Summary Under the proposed Cloud and AI Development Act (CADA), Member States would have to consider the physical location and dimensions of a site when designating data centre acceleration zones. As proposed, Article 10(1)(a) lists, among the aspects Member States "shall consider," the location and dimension of the site or area and the minimum and maximum size of the facilities that could be built there. The aim is to give acceleration zones clear spatial boundaries and capacity limits.

Detail

The proposed Cloud and AI Development Act (CADA), COM(2026) 502 final, introduces a harmonised framework to accelerate the deployment of data centres across the European Union. A core mechanism is the designation of "data centre acceleration zones" by Member States. These are specific geographical areas where the development, expansion and modernisation of data centres would be facilitated through streamlined permitting and coordinated infrastructure planning.

When designating these zones, Member States would not have unbounded discretion. As proposed, Article 10(1) requires that, where data centre capacity is being deployed in its territory, a Member State designate at least one acceleration zone, and it sets out a list of aspects Member States "shall consider" when doing so.

The most direct answer to the question lies in Article 10(1)(a), which lists:

"the location and dimension of the site or area, and the minimum and maximum size of the facilities that could be built on that site or area;"

This serves two purposes. First, it calls for a geographical definition ("location and dimension of the site or area"), reducing ambiguity about which parcels fall under the framework. Second, it calls for a capacity definition ("minimum and maximum size of the facilities"). A maximum size can help prevent a single entity from monopolising a zone or reserving resources speculatively — a concern Article 11(2) addresses separately by requiring that resource allocation within zones be on fair, reasonable and non-discriminatory terms and not give rise to speculative reservation or foreclosure. A minimum size can help ensure a zone is used for projects substantial enough to justify the associated infrastructure investments, such as grid upgrades.

The location and dimension are not assessed in isolation. Article 10(1) lists other aspects to consider alongside, including available and future power grid capacity (point b), network connectivity (point c), facilities that can reuse waste heat (point e), and the ability of the site to function sustainably (point h). In practice, a site's dimension would need to accommodate not just server halls but also cooling, energy storage and potentially waste-heat-recovery infrastructure.

CADA's stated objectives, set out in the explanatory memorandum, aim for the EU to at least triple its current data centre capacity by 2030 as an intermediate step, with computing capacity meeting the EU's needs by 2035. Article 10(1)(g) also lists a preference for reusing brownfield sites over greenfield sites, which adds a further dimension to the "location" assessment: authorities would weigh whether existing structures are suitable for conversion.

What this means for you

For public-sector procurement officers and local planning authorities, Article 10(1)(a) flags a planning step to address before projects can benefit from the accelerated framework.

  1. Define clear boundaries. When proposing an acceleration zone, map the location and dimensions precisely. Vague descriptions such as "the industrial park near the highway" are unlikely to suffice; precise coordinates or parcel definitions are the goal.
  2. Set size thresholds. Consider the minimum and maximum facility sizes for the zone. A maximum can preserve room for multiple investors within a zone; a minimum can ensure that grid and infrastructure investment is justified by the scale of deployment.
  3. Coordinate with grid operators. The dimensions chosen should match available and future power grid capacity (Article 10(1)(b)). Where appropriate, Member States are to conduct the energy needs analysis under Article 10(2)(a), which can inform dimensional decisions.
  4. Guard against speculation. Clear location and size limits are one practical tool supporting Article 11(2)'s prohibition on speculative reservation and foreclosure practices.

Common misconceptions

Misconception 1: CADA sets a uniform maximum size for all data centres in the EU. Reality: As proposed, CADA does not set a single EU-wide maximum. Article 10(1)(a) frames minimum and maximum facility sizes as an aspect each Member State considers for its own designated zones, allowing local flexibility.

Misconception 2: "Dimension" refers only to the building footprint. Reality: Article 10(1)(a) refers to the "site or area," which would cover the whole parcel — server halls plus ancillary infrastructure such as cooling, substations and backup power.

Misconception 3: Acceleration zones are only for new greenfield sites. Reality: Article 10(1)(g) lists a preference for reusing brownfield sites over greenfield sites among the aspects to consider, so the location assessment would often weigh existing structures.

Misconception 4: Once a zone is designated, the size limits are fixed forever. Reality: Article 10(2)(a) provides that, where appropriate, Member States conduct and review at least every three years a comprehensive analysis of the energy needs of current and future zones. As conditions change, dimensional choices could be revisited, subject to the applicable legal procedures.

Related

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