Summary As proposed, the Cloud and AI Development Act (CADA) addresses data centre water use mainly by streamlining administrative authorisations and ensuring environmental compliance within designated "acceleration zones." Under Article 12(2)(c), single information points would coordinate authorisations for water abstraction, wastewater discharge, and heat utilisation and recovery. Under Article 10(3), where spatial and development plans for zones are subject to combined environmental assessment, that assessment "shall also address the impact on potentially affected water bodies" referred to in Directive 2000/60/EC (the Water Framework Directive). As proposed, CADA does not set numerical water-use limits.

Detail

CADA (COM(2026) 502 final, a proposal not yet in force) would strengthen Europe's cloud and AI ecosystem by accelerating data centre deployment while pursuing sustainability. For public-sector procurement officers and planners, how the proposal handles a resource-intensive issue like water use matters when evaluating future infrastructure. CADA does not set specific numerical limits on water consumption; instead, it creates a framework that facilitates lawful water access and maintains environmental oversight.

Streamlining water authorisations via single information points

Data centres can require significant water for cooling, often needing complex permits for abstraction and discharge. Under Article 12(2)(c), the role of a single information point in an acceleration zone may include coordinating, facilitating, monitoring and sharing information on:

"authorisations regarding water abstraction, wastewater discharge, and heat utilisation and recovery;"

For planners and procurement officers, this is significant because it is intended to reduce administrative burden and shorten timelines for securing water rights: instead of navigating several agencies, an operator would interact with a single coordinating point. (As proposed, Article 12(1) frames this as a right of the operator, on request, to be assisted throughout the project lifecycle.)

Environmental assessments and water-body protection

While accelerating deployment, CADA would retain environmental safeguards. Article 10(3) addresses spatial and development plans for acceleration zones and provides that, where those plans are subject to assessment under Directive 2001/42/EC and Article 6 of Directive 92/43/EEC, those assessments shall be combined. As proposed, it then states:

"Where applicable, the combined assessment shall also address the impact on potentially affected water bodies referred to in Directive 2000/60/EC of the European Parliament and of the Council."

Directive 2000/60/EC is the EU Water Framework Directive. By linking acceleration-zone planning to that directive, the proposal aims to ensure rapid deployment does not come at the cost of water quality or availability. Procurement officers should note that a project in an acceleration zone would be covered by assessments that, where applicable, explicitly address impacts on local water bodies.

Sustainability conditions in acceleration zones

Beyond water-specific authorisations, Article 11(1) would require Member States, when setting sustainability requirements for data centres deployed in acceleration zones, to use the key performance indicators specified in Delegated Regulation (EU) 2024/1364 (pursuant to Directive (EU) 2023/1791), Annex II, points (a) to (n). Water-related indicators are detailed in that delegated act rather than in CADA itself, so water efficiency would form part of the overall sustainability benchmark for new infrastructure in zones.

Furthermore, Article 10(1)(h) requires Member States, when designating zones, to consider the ability of the site to function sustainably, particularly as regards preventing or minimising environmental impacts — so the vulnerability of local water resources can factor into where deployment is accelerated.

Strategic projects

For projects designated as strategic under Article 14, the criteria centre on grid stability, innovation, supply chains and capacity shortages; one criterion (Article 14(1)(b)) concerns "highly sustainable or innovative features." As proposed, water is not a standalone strategic-project criterion, but efficient water management can form part of a project's sustainability case.

What this means for you

For public-sector procurement officers and planners, CADA's approach to water use, as proposed, has several practical implications:

  1. More streamlined water permitting. When procuring data centre services or capacity in acceleration zones, expect more coordinated handling of water abstraction and wastewater-discharge authorisations via the single information point (Article 12), which may shorten timelines.
  2. Environmental due diligence. Account for the combined assessments under Article 10(3). Where applicable, look for evidence that projects' assessments addressed impacts on water bodies under the Water Framework Directive.
  3. Sustainability criteria. When evaluating tenders, consider the KPIs referenced in Article 11(1). CADA does not dictate water limits, but it requires use of these EU-wide indicators; align your evaluation accordingly.
  4. Risk management. Requiring assessment of water-body impacts helps mitigate long-term risks tied to water scarcity or non-compliance — a feature supporting the durability of data centre investments.

Common misconceptions

  • "CADA sets specific water-usage limits." No. As proposed, CADA does not set numerical caps; it relies on existing EU environmental law (such as the Water Framework Directive) and the KPIs in Delegated Regulation (EU) 2024/1364. The focus is procedural compliance and impact assessment, not usage caps.
  • "Water authorisations are handled separately from other permits." Under Article 12(2)(c), water abstraction and wastewater discharge are within the single information point's coordinating role, alongside other permits — intended to streamline the overall process.
  • "Acceleration zones bypass environmental checks." No. Article 10(3) requires combined environmental assessments that, where applicable, address impacts on water bodies. Zones aim to speed up permitting, not to circumvent environmental protection.

Related

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