Summary No, participating in an Experience and Acceleration Centre for AI (Centre for AI) is not mandatory for small and medium-sized enterprises (SMEs) under the proposed Cloud and AI Development Act (CADA). As proposed in COM(2026) 502 final, the regulation establishes these centres as voluntary support structures designed to help organisations accelerate their digital transformation, not as a compulsory requirement for market access or operation. While Member States are required to establish these centres and promote their use as "entry points" to the ecosystem, SMEs retain the freedom to choose whether to engage with them. The regulation explicitly tasks centres with "helping" and "connecting" organisations, language that denotes facilitation rather than coercion.

Detail

The Cloud and AI Development Act (CADA) introduces a comprehensive framework to strengthen Europe's cloud and AI ecosystem. A central pillar of this framework is the establishment of Experience and Acceleration Centres for AI (referred to as "Centres for AI"). It is crucial for SMEs, startups, and cloud service providers to understand that these centres function as facilitators and support hubs, not as regulatory gatekeepers that mandate participation.

The Voluntary Nature of Centres for AI

Article 5 of the proposed regulation outlines the role, objectives, and tasks of these centres. The legislative text is careful to frame the relationship between the centres and the private sector as one of support. Specifically, Article 5(3)(a) states that the Centres for AI shall be tasked with "helping organisations accelerate their digital transformation through access to and use of AI technologies, including by connecting organisations with European providers of cloud and AI technologies."

The language used hereβ€”"helping" and "connecting"β€”is inherently supportive and facilitative. There is no provision in Article 5 that imposes a legal obligation on SMEs, startups, or other private entities to register with, use the services of, or purchase through a Centre for AI. The centres are designed to remove barriers to adoption by providing expertise, testing facilities, and skills support, but the decision to utilise these resources remains entirely with the individual organisation.

Furthermore, Article 5(3)(d) highlights that these centres support the scaling-up of spin-offs and startups by "facilitating access to clients, companies and organisations seeking specialised AI services." This facilitation is an offer of assistance to improve market connectivity, not a regulatory mandate. An SME can legally operate, develop AI systems, and sell cloud services without ever interacting with a Centre for AI. The regulation does not condition market access, the right to provide services, or the validity of contracts on engagement with these centres.

The Role of National Strategies

While the centres themselves do not compel participation, the broader strategic framework of CADA encourages their utilisation through national policy. Article 7 requires Member States to adopt national cloud and AI strategies within one year of the regulation's entry into force. Article 7(2)(b) specifies that these national strategies must include "measures to accelerate the development and adoption of cloud and AI at national, regional and local level, particularly among public sector bodies, SMEs and SMCs, including by supporting the Centres for AI referred to in Article 5 as entry points to the European AI innovation ecosystem."

This provision places the onus on Member States to actively promote and support these centres as "entry points" for the ecosystem. Governments may offer subsidies, grants, or preferential access to public procurement opportunities for companies that engage with these centres. However, a "measure to accelerate" or "support" is distinct from a "requirement to participate." An SME may choose to ignore these national incentives and operate independently; doing so would not constitute a breach of CADA. The obligation falls on the Member State to provide the support, not on the SME to accept it.

Distinction from Regulatory Compliance

It is important to distinguish between the voluntary support provided by Centres for AI and the mandatory regulatory obligations that SMEs might face under other parts of CADA or adjacent legislation like the AI Act. For example, if an SME develops a high-risk AI system, it must comply with the safety and transparency requirements of the AI Act. If an SME provides cloud computing services to the public sector, it may need to meet specific "Union assurance levels" under CADA's sovereignty framework (Article 16).

Centres for AI can help SMEs navigate these complex regulatory landscapes by providing guidance and testing environments. Article 5(2)(a) notes that the objectives of the centres include supporting the "integration and scaling-up of AI use cases in strategic industrial and public sectors." While this integration is highly beneficial for securing public contracts, the regulation does not stipulate that an SME must go through a Centre for AI to prove its compliance or to be eligible for contracts. The centres are a resource, not a prerequisite. The compliance burden remains on the provider to meet the statutory criteria, regardless of whether they sought assistance from a Centre.

What this means for you

For cloud service providers, data centre operators, and SMEs subject to CADA, understanding the voluntary nature of Centres for AI is vital for business strategy and compliance planning.

  1. No Forced Channel: You are not required to route your SME customers through a Centre for AI to validate their use of your services. Your contractual relationships with SMEs remain direct and governed by standard commercial and data protection laws. There is no "Centre for AI stamp of approval" required for market entry.
  2. Strategic Partnership Opportunity: While not mandatory, partnering with Centres for AI can be a significant competitive advantage. Since Article 7(2)(b) encourages national strategies to position these centres as "entry points," many SMEs will look to them for trusted recommendations. Aligning your services with the testing and validation standards promoted by these centres can enhance your market credibility and visibility.
  3. Support for Compliance: If your SME clients are struggling with the new sovereignty requirements or AI Act obligations, you can refer them to the Centres for AI for expert support. Article 5(3)(b) mentions that centres ensure or provide access to upskilling and reskilling schemes. Leveraging this network can help your clients become more compliant and thus better customers for your advanced cloud infrastructure.
  4. Monitoring National Strategies: Keep a close eye on the national cloud and AI strategies adopted by Member States under Article 7. While participation is voluntary, national governments may introduce financial incentives or procurement preferences for SMEs that engage with these centres. Understanding these incentives can help you advise your clients effectively on whether the benefits of engagement outweigh the costs.

Common misconceptions

Misconception 1: SMEs must register with a Centre for AI to operate in the EU. Reality: There is no registration requirement for SMEs to operate in the EU cloud or AI market under CADA. The centres are support bodies, not regulatory registries. An SME can operate entirely independently of these centres.

Misconception 2: Public sector bodies can only buy from SMEs that use Centres for AI. Reality: While public sector bodies are encouraged to use sovereign cloud services (Article 30), there is no rule stating that the SME providing those services must have used a Centre for AI. The procurement criteria focus on the service's assurance level and Union added value, not the supplier's engagement with support centres.

Misconception 3: The AI Act requires SMEs to test their models in a Centre for AI. Reality: The AI Act allows for testing in regulatory sandboxes (Article 57 of the AI Act), which may be linked to or hosted by Centres for AI, but this is optional. SMEs can conduct their own internal testing and validation to meet AI Act requirements without using a Centre for AI. The CADA proposal does not alter this voluntary nature.

Official sources

Related

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