Making CADA’s sovereignty framework work for Europe
Position Paper
7 Oct 2026
Digital

The success of the Cloud and AI Development Act (CADA) will depend on whether its sovereignty framework strengthens Europe’s resilience and competitiveness without restricting access to the technologies, providers and operating models needed to support the bloc’s digital transformation. As currently envisaged, several elements of CADA introduce origin-based restrictions that are not necessarily linked to genuine sovereignty, security or resilience risks. These measures could reduce competition, increase costs and slow cloud and AI adoption – ultimately working against CADA’s underlying objectives.

A sovereignty framework built on objective, risk-based criteria will better support Europe’s competitiveness, resilience and digital transformation than one based on origin, ownership or nationality.

To ensure CADA achieves its objectives, the co-legislators should:

  • Base sovereignty requirements on demonstrable control and risk rather than ownership, nationality or corporate domicile.

  • Apply a proportionate, risk-based approach across assurance levels, cloud service models and workload types.

  • Ensure sovereignty requirements strengthen rather than undermine cybersecurity, operational resilience and service continuity.

  • Maintain a technology-neutral framework that recognises global operating models and existing security and compliance mechanisms.

  • Keep CADA focused on the public sector and avoid duplicating requirements already addressed through DORA, NIS2 and other sector-specific frameworks.

  • Promote competition, interoperability and supplier choice while avoiding measures that reinforce vendor lock-in.

  • Provide legal certainty through a workable equivalence framework, proportionate compliance requirements and efficient recognition procedures.

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Learn more about how to make the most of CADA in the full paper and one-pager.

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