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Topic

Remote data processing

The clause that pulls backends into a product Regulation.

Remote data processing means data processing at a distance for which the software is designed and developed by the manufacturer or under its responsibility, and without which the product could not perform one of its functions F-006. The definition is the hinge: a product with digital elements includes its remote data processing solutions F-005.

The two-sided boundary

Where a product depends on your own backend or API — one without which it cannot perform a function — that remote processing sits with the product F-107. Cloud services that are not part of a product go the other way, out of this Regulation and toward NIS2 F-008.

How to reason about it

Ask what breaks when the backend is unplugged. A companion app that loses its sync has lost one of its functions, just as a lock that stops opening has; the test is not whether the product still mostly works F-006. Function-by-function is the granularity the definition actually uses F-006.

Verified facts this page relies on

Facts are maintained and human-verified in the CEMarque Facts Table (v2026.09.4, verified 2026-09-10).

Editorial review: Claude (AI reviewer, delegated by the editor), 2026-10-08. Methodology and correction process: how this site works.

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