# When Lawyers Get Lazy: PwC’s Data Act Hiccup

- Link: https://smartnuts.com/2025/10/12/when-lawyers-get-lazy-pwcs-data-act-hiccup/
- Veröffentlicht: 2025-10-12T22:39:56+02:00
- Autor: Michael Bunzel

Sometimes satire writes itself. The European Union’s Data Act, a landmark piece 
of legislation on data access and portability, is [Regulation (EU) 2023/2854](https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng#:~:text=All%20consolidated%20versions%20%20,Hide%20consolidated%20versions),
which has been adopted on 13 December 2023, published in the Official Journal of
the EU on 22 December 2023 and fully applicable since 12 September 2025. That number
2023/2854 matters. It tells compliance officers which obligations to implement and
which fine print to read. Yet two recent posts from PwC Germany proudly announce
that the _“Data Act”_ is [Regulation (EU) 2023/2084](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R2084&qid=1760301821089).
One might shrug if the articles were musings on pop culture; they are supposed to
be legal guidance for PwC’s clients.

PwC’s [English article of 25 September 2025](https://legal.pwc.de/en/news/articles/eu-data-act-new-rules-for-data-access-contract-fairness-and-cloud-portability-in-the-financial-sector#:~:text=The%20EU%20Data%20Act%20,EU%29%202022%2F868%29%20and%2C%20alongside)(
[sreenshot](https://smartnuts.com/wp-content/uploads/2025/10/PwC_Reg_Data_Act.png))
and its [German twin of 2 October 2025](https://blogs.pwc.de/de/steuern-und-recht/article/251064/eu-data-act-neue-spielregeln-fuer-datenzugang-vertragsfairness-und-cloud-portabilitaet-im-finanzsektor/#:~:text=Der%C2%A0EU%20Data%20Act%20,zentralen%20Baustein%20der%20europ%C3%A4ischen%20Datenstrategie)(
[screenshot](https://smartnuts.com/wp-content/uploads/2025/10/PwC_Reg_Data_Act_1-scaled.png))
both trumpet the wrong citation. Ironically, the footnotes in the same articles 
link to the correct Official Journal entry for Regulation (EU) 2023/2854 … almost
as if a helpful intern (or a begrudging AI) whispered the truth, only to be ignored.
In reality, Regulation (EU) 2023/2084 is a different act altogether and has nothing
to do with Data Act topics. The Data Act sits comfortably in Regulation (EU) 2023/
2854, regulating raw data sharing, FRAND terms and switching fees.

When your trusted adviser can’t copy‑paste a number, the trust part evaporates. 
As _[smartnuts](https://smartnuts.com/2025/10/12/dear-consultants-ai-ate-your-pyramid/#:~:text=Dear%20Management%20Consultants%2C)_
wryly observes, artificial intelligence now assembles board packs and writes market
analysis in the time it takes to brew a coffee. Maybe PwC’s articles were an experiment:
give the firm’s new AI a regulatory summary and see what happens. The result? A 
hallucinated regulation number and a collective facepalm.

Why does this gaffe deserve mockery? Because it undermines the notion that high‑
priced legal advice is synonymous with rigour. PwC positions itself as a steward
of compliance; its clients pay for confidence. Yet its authors – qualified lawyers!–
confused some bird-flu-driven import list with the flagship Data Act. That is not
an unfortunate typo; it is the textual equivalent of showing up to court with the
wrong statute. If the article were a university paper, it would earn a red pen. 
Published under a Big Four brand, it becomes a cautionary tale.

Here’s where the irony bites. The _smartnuts_ essay “[Dear Consultants, AI Ate Your Pyramid](https://smartnuts.com/2025/10/12/dear-consultants-ai-ate-your-pyramid/#:~:text=Denial%20will%20have%20its%20cameo,build%20an%20internal%20strategy%20pod)”
warns that AI is coming for the consulting industry’s billable hours and that clients
will soon ask if a deliverable was produced by an “AI intern”. The article skewers
the idea that a roomful of analysts Googling all night justifies seven‑figure fees.
When PwC’s human lawyers mis‑number a regulation, the suspicion that a bot wrote
the piece becomes a punchline. Maybe the firm’s AI decided “2084” looked prettier.
Maybe the human editors let autopilot run. Either way, the result proves _smartnuts_’
thesis: the pyramid starts to wobble when machines (or distracted humans) handle
research.

Sarcasm aside, there is a genuine lesson here. AI can be a powerful drafting tool,
an assistant that summarises dense EU law. But professionals must still verify citations,
cross‑check references and think critically. When used lazily, AI hallucinates. 
When used wisely, it frees experts to add value. For a firm like PwC, the choice
is clear: either ensure that AI or junior staff produce flawless work, or prepare
to be the subject of more sardonic blog posts.

In the meantime, dear readers, double‑check your sources. The Data Act is Regulation(
EU) 2023/2854. Don’t let anyone convince you otherwise.