Summary No. As proposed, the Cloud and AI Development Act (CADA) would not set a uniform, EU-wide maximum size for data centres in acceleration zones. Under Article 10(1)(a), Member States must consider "the location and dimension of the site or area, and the minimum and maximum size of the facilities that could be built on that site or area" when designating a zone. Any size limits are therefore set at national or local level, tailored to each site's physical and infrastructural capacity.

Detail

CADA, COM(2026) 502 final, was proposed by the European Commission on 3 June 2026 to accelerate the deployment of sustainable, innovative compute capacity across the EU. A core mechanism is the data centre acceleration zone — a geographic area where deployment is facilitated through streamlined permitting and infrastructure planning.

No EU-wide size cap

A common question is whether CADA imposes harmonised physical limits — for example a megawatt or floor-area ceiling — on data centres in these zones. The proposal does not prescribe a single, binding maximum size across the Union. Instead it takes a site-specific approach: the right size depends on local conditions such as grid capacity, water resources, land availability and environmental impact. A rigid EU-wide cap could hinder deployment where resources are abundant while being irrelevant where they are scarce.

The role of Article 10(1)(a)

The governing provision is Article 10(1)(a), in the list of aspects Member States must consider when designating a zone. Member States shall consider:

"the location and dimension of the site or area, and the minimum and maximum size of the facilities that could be built on that site or area;"

This places responsibility for defining size constraints on Member States (often via regional or local authorities). When designating a zone, a Member State assesses the specific land and infrastructure, so any "maximum size" reflects the limits of that site rather than a legislative ceiling set centrally. Note the duty is to consider these aspects at designation — CADA does not require that a numeric maximum be fixed for every zone.

Why size features in designation

Considering size supports CADA's planning goals:

  1. Realistic infrastructure planning. Grid operators and planners can forecast demand; a zone for small edge facilities differs from one for hyperscale AI clusters.
  2. Environmental sustainability. Under Article 11(1), Member States must apply the sustainability KPIs in Delegated Regulation (EU) 2024/1364 (Annex II, points (a) to (n)) to zone data centres; fitting facilities to a site helps avoid overwhelming local environmental capacity such as cooling water.
  3. Optimised land use. Article 10(1)(g) records a preference for reusing brownfield sites over greenfield sites, encouraging efficient use of land.

Interaction with other provisions

While Article 10(1)(a) frames the size question, other provisions shape the practical outcome. Article 11 makes the sustainability KPIs mandatory for zone facilities, so a very large facility that cannot meet, for example, power- or water-efficiency expectations may face stricter scrutiny — a soft constraint. Article 14 lets the Commission designate qualifying projects as "data centre strategic projects," which unlocks support and streamlined processes but does not override the site-specific size considerations set at designation under Article 10.

What this means for you

For public-sector procurement officers and local planning authorities, the absence of an EU-wide cap means real discretion — and a clear duty to define limits transparently.

  1. Define clear parameters. When your region designates a zone, set out the minimum and maximum facility sizes that the local grid capacity and land can support, and document them in the designation to give investors certainty.
  2. Align with grid capacity. Match any maximum size to the grid's ability to deliver power. CADA contemplates anticipatory grid investment (Article 10(2)(b)), so size limits should be part of a dialogue with transmission and distribution system operators.
  3. Avoid arbitrary restrictions. Ground limits in the "location and dimension of the site" (Article 10(1)(a)). Caps that ignore actual capacity could be challenged as barriers to investment.
  4. Use single information points. Under Article 12, designate single information points that can clearly communicate a zone's size constraints to developers, streamlining their feasibility studies.

For data centre operators, this means site-specific due diligence: there is no standard EU-wide "maximum size." Engage local authorities to learn the dimensional and capacity limits of the specific zone.

Common misconceptions

Misconception 1: CADA bans large hyperscale data centres. No. CADA aims to increase EU capacity substantially. The "maximum size" consideration in Article 10(1)(a) is about matching facilities to a site's capacity, not capping growth arbitrarily — large facilities are welcome where the local infrastructure supports them.

Misconception 2: Member States can set any size limit they like. They have discretion, but Article 10(1)(a) ties it to the "location and dimension of the site." Limits should rest on technical and environmental realities rather than protectionist motives, consistent with the proposal's internal-market aims.

Misconception 3: Size limits are static. As infrastructure improves (for example through grid upgrades), the viable maximum may rise. Member States are to review the energy-needs analysis for current and future zones at least every three years (Article 10(2)(a)), allowing limits to evolve.

Related

This is general information about a draft EU regulation, not legal advice.