United Kingdom. UK GDPR Articles 12, 12A and 15, in force 5 February 2026
Which subject access request template do you need?
A subject access request is four sentences long and there is no prescribed form, so the template is not really the hard part. What decides whether you get an answer is which situation you are in: asking about yourself or about somebody else, wanting everything or wanting one specific thing, and what the organisation has said back. The deadline rules changed on 5 February 2026, and a controller can now stop the clock while it asks you to narrow the request down. Answer four questions and you will get the wording that fits, and the deadline the wording starts.
One month
the applicable time period, beginning with the relevant time rather than with the day you sent the request
5 Feb 2026
the day Article 12A came into force, inserted by section 76 of the Data (Use and Access) Act 2025
Free
the default: a request is dealt with free of charge unless it is manifestly unfounded or excessive, and the controller has to prove that it is
Question 1
Whose personal data are you asking for?
The right of access belongs to the data subject. Who is asking changes what the organisation may reasonably want before it starts.
The subject access request clock under UK GDPR Article 12A, from 5 February 2026
Last updated
The one month deadline for a subject access request has not changed. What changed on 5 February 2026 is when it starts and what stops it, and most published SAR templates and guides still describe the position before that date.
Every row is taken from the text of the UK GDPR as it stands on legislation.gov.uk on 15 August 2026, read in full rather than summarised from guidance. Article 12A was inserted by section 76(3) of the Data (Use and Access) Act 2025 and came into force on 5 February 2026 by S.I. 2026/82. The wording quoted in the effect column is the statutory wording, not a paraphrase. Where the effect depends on a judgement by the controller, for example whether it reasonably requires further information, the row says so rather than presenting the outcome as automatic. No timescale here is an estimate of how long an organisation actually takes: these are the statutory limits, and they are the floor a complaint is measured against. Nothing in this table is advice on an individual request.
| What happens | Effect on the deadline | Provision |
|---|---|---|
| The controller receives your request | One month begins, running from the relevant time rather than from the day you sent it | Article 12A(1) and (2)(a) |
| The controller has reasonable doubts about your identity and asks for more information | It may delay dealing with the request until identity is confirmed, and the relevant time becomes the day it receives that information, so the month starts again | Article 12(6) and Article 12A(2)(b) |
| The controller charges a fee because the request is manifestly unfounded or excessive, and you pay it | The relevant time becomes the day the fee is paid | Article 12A(2)(c) |
| The controller reasonably requires further information to identify what the request relates to | The period from the day it asks to the day it receives your answer does not count towards the deadline. The clock stops and resumes; it does not restart | Article 12A(5), in force 5 February 2026 |
| The controller extends because of the complexity or the number of requests | Two further months, but notice must be given before the end of the first month and must state the reasons for the delay | Article 12A(3) and (4) |
| The controller decides not to act on the request | It must tell you the reasons, and about complaining to the controller, complaining to the Commissioner and seeking a judicial remedy, before the period ends | Article 12(4) |
| You ask for further copies of the same data | The first copy is free. For further copies the controller may charge a reasonable fee based on administrative costs | Article 15(3) |
| The request concerns a confidential reference for employment, training, a volunteer placement, an office or a service | The listed GDPR provisions do not apply to the reference itself, whichever side of it holds the copy | Data Protection Act 2018, Schedule 2, paragraph 24 |
- A UK subject access request must be answered within one month of the relevant time, which since 5 February 2026 is defined by Article 12A rather than by the date you sent the request.
- The relevant time is the latest of three dates: when the controller receives the request, when it receives any identity information it asked for, and when any fee it charged is paid.
- Since 5 February 2026 a controller that reasonably requires further information to identify what a request relates to can stop the clock: the days between its question and your answer do not count.
- An extension of two further months is available for complexity or volume, but notice of it must be given inside the first month and must state the reasons for the delay.
- A subject access request is free unless it is manifestly unfounded or excessive, and the controller bears the burden of demonstrating that it is.
- Confidential references given for employment, training, volunteering, appointment to an office or the provision of a service are exempt under Schedule 2 paragraph 24 of the Data Protection Act 2018.
- The right of access applies only to living individuals: personal data is defined by section 3(2) of the Data Protection Act 2018 as information relating to an identified or identifiable living individual.
Cite this page
“The subject access request clock under UK GDPR Article 12A, from 5 February 2026”, SAR Builder, https://sarbuilder.co.uk/ (updated 2026-08-15). Every row is taken from the text of the UK GDPR as it stands on legislation.gov.uk on 15 August 2026, read in full rather than summarised from guidance. Article 12A was inserted by section 76(3) of the Data (Use and Access) Act 2025 and came into force on 5 February 2026 by S.I. 2026/82. The wording quoted in the effect column is the statutory wording, not a paraphrase. Where the effect depends on a judgement by the controller, for example whether it reasonably requires further information, the row says so rather than presenting the outcome as automatic. No timescale here is an estimate of how long an organisation actually takes: these are the statutory limits, and they are the floor a complaint is measured against. Nothing in this table is advice on an individual request.
What this checker covers
- Requests about your own personal data, and requests made for somebody else
- Employers, companies you have been a customer of, health providers and public authorities
- Asking for everything, asking for one specific record, and asking for CCTV
- The Article 12A clock, including the stop-the-clock rule that arrived on 5 February 2026
- What a controller may withhold, and what it must tell you when it refuses
- Based on the text of UK GDPR Articles 12, 12A and 15 and the Data Protection Act 2018 as in force on 15 August 2026
SAR Builder is an independent site operated by Ellul Solutions Ltd. It is not affiliated with, endorsed by or connected to the Information Commissioner's Office or any government body, and it is not a law firm. Nothing here is legal advice on an individual request, and the wording it produces is a starting point rather than a document settled for your circumstances. Every statement of law on this site is taken from the text of the legislation on legislation.gov.uk, read on the date shown at the top of the page, and quoted rather than summarised where the wording carries the meaning. The rules described here changed on 5 February 2026 and could change again; the date on this page is when we last read the source.
Want a solicitor to run the request?
Tell us who holds the data and what has happened so far. Data protection and employment solicitors who handle subject access work will contact you directly.
Frequently asked
Is there an official subject access request template in the UK?
No, and there is no form you have to use. The UK GDPR sets no formality requirements for a request under Article 15, so a plain email is as valid as a formal letter. What a good template gives you is not legal effect but scope: a request that identifies you clearly, says what it is, and states what you want with a date range is far less likely to trigger a clarification request, and since 5 February 2026 a clarification request can pause your own deadline under Article 12A(5).
How long does an organisation have to answer a subject access request?
One month, but from the relevant time rather than from the day you sent it. Article 12A(1) sets the applicable time period as one month beginning with the relevant time, and Article 12A(2) defines that as the latest of three dates: when the controller receives the request, when it receives any identity information it asked for, and when any fee it charged is paid. It may extend by two further months for the complexity or number of requests, but under Article 12A(4) notice of that must be given inside the first month and must state the reasons.
Can an organisation stop the clock on a subject access request?
Yes, since 5 February 2026, in one specific circumstance. Article 12A(5) provides that where a controller reasonably requires further information in order to identify the information or processing activities to which an Article 15 request relates, the period from the day it asks to the day it receives your answer does not count towards the deadline. It pauses rather than restarts. The power is limited to identifying what the request relates to: a question about why you want the data does not engage it.
Does a subject access request cost anything?
No, in the ordinary case. Article 12(5) makes the response free of charge. A fee is only available where the request is manifestly unfounded or excessive, in particular because of its repetitive character, and the same provision states that the controller bears the burden of demonstrating that character. Separately, Article 15(3) allows a reasonable fee based on administrative costs for further copies of data already provided, which is a different thing from charging for the request itself.
Can I make a subject access request about someone who has died?
Not under the UK GDPR. Section 3(2) of the Data Protection Act 2018 defines personal data as information relating to an identified or identifiable living individual, so information about someone who has died is not personal data for these purposes. Other routes exist depending on what you need: the Access to Health Records Act 1990 for a deceased person's health records, the Freedom of Information Act 2000 for records held by a public authority, and the executor's ordinary entitlement to the estate's papers. Correspondence between you and the person who died is your own personal data and remains in scope.
What can an employer refuse to give me?
Specific things, not the request as a whole. Confidential references are exempt under Schedule 2 paragraph 24 of the Data Protection Act 2018, and the exemption follows the reference whichever organisation holds the copy. Material covered by legal professional privilege is exempt. Article 15(4) allows information to be withheld or redacted where providing it would adversely affect the rights and freedoms of others, which is where colleagues' details are removed. None of those is a reason to refuse the request itself, and Article 12(4) requires the controller to state its reasons where it does not act.
What can I do if a subject access request is ignored?
Article 12(4) requires a controller that does not act on a request to tell you the reasons, and to tell you about three routes: making a complaint to the controller itself under section 164A of the Data Protection Act 2018, complaining to the Information Commissioner under section 165 of that Act, and seeking a judicial remedy. Silence fails that duty on its own terms. Use the complaint to the controller first: it is quick, it creates a dated record, and the regulator will ask whether you did.
Go deeper
Each one cites where its numbers come from.
Subject access request deadline: what Article 12A changed
The one month deadline now runs from the relevant time, and a clarification request stops the clock. Both rules arrived on 5 February 2026 and most guides predate them.
What to write in a subject access request
There is no prescribed form. Four sentences do the job, and two optional lines make the reply far more useful. What each line is doing and why.
When a subject access request can be refused or cut down
Manifestly unfounded or excessive, third-party data, confidential references and the listed exemptions. What has to be proved, and by whom.
Subject access request to an employer: what to expect
Employers hold more about you than almost anyone else and have the most to redact. Where the data actually is, and the two exemptions that come up every time.
Sources
- UK GDPR Article 15, right of access (legislation.gov.uk)
- UK GDPR Article 12, modalities for exercising rights (legislation.gov.uk)
- UK GDPR Articles 12 to 22, including Article 12A on the applicable time period
- Data (Use and Access) Act 2025 s.76, time limits for responding to requests
- Data Protection Act 2018 s.3, meaning of personal data
- Data Protection Act 2018 Schedule 2 paragraph 24, confidential references
- ICO, make a data protection complaint
Four questions, then the wording
Who the data is about, who holds it, what you want and where it has got to. That settles both the template and the deadline.
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