Summary No, the EuroCloud Federation does not own any computing infrastructure, data centres, or hardware. As proposed in the Cloud and AI Development Act (CADA), the Federation acts strictly as a coordination and facilitation layer for public sector bodies. Under Article 35(1), the physical and logical infrastructure remains the property of the individual "sharing entities" (such as national governments or EU institutions). The Federation itself operates only a digital platform managed by the European Commission to catalogue and orchestrate the sharing of these existing resources.

Detail

The Cloud and AI Development Act (CADA), as proposed in COM(2026) 502 final, establishes the European public sector cloud federation (the "EuroCloud Federation") to enhance the resilience, sovereignty, and efficiency of the EU's public sector digital infrastructure. A fundamental distinction in the proposal is that the Federation is not designed to be a new cloud provider, nor does it procure, build, or own its own data centre capacity. Instead, it functions as a legal and technical framework for interconnecting and sharing existing public sector resources across borders.

The Federation as a Coordination Layer

Article 34 of the CADA proposal establishes the EuroCloud Federation and defines its scope and purpose. The primary objective is to "facilitate the sharing of public sector data centre services and cloud computing services between Union entities and public sector bodies" (Article 34(2)). The Federation is open for participation on a voluntary basis, allowing Union entities and public sector bodies to request membership from the Commission (Article 34(1)).

Crucially, the Commission's role is limited to establishing and maintaining a platform for this federation. Article 34(3) specifies that this platform must provide:

  • A catalogue providing information on available public sector data centre services and cloud computing services.
  • A service platform for the exchange and orchestration of computing, storage, and network resources and services.

This structure confirms that the Federation is a digital intermediary and governance structure, not an infrastructure operator. It does not buy servers, rent data centre space, or deploy its own hardware. Its function is to enable visibility and interoperability between independent public clouds.

Ownership Remains with Sharing Entities

The question of asset ownership is explicitly addressed in Article 35, which governs the sharing of services within the Federation. Article 35(1) states that a member (the "sharing entity") may share services with another member (the "using entity") only where the sharing entity "directly, or indirectly through an intermediate legal entity, owns the hardware through which the service is made available and provides the service."

This provision establishes three critical principles:

  1. Ownership is a prerequisite for sharing: To participate as a sharing entity, the public body must already own the underlying hardware. The Federation cannot aggregate assets from entities that do not own them.
  2. No centralised asset pool: The Federation does not create a common EU-owned pool of servers or data centres. Each resource remains under the legal and operational control of the original owner.
  3. Control requirements: If the hardware is owned indirectly through an intermediate legal entity, the sharing entity must exercise control over that intermediate entity (Article 35(1)). This ensures that the public interest remains protected and that private parties do not distort competition by gaining undue advantage through the Federation.

The Role of the Commission Platform

While the Federation does not own infrastructure, the European Commission plays an active technical role. By establishing the platform under Article 34(3), the Commission provides the technical means for discovery and orchestration. This platform allows public sector bodies to identify idle or underutilised capacity available across the Union and to request access to it.

However, the actual service delivery, maintenance, and security of the underlying infrastructure remain the responsibility of the sharing entity. Under Article 35(2), the sharing entity must put in place appropriate technical, operational, and organisational measures to ensure an effective, secure, and resilient provision of services. The Commission manages the catalogue and the orchestration logic, but the infrastructure stays with the public owner.

What this means for you

For CTOs, architects, and technology vendors evaluating the impact of CADA on the public sector market, the structure of the EuroCloud Federation has several practical implications:

  • No New Competitor from the Federation: The Federation itself will not enter the market as a cloud provider. It will not bid for contracts to build data centres or offer cloud services directly. This ensures the initiative complements rather than competes with existing public and private offerings.
  • Opportunities for Integration: SMEs providing cloud management, orchestration, security, or interoperability tools may find significant opportunities in integrating with the Commission's platform. Since the platform facilitates the exchange of resources across borders, tools that help public bodies manage multi-cloud environments or ensure seamless interoperability between different national clouds will be highly valuable.
  • Focus on Public Sector Assets: The Federation is strictly limited to public entities. Private cloud providers cannot join the Federation to share their infrastructure. However, private providers may still sell services to public entities that are members of the Federation, provided those services meet the relevant Union assurance levels (e.g., Level 1, 2, 3, or 4) as determined by national risk assessments under Article 29.
  • Standardisation Needs: Because the Federation connects diverse national infrastructures, there will be a heightened demand for standardised APIs, security protocols, and identity management solutions that can work across different national clouds. Architects should prepare for environments where resources are dynamically orchestrated across borders, requiring robust interoperability standards to ensure the "exchange and orchestration" mandated by Article 34(3) functions smoothly.

Common misconceptions

Misconception 1: The EuroCloud Federation is a new EU-owned hyperscaler. Reality: The Federation is not a cloud provider. It does not own servers or data centres. It is a cooperative framework that allows existing public sector clouds to share capacity. The infrastructure remains nationally or institutionally owned, as explicitly stated in Article 35(1).

Misconception 2: Private companies can join the EuroCloud Federation to offer their services. Reality: Participation is restricted to "Union entities and public sector bodies" (Article 34(1)). Private cloud providers cannot become members of the Federation. They can only serve as vendors to the public entities that are members, subject to the sovereignty and procurement rules of CADA.

Misconception 3: The Commission manages the day-to-day operation of the shared clouds. Reality: The Commission manages the platform that lists and orchestrates the services (Article 34(3)). However, the actual operation, maintenance, and security of the cloud services remain with the "sharing entity" that owns the hardware (Article 35(2)). The Commission does not act as the system administrator for national data centres.

Related

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