes granular: many requests, each at a price close to the manufacturer's cost.

What a Data Space Governs and What It Leaves Open

Industrial data spaces such as Catena-X in the automotive industry connect companies through connectors. Before each exchange, these connectors negotiate who may use which data under which conditions. The Dataspace Protocol, maintained by the Eclipse Foundation, describes this negotiation in detail. The words payment, price and invoice do not appear in its specification. For the contractual relationship, Catena-X expressly provides for bilateral contracts outside the connector.

A data space thus governs access, not money. Payment runs the usual way, through invoice, bank transfer and reconciliation in accounting. Pontus-X, from the Gaia-X environment, takes a different approach: data and services there are paid for in EURAU, an e-money token issued by AllUnity GmbH. AllUnity announced the launch on Pontus-X on 14 October 2025. According to its documentation, only test and development networks are running so far, and their payments carry no economic value (as of October 2026).

Payment per Request, Invoice per Month

Programmable money promises to pay for each request individually as soon as it is confirmed. Which designs exist for this and where the rule sits in each case is covered in Programmability of Digital Money. Such a payment does not replace an invoice. Under German VAT law (section 14(2) UStG), a business supplying another business must issue an invoice within six months. Between domestic businesses this is an electronic invoice; the transitional rules run until the end of 2027 at the latest.

VAT law does, however, allow payment and billing to be separated. The invoice may state the calendar month as the time of supply (section 31(4) UStDV). It may consist of several documents, provided one of them sums up the price and the tax and refers to the others (section 31(1) UStDV). And the recipient of the service may issue the invoice itself, if this has been agreed in advance. This self-billing document then counts as the invoice (section 14(2) UStG).

For the manufacturer, this opens up one possible arrangement. Payment is made per request or per day, billing once a month, with the request log attached. Whether this works in a given case is for tax advisers to decide; this article only states what the provisions allow. On the provider's side, many payments then meet a single invoice. How payments without a remittance reference find their invoice is covered in Reconciliation & Payment Flows.

What a Micro-Amount Really Costs

Suppose the provider requests one data record per machine every hour. With forty machines, that is around 29,000 requests a month, or 144 euros at half a cent per request. Paid individually on a blockchain, that would also mean 29,000 payments. Each one incurs a network fee, for example in ether, and each fee is a separate disposal in the accounts. What this means in ongoing work is covered in Posting, Valuation & Tax.

Whether a micro-amount pays off therefore shows less in the fee of a single payment than in the number of bookings. A middle way is to reserve an amount in advance and settle at intervals, say once a day. The log stays as fine-grained as the request, while the payment becomes coarser. For the manufacturer's CFO, this is the real design question: how many payments a month the accounts should carry, not how fast a single one arrives.

The European Central Bank (ECB) knows the idea too. On its innovation platform for the digital euro, market participants proposed conditional payments for pay-per-use and payments between machines in industry. The report of September 2025 presents their ideas, not a decision by the ECB. According to the ECB, the digital euro could be issued during 2029, provided the regulation is adopted in 2026. For a contract signed today, it is therefore not a means of payment.

A Contract That Pays Must Be Able to Stop

The Data Act also regulates the program that executes an agreement on making data available. It calls this a smart contract. Anyone who offers an application using such contracts, or deploys them for others, must meet five requirements (Article 36). They include protection against manipulation, strict access control and consistency with the agreement. Two requirements do not fit the common picture of immutable code. There must be a mechanism that terminates or interrupts further execution. And transaction data, logic and code must be capable of being archived, so that past operations remain auditable.

The vendor assesses compliance in a conformity assessment and issues an EU declaration of conformity. For the buyer of such a solution, this declaration is a concrete document to ask for. Whether a contract that only triggers the payment under a data agreement falls under Article 36 is not stated explicitly in the text. It refers to the execution of an agreement "or part thereof". The classification belongs in a legal review before money flows through such a contract.

The duty to be able to stop has a downside for the payee. Whoever can interrupt the contract can also hold back a payment that is due. For the manufacturer, this raises the same question as with any approval in-house, namely who may do this and who is informed. If the contract leaves this open, the risk of a payment stop lies with the recipient.

Billing as Proof of Cost

The cost ceiling has a second side for the manufacturer. The maintenance provider obtains the data at cost and can offer the same service as the manufacturer's own service unit. The lead that access to the data used to give the manufacturer is then gone. All the more weight falls on what Article 9(7) requires the manufacturer to disclose: the basis of its costs.

Billing per request delivers more than incoming payments here. A manufacturer that records formatting, dissemination and storage per request has the required calculation basis at hand and can present it in the same way to every recipient. The request log thus becomes evidence in two directions: as an attachment to the invoice, and as proof that the price does not exceed the cost.