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

Under the proposed Cloud and AI Development Act (CADA), Lithuania would be required to designate one or more single information points to assist data centr

Summary Under the proposed Cloud and AI Development Act (CADA), Lithuania would be required to designate one or more single information points to assist data centre operators with all authorisations within designated data centre acceleration zones. As proposed in Article 12, these points must guide operators throughout the project lifecycle and may integrate with existing single information points established under the Gigabit Infrastructure Act (Regulation (EU) 2024/1309). Furthermore, Article 13 would mandate the issuance of an aggregated baseline permit for each acceleration zone, covering zone-level authorisations to streamline the process, while explicitly excluding installation-specific permits. These measures aim to cap the permit-granting procedure at 12 months for projects within these zones.

Detail

The Cloud and AI Development Act (CADA), as proposed in COM(2026) 502 final, introduces a harmonised EU framework designed to address the fragmentation of national permitting procedures and the shortage of computing capacity. For Lithuania, as for all Member States, this proposal imposes specific, binding obligations regarding the establishment of single information points and the issuance of aggregated baseline permits within designated data centre acceleration zones. These mechanisms are central to the Act's goal of tripling EU data centre capacity within five to seven years.

Single Information Points: The Operator's Gateway (Article 12)

Article 12 of the CADA proposal establishes a critical obligation for Member States to designate single information points specifically for data centre projects located in acceleration zones. This provision is designed to replace the current reality where operators must navigate a fragmented landscape of disparate authorities for planning, energy, water, and environmental approvals.

Designation and Integration: Lithuania must designate one or more single information points. Crucially, the proposal explicitly allows Member States to designate for this purpose a single information point already established under Regulation (EU) 2024/1309 (the Gigabit Infrastructure Act). This is a pivotal provision for Lithuania, as it permits the reuse and upgrading of existing administrative structures rather than mandating the creation of entirely new bureaucratic entities. The functions, procedures, and mechanisms applicable to the Gigabit single information point—including digital access and dispute settlement—would extend to data centre projects.
Lifecycle Assistance: The single information point is not a passive repository of documents. Article 12(1) grants the data centre operator a specific right to be assisted by this point throughout the entire lifecycle of the project regarding all authorisations required for deployment. The scope of this assistance is comprehensive, covering:
- Spatial planning and building permits.
- Environmental assessments (linked to the proposed Regulation on speeding-up environmental assessments).
- Authorisations regarding water abstraction, wastewater discharge, and heat utilisation and recovery.
- Compliance with applicable administrative and reporting obligations.
- Public information dissemination to increase acceptance of the project.
- Applications for connection to electricity, heat, or communications networks.
Strategic Project Screening: The single information point also serves a proactive function. Under Article 12(3), it must assist the operator in assessing whether a specific data centre project may qualify as a strategic project under Article 14. Qualification as a strategic project can unlock significant benefits, including potential support measures from the Member State and eligibility for Union funding.
SME Focus: Recognising that smaller operators often lack the legal resources of major hyperscalers, Article 12(4) mandates that single information points pay particular attention to SMEs. Lithuania would be required to establish dedicated communication channels for SMEs to provide tailored guidance and respond to queries, ensuring that the acceleration framework does not inadvertently favour only large incumbents.

Aggregated Baseline Permits: Streamlining Zone-Level Approval (Article 13)

Complementing the single information point, Article 13 introduces a mechanism to drastically reduce permitting times through the aggregated baseline permit. This tool shifts the regulatory burden from the individual project to the zone level.

Zone-Level Authorisation: For each designated acceleration zone, Lithuania would be required to prepare and issue an aggregated baseline permit. This permit covers the permits and administrative authorisations commonly required for data centre projects located within that specific zone. By pre-approving zone-level conditions, the state effectively "banks" the generic compliance requirements, allowing individual projects to bypass repetitive assessments.
Exclusions: It is vital to understand the limits of this permit. Article 13(2) explicitly states that the aggregated baseline permit covers permits required for the zone but excludes installation-specific permits. This means that while the environmental impact, spatial planning, and general infrastructure compatibility of the zone are pre-approved, the specific technical details of an individual data centre build—such as specific structural engineering approvals, unique fire safety configurations, or site-specific grid connection details—still require separate, installation-specific authorisation.
Pre-Assessment Requirement: Before issuing this baseline permit, Lithuania must carry out all necessary procedures and assessments, including relevant environmental assessments and planning procedures, at the level of the acceleration zone itself. This ensures that the zone is legally and technically ready for deployment before any operator submits a specific application.
Strict Time Limits: Article 13(5) imposes a binding ceiling on the permitting process. The permit-granting procedure for data centre projects deployed in acceleration zones shall not exceed 12 months from the moment a comprehensive application has been submitted. This is a maximum limit; Member States may set shorter time limits, but they cannot exceed this 12-month cap.
Highest National Significance: To further prioritise these projects, Article 13(5) mandates that where national law provides for a status of "highest national significance," data centre projects in acceleration zones must be allocated this status. This ensures they receive priority treatment in permit-granting processes, provided such a status exists in Lithuanian law.

Interaction with Existing Frameworks and Environmental Law

The proposal is designed to integrate with, rather than duplicate, existing EU legislation. The reference to Regulation (EU) 2024/1309 in Article 12 is a key example of this interoperability. Lithuania has already implemented single information points for gigabit infrastructure; CADA proposes that these existing bodies can be upgraded or integrated to handle data centre projects, ensuring continuity and reducing administrative overhead.

Furthermore, Article 13(1) explicitly links the permitting process to the proposed Regulation on speeding-up environmental assessments. Data centre projects in acceleration zones are considered strategic projects within the meaning of that Regulation and benefit from its dedicated toolbox. This means that environmental assessments for these projects are accelerated and streamlined, aligning with the 12-month permitting cap.

What this means for you

For CTOs, infrastructure architects, and SMEs evaluating data centre investments in Lithuania, these provisions signal a fundamental shift from fragmented, unpredictable permitting to a structured, time-bound process.

Predictability for SMEs: The dedicated SME channels at single information points (Article 12(4)) are a tangible benefit. If you are a smaller operator, you can expect targeted guidance, reducing the risk of procedural errors that often delay projects. This levels the playing field against larger competitors with in-house legal teams.
Faster Zone-Level Approvals: If you build in a designated acceleration zone, the aggregated baseline permit (Article 13) means you won't need to re-litigate generic environmental or spatial planning issues that have already been assessed for the zone. This should significantly compress the timeline for the initial phase of your project, allowing you to focus on installation-specific engineering.
Strategic Project Potential: Engage with the single information point early to assess if your project qualifies as a strategic project under Article 14. This status can open doors to state support measures and further streamlined procedures, potentially unlocking access to Union funding or financial instruments.
The 12-Month Clock: The 12-month maximum for permit-granting (Article 13(5)) provides a clear contractual and planning benchmark. However, this clock starts only upon submission of a comprehensive application. Ensure your submission is complete and accurate to avoid the clock stopping or resetting due to requests for additional information.
Leverage Existing Gigabit SIPs: Monitor whether Lithuania designates its existing Gigabit Infrastructure Act single information points to also serve as CADA single information points. This will determine which administrative body you interact with and whether you can utilise existing digital portals and dispute settlement mechanisms.
Preparation for Installation-Specific Permits: While the zone-level permit is streamlined, remember that installation-specific permits are still required. You must prepare for the specific technical authorisations unique to your facility, even if the zone is pre-approved.

Common misconceptions

"The single information point approves permits."

Reality: The single information point assists and coordinates (Article 12(2)). It does not have the authority to issue permits itself. It facilitates the exchange of information between the operator and the various competent authorities (environmental, energy, planning) and ensures the process moves forward, but the actual issuance of permits remains with the relevant authorities.

"The aggregated baseline permit covers everything."

Reality: Article 13(2) explicitly excludes installation-specific permits. You will still need to obtain specific authorisations for your unique data centre design, even if the zone-level baseline is approved. The baseline permit removes the need to re-assess zone-wide issues, not project-specific engineering details.

"CADA creates entirely new bureaucracies."

Reality: Article 12(1) allows Member States to upgrade or integrate existing single information points, such as those under Regulation (EU) 2024/1309. The goal is harmonisation and efficiency, not necessarily new entities. Lithuania is expected to leverage its existing Gigabit Infrastructure Act infrastructure.

"The 12-month limit applies to all data centres."

Reality: The 12-month maximum for permit-granting (Article 13(5)) applies only to data centre projects deployed in data centre acceleration zones. Projects located outside these zones may be subject to different, potentially longer, national timelines, as the accelerated framework is zone-specific.

"Environmental assessments are skipped."

Reality: Environmental assessments are not skipped; they are accelerated and streamlined. Article 13(1) designates these projects as strategic under the proposed Regulation on speeding-up environmental assessments, and Article 13(3) requires that all necessary assessments be carried out at the zone level before the baseline permit is issued.

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