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

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

Summary Under the proposed Cloud and AI Development Act (CADA), Slovenia would be required to designate one or more single information points (SIPs) to assist data centre operators with all authorisations for projects located within designated data centre acceleration zones. The proposal introduces an aggregated baseline permit for each zone, covering zone-level spatial and environmental approvals while excluding installation-specific permits. This framework aims to cap the permit-granting procedure at 12 months from the submission of a comprehensive application. Crucially, CADA allows Slovenia to integrate these new requirements with existing single information points established under the Gigabit Infrastructure Act (Regulation (EU) 2024/1309), avoiding the creation of redundant administrative layers.

Detail

The proposed Cloud and AI Development Act (CADA), COM(2026) 502 final, addresses the critical shortage of computing capacity in the EU by harmonising the regulatory landscape for data centre deployment. For Slovenia, as for all Member States, the proposal shifts the administrative burden from the operator to the state through two primary mechanisms: the establishment of single information points and the issuance of aggregated baseline permits within acceleration zones. These measures are designed to transform the permitting process from a fragmented, multi-year ordeal into a predictable, streamlined procedure.

The Obligation to Designate Single Information Points (Article 12)

Article 12 of the CADA proposal imposes a direct obligation on Member States to designate one or more single information points (SIPs) specifically for data centre operators deploying projects within acceleration zones. The primary function of the SIP is to assist the operator "throughout the entire lifecycle of the data centre project" regarding "all authorisations required for the deployment of the data centre."

This assistance extends beyond simple information provision. The SIP is tasked with actively coordinating, facilitating, monitoring, and sharing information on procedures relating to:

Spatial planning and building permits.
Environmental assessments, specifically referencing the upcoming Regulation on speeding-up environmental assessments.
Authorisations regarding water abstraction, wastewater discharge, and heat utilisation and recovery.
Compliance with applicable administrative and reporting obligations.
Information to the public to increase acceptance of the project.
Applications for connection to electricity, heat, or communications networks.

A critical feature of Article 12(1) is the flexibility it affords Slovenia. The text states that Member States "may designate for this purpose a single information point established under Regulation (EU) 2024/1309." This refers to the Gigabit Infrastructure Act, which already mandates Member States to establish SIPs for the deployment of electronic communications networks. By allowing the integration of these existing structures, CADA ensures continuity rather than forcing the creation of a parallel, siloed bureaucracy. The functions, procedures, and mechanisms applicable to the Gigabit SIPs—including digital access, administrative coordination, and dispute settlement—would apply to the data centre SIPs. This means Slovenia could leverage its existing digital infrastructure for permitting, potentially expanding the scope of current portals to cover full data centre deployment.

Furthermore, Article 12(4) mandates that SIPs pay "particular attention to SMEs," requiring them to establish dedicated communication channels to provide guidance and respond to queries. This is a significant provision for smaller data centre operators or those deploying edge computing facilities who may lack the internal legal resources to navigate complex cross-departmental permitting processes.

The Aggregated Baseline Permit (Article 13)

While the SIP handles coordination, Article 13 transforms the permitting mechanism itself through the concept of the aggregated baseline permit. For each designated acceleration zone, Member States must prepare and issue this permit, which authorises the deployment of data centres in that specific zone.

The aggregated baseline permit is designed to cover "the permits and administrative authorisations required for the data centre projects located within the acceleration zone, excluding installation-specific permits." This distinction is vital for operators. The baseline permit addresses zone-level issues such as:

General environmental assessments for the zone.
Spatial planning approvals for the area.
Cumulative impact assessments.

Installation-specific permits—such as those related to the specific technical configuration of a unique building, specific fire safety systems, or unique grid connection points—remain outside the scope of the baseline permit. Data centres deployed in acceleration zones are required to obtain additional permits only for activities falling outside this aggregated baseline.

Before issuing the aggregated baseline permit, Member States must carry out all necessary procedures and assessments, including environmental assessments, at the level of the acceleration zone. This "front-loading" of assessments ensures that once a zone is designated and the baseline permit is issued, individual projects face significantly reduced administrative hurdles. The operator benefits from a pre-approved environmental and spatial framework, allowing them to focus on the specific technical requirements of their facility.

Time Limits and Strategic Status

Article 13(5) establishes a strict deadline for the permit-granting procedure: it "shall not exceed 12 months" from the moment a comprehensive application has been submitted. This time limit is without prejudice to any shorter time limits set by Member States, encouraging Slovenia to potentially adopt even faster processing times if feasible.

To facilitate this speed, Article 13(5) also states that where a status of "highest national significance" exists in national law, data centre projects shall be allocated this status and treated as such in permit-granting processes. While this paragraph applies only where such a status exists in national law and does not create an obligation to introduce it, it provides a clear pathway for Slovenia to prioritise data centre projects if it chooses to align its national planning laws with this framework.

Interaction with Environmental Assessments

Article 13(1) explicitly links data centre projects in acceleration zones to the upcoming Regulation on speeding-up environmental assessments. These projects are to be considered "strategic projects" within the meaning of that Regulation, granting them access to a dedicated toolbox for accelerated environmental assessments. This ensures that the environmental compliance process, often the longest bottleneck in data centre deployment, is harmonised with the 12-month permitting target. The regulation notes that data centre projects deployed in acceleration zones should benefit from the dedicated toolbox established under the environmental assessment Regulation to ensure coherence while accommodating the need for accelerated deployment.

What this means for you

For CTOs, architects, and SMEs evaluating data centre deployment in Slovenia, the CADA proposal offers a structured, predictable pathway for securing permits, provided the projects are located within designated acceleration zones.

1. Simplified Administrative Interface You will no longer need to navigate a maze of disconnected municipal, regional, and national authorities independently. The single information point acts as your central coordinator. For SMEs, this is particularly valuable as the SIP is legally required to provide dedicated support and guidance, reducing the need for expensive external legal counsel to manage basic procedural compliance.

2. Predictable Timelines The 12-month maximum for permit-granting procedures introduces a level of certainty that has been historically lacking in EU infrastructure projects. While the clock starts upon the submission of a comprehensive application, the existence of an aggregated baseline permit for the zone means that many foundational approvals (such as general environmental impact statements for the zone) are already resolved. This significantly reduces the risk of indefinite delays due to procedural bottlenecks.

3. Strategic Site Selection The benefits of Article 12 and 13 apply only to data centre projects deployed in acceleration zones. Therefore, site selection becomes a critical strategic decision. Operators should prioritise locations within Slovenia's designated acceleration zones to benefit from the aggregated baseline permit and the SIP assistance. Deploying outside these zones may mean reverting to traditional, potentially slower, national permitting processes.

4. Leverage Existing Gigabit Infrastructure Since Slovenia can integrate the CADA SIP with the existing Gigabit Infrastructure Act SIP, you may already be familiar with the portal or authority handling network deployments. This continuity means that the digital tools and contact points you use for fibre connectivity applications may soon be expanded to cover full data centre permitting, creating a one-stop-shop for digital infrastructure deployment.

5. SME-Friendly Provisions If you are an SME, explicitly engage with the SIP's dedicated channel. The regulation mandates that these points pay particular attention to SMEs, meaning you may receive more proactive assistance in preparing your comprehensive application to ensure it meets the threshold for the 12-month clock to start.

Common misconceptions

Misconception 1: The Single Information Point makes decisions for you. The SIP is a coordination and assistance body, not a decision-making authority. It facilitates communication between you and the various competent authorities (municipal, environmental, energy). It does not have the power to grant permits itself; rather, it ensures that your application is routed correctly, that information is shared between authorities, and that timelines are monitored. The actual permit decisions remain with the relevant competent authorities.

Misconception 2: The aggregated baseline permit covers everything. The aggregated baseline permit covers zone-level authorisations, but it explicitly excludes installation-specific permits. You will still need to secure permits for aspects unique to your specific facility, such as detailed building construction permits, specific fire safety certifications, and final grid connection agreements. The baseline permit removes the need to re-litigate general environmental or spatial planning issues for the zone, but it does not eliminate all permitting requirements.

Misconception 3: Slovenia must create a new, separate SIP from scratch. Article 12(1) explicitly allows Member States to designate a single information point established under Regulation (EU) 2024/1309 (the Gigabit Infrastructure Act). Slovenia is not required to build a new, parallel administrative body. It can upgrade or integrate its existing Gigabit SIP to handle data centre projects, ensuring efficiency and reducing administrative overhead.

Misconception 4: The 12-month limit applies from the initial enquiry. The 12-month limit for the permit-granting procedure applies from the moment a comprehensive application has been submitted. Preliminary enquiries, site feasibility studies, or incomplete applications do not start the clock. It is crucial to ensure your application is complete and meets all requirements defined by the SIP to benefit from the accelerated timeline.

Misconception 5: CADA overrides all national planning laws. CADA sets a harmonised framework for acceleration zones but does not abolish national planning laws. It requires Member States to prepare an aggregated baseline permit before issuing it, carrying out necessary procedures and assessments at the zone level. National laws regarding specific construction details, fire safety, and local zoning within the zone still apply, but they are streamlined through the baseline permit process.

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