How do data centre permits and single information points work in Belgium under CADA?

Under the proposed Cloud and AI Development Act (CADA), Belgium would be required to designate one or more "single information points" (SIPs) to assist dat

Summary Under the proposed Cloud and AI Development Act (CADA), Belgium would be required to designate one or more "single information points" (SIPs) to assist data centre operators with all authorisations within designated acceleration zones, as stipulated in Article 12. These SIPs streamline the permitting process by coordinating administrative support, potentially integrating with existing single points under the Gigabit Infrastructure Act. Furthermore, Article 13 mandates that Member States issue an "aggregated baseline permit" for each acceleration zone, covering common zone-level authorisations while excluding installation-specific permits, thereby capping the standard permit-granting procedure at 12 months.

Detail

The Cloud and AI Development Act (CADA), as proposed in COM(2026) 502 final, introduces a harmonised framework designed to accelerate the deployment of data centre capacity across the European Union. For Belgium, as for all Member States, the proposal addresses critical bottlenecks in permitting and administrative coordination through two pivotal mechanisms: Article 12 (Single information points) and Article 13 (Facilitating administrative and permit-granting processes). These provisions aim to transform the regulatory landscape from a fragmented, project-by-project assessment model into a streamlined, zone-based approach.

Single Information Points under Article 12

Article 12(1) of the CADA proposal imposes a clear obligation on Member States, including Belgium, to designate one or more single information points (SIPs) specifically for data centre operators of projects located in data centre acceleration zones. The primary function of these SIPs is to provide comprehensive assistance to the data centre operator "throughout the entire lifecycle of the data centre project" with respect to "all authorisations required for the deployment of the data centre."

The scope of assistance provided by the SIP is intentionally broad to centralise administrative coordination and reduce the burden on operators. According to Article 12(2), the role of the single information point may include, among other things:

Coordinating, facilitating, monitoring, and sharing information on procedures relating to spatial planning and building permits.
Managing environmental assessments in accordance with the forthcoming Regulation on speeding-up environmental assessments.
Handling authorisations regarding water abstraction, wastewater discharge, and heat utilisation and recovery.
Ensuring compliance with applicable administrative and reporting obligations.
Providing information to the public to increase acceptance of the data centre project.
Processing applications for connection to electricity, heat, or communications networks.

Crucially, Article 12(1) explicitly states that Member States may designate for this purpose a single information point established under Regulation (EU) 2024/1309 (the Gigabit Infrastructure Act). This provision creates a direct legislative link between cloud infrastructure deployment and existing digital connectivity frameworks. If Belgium has already designated SIPs under the Gigabit Act to facilitate the rollout of high-speed networks, the CADA proposal allows for the upgrade or integration of these existing points to cover data centre projects, rather than mandating the creation of entirely new administrative bodies. The functions, procedures, and mechanisms applicable to SIPs under the Gigabit Act—including digital access, administrative coordination, and dispute settlement—would also apply to data centre SIPs.

Furthermore, Article 12(3) requires the single information point to assist in assessing whether a data centre project may qualify as a strategic project under Article 14. This integration ensures that operators receive early guidance on potential strategic designation, which can unlock additional support measures such as state aid or priority grid connections.

To ensure inclusivity and support smaller market players, Article 12(4) mandates that when providing administrative support, the single point of contact must pay particular attention to SMEs. Where appropriate, Member States must establish a dedicated channel for communication with SMEs to provide guidance and respond to queries related to the implementation of the Regulation.

Aggregated Baseline Permits under Article 13

While Article 12 addresses the coordination of permits, Article 13 addresses the substance and timing of the permitting process itself. The proposal introduces a significant innovation: the "aggregated baseline permit."

Article 13(2) requires Member States to prepare and issue an aggregated baseline permit authorising the deployment of data centres in a designated acceleration zone. This permit is designed to cover "the permits and administrative authorisations required for the data centre projects located within the acceleration zone," with a critical exclusion: it does not cover installation-specific permits.

The mechanism works as follows:

Pre-assessment: Before issuing the aggregated baseline permit, Member States must carry out all necessary procedures and assessments, including relevant environmental assessments, planning procedures, and evaluations applicable at the level of the acceleration zone (Article 13(3)).
Zone-Level Clearance: Once the aggregated baseline permit is issued, the zone is effectively cleared for general data centre deployment regarding common regulatory hurdles.
Project-Specific Additions: Data centres deployed in acceleration zones are only required to obtain additional permits for activities falling outside the aggregated baseline permit (Article 13(4)). This significantly reduces the redundant administrative burden for individual projects, as the heavy lifting of zone-level environmental and planning assessments is done once for the entire zone.

Article 13(5) imposes a strict timeline on this process. Member States must ensure that administrative applications related to the planning, construction, and operation of data centres in acceleration zones are processed in an efficient, transparent, and timely manner. Specifically, the permit-granting procedure for data centre projects deployed in data centre acceleration zones "shall not exceed 12 months, from the moment a comprehensive application has been submitted." This 12-month limit applies to the remaining installation-specific permits after the baseline zone clearance.

Additionally, Article 13(1) links data centre projects in acceleration zones to the forthcoming Regulation on speeding-up environmental assessments. These projects would be considered "strategic projects" within the meaning of that Regulation, allowing them to benefit from a dedicated toolbox for accelerated environmental assessments.

Interaction with Existing Belgian Frameworks

For Belgium, the implementation of Articles 12 and 13 requires alignment with existing regional and federal competencies. The proposal allows for flexibility in how SIPs are structured, permitting the use of existing infrastructure such as those under the Gigabit Act. This suggests that Belgium could leverage its existing digital infrastructure coordination bodies to fulfil CADA obligations, provided they meet the expanded scope of assistance required for data centres (e.g., water, heat, and specific building permits).

The aggregated baseline permit model represents a shift from project-by-project assessment to a zone-based approach. For Belgium, this means that the designation of an acceleration zone triggers a comprehensive pre-assessment phase. Once this phase is complete, individual operators benefit from a streamlined pathway, focusing only on the specific technical details of their installation rather than re-litigating zone-level environmental or planning concerns.

What this means for you

For CTOs, architects, and SMEs evaluating the practical impact of CADA on data centre deployment in Belgium, the provisions in Articles 12 and 13 offer significant operational advantages, provided the regulation is adopted in its current form.

1. Reduced Administrative Friction via Single Points of Contact Instead of navigating a labyrinth of separate municipal, regional, and federal authorities, operators in acceleration zones would interact with a designated Single Information Point. This centralisation simplifies the initial phases of project development. For SMEs, the mandatory dedicated channel under Article 12(4) ensures that smaller operators receive tailored guidance, potentially reducing the need for expensive legal and administrative consultants to navigate complex permitting landscapes.

2. Predictable Timelines with the 12-Month Cap The 12-month maximum duration for permit-granting procedures (Article 13(5)) provides greater predictability for project planning and financial modelling. While this clock starts after the submission of a comprehensive application, the prior existence of an aggregated baseline permit means that the most time-consuming environmental and planning assessments have likely already been conducted at the zone level. This reduces the risk of prolonged delays due to unexpected regulatory hurdles.

3. Strategic Project Potential The SIP's role in assessing strategic project status (Article 12(3)) is crucial. If a project is designated as strategic under Article 14, it may become eligible for additional support measures, including potential public funding or state aid, provided it meets specific criteria such as sustainability, innovation, or grid stability contributions. Early engagement with the SIP can help operators position their projects to meet these criteria.

4. Integration with Gigabit Infrastructure For operators already engaged with Belgium's digital infrastructure rollout, the potential integration with Gigabit Act SIPs means that expertise and processes for connectivity permits can be leveraged for broader data centre authorisations. This synergy can accelerate the deployment of high-capacity connectivity, a critical component for data centre operations.

5. Focus on Installation-Specific Details With the aggregated baseline permit covering zone-level authorisations, operators can focus their resources on the unique aspects of their installation, such as specific building designs, internal security measures, and proprietary cooling systems. This allows for more efficient allocation of engineering and legal resources.

Common misconceptions

Misconception 1: The Single Information Point grants the permits. Correction: The SIP does not have the authority to grant permits. Its role is to assist, coordinate, facilitate, and monitor the procedure. The actual permitting authority remains with the relevant national, regional, or local authorities. The SIP acts as a guide and coordinator, not the decision-maker.

Misconception 2: The aggregated baseline permit covers all permits for a data centre. Correction: The aggregated baseline permit only covers zone-level authorisations. It explicitly excludes installation-specific permits. Operators will still need to obtain permits for aspects unique to their specific facility, such as detailed building plans or specific equipment installations, though the 12-month cap applies to these remaining procedures.

Misconception 3: CADA eliminates the need for environmental assessments. Correction: CADA does not eliminate environmental assessments; it accelerates them. Data centre projects in acceleration zones are considered strategic projects under the forthcoming Regulation on speeding-up environmental assessments, allowing them to benefit from a dedicated toolbox. However, the assessments themselves must still be carried out, either at the zone level (for the baseline permit) or at the project level (if not covered by the baseline).

Misconception 4: The 12-month timeline applies from the initial project idea. Correction: The 12-month timeline for permit-granting procedures starts "from the moment a comprehensive application has been submitted" (Article 13(5)). It does not cover the pre-application phase, including the preparation of the aggregated baseline permit for the zone, which is a separate process undertaken by the Member State.

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