Definitions Glossary
82 articles
Am I a manufacturer under CADA if I rebrand a third party's hardware?
Under the proposed Cloud and AI Development Act (CADA), simply rebranding a third party’s hardware would generally not make you a "manufacturer," because C
Are EU agencies like ENISA or the ECB 'Union entities' under CADA?
Yes.
Audit criteria vs audit evidence under CADA: the difference
Under the proposed Cloud and AI Development Act (CADA), audit criteria are the cumulative requirements in Annex II that a cloud service must meet to be rec
Can a CADA provider audit its own cloud service?
No.
Can a reseller or broker be a cloud computing service provider under CADA?
Under the proposed Cloud and AI Development Act (CADA), a reseller or broker could be a cloud computing service provider (CSP) if it legally "provides" the
Data centre operator vs data centre service under CADA
As proposed, CADA distinguishes a data centre operator (a legal entity) from a data centre service (an activity).
Do CADA's definitions apply only within CADA or across other EU laws too?
As proposed, the definitions in Article 2 of the Cloud and AI Development Act (CADA) apply "for the purposes of this Regulation." CADA borrows terms from t
Does a company have to be EU-based to be a CSP under CADA?
No.
Does a hyperscaler's EU subsidiary escape the CADA control test?
No.
Does a multi-agent system count as a single AI agent under CADA?
Under the proposed Cloud and AI Development Act (CADA), a multi-agent system is not automatically a single monolith — but Article 2(5) defines an "AI agent
Does an AI agent automatically count as frontier AI under CADA?
No.
Does an AI-as-a-service offering count as a cloud computing service under CADA?
Yes — as proposed, an AI-as-a-service (AIaaS) offering would count as a cloud computing service under the Cloud and AI Development Act (CADA) where it prov
Does an edge site or server room count as a data centre under CADA?
Under the proposed Cloud and AI Development Act (CADA), an edge computing site or a server room can be a "data centre" if it falls within the definition in
Does an open-weight AI model under a restrictive licence count as open source under CADA?
Under the proposed Cloud and AI Development Act (CADA), publishing a model's weights does not by itself make the licence "open source." Article 2(25) of th
Does a public sector body that builds its own cloud become a CSP under CADA?
Yes — under the proposed Cloud and AI Development Act (CADA), a public sector body that builds and operates its own cloud can be a cloud computing service
Does CADA define cloud differently from the EUCS scheme?
No.
Does minority foreign investment trigger control under CADA?
Under the proposed Cloud and AI Development Act (CADA), minority foreign investment alone does not automatically amount to "control." But if the minority s
Does my AI model qualify as frontier AI under CADA?
As proposed in Article 2, point (4), your model is "frontier AI" only if it meets two cumulative conditions: it can perform a wide variety of tasks, and it
Does my chatbot or automation count as an AI agent under CADA?
Under the proposed Cloud and AI Development Act (CADA), a simple scripted chatbot does not automatically qualify as an "AI agent." As proposed, Article 2(5
Does my SaaS product count as a cloud computing service under CADA?
As proposed, most SaaS products would qualify as cloud computing services under the Cloud and AI Development Act (CADA) if they meet the core definition: o
Does my startup qualify as an SME under CADA?
As proposed in Article 2, point (8), CADA imports the standard EU definition of an SME from Article 2 of Annex I to Commission Recommendation 2003/361/EC.
Does the CADA software definition include firmware and AI model weights?
As proposed, the Cloud and AI Development Act (CADA) does not write its own definition of "software." CADA Article 2(13) imports it from the Cyber Resilien
Do permissive and copyleft licences count as open source under CADA?
Under the proposed Cloud and AI Development Act (CADA), both permissive licences (such as MIT, Apache 2.0 and BSD) and copyleft licences (such as the GPL f
Glossary: every term defined in Article 2 of CADA at a glance
As proposed, Article 2 of the Cloud and AI Development Act (CADA) sets out the defined terms that establish the legal vocabulary for the EU's cloud and AI
Hardware vs software vs component under CADA: what's the difference?
Under the proposed Cloud and AI Development Act (CADA), "hardware," "software" and "component" are not defined from scratch — Article 2 borrows each one fr
How CADA definitions interact across the AI Act, NIS2 and the Cyber Resilience Act
As proposed, the Cloud and AI Development Act (CADA) does not redefine core technical terms.
How CADA's audit definitions work together for sovereignty recognition
As proposed, the Cloud and AI Development Act (CADA) builds its cloud sovereignty framework on independent audits for Union assurance levels 2, 3 and 4.
How CADA's control definition affects sovereignty tier eligibility
Under the proposed Cloud and AI Development Act (CADA), the definition of "control" is decisive for which Union assurance level a cloud service can reach.
How does CADA define the actors in a sovereignty audit?
Under the proposed Cloud and AI Development Act (CADA), the actors and concepts in a sovereignty audit are defined in Article 2: Article 2(17) defines the
How does CADA define the key terms in Article 2?
Article 2 is the definitions article of the proposed Cloud and AI Development Act (CADA), COM(2026) 502 final.
How does CADA's AI system definition relate to the AI Act?
As proposed, the Cloud and AI Development Act (CADA) aligns its "AI system" definition with the EU AI Act for coherence.
How does CADA's auditing organisation definition allow consortia and subcontractors?
As proposed, an "auditing organisation" under CADA is not limited to a single legal entity.
How does CADA's frontier AI definition compare to the AI Act's GPAI with systemic risk?
The proposed Cloud and AI Development Act (CADA) defines "frontier AI" in Article 2(4) as AI models — or systems built on them — that can perform a wide va
How is a public sector body different from a contracting authority under CADA?
Under the proposed Cloud and AI Development Act (CADA), a "public sector body" is the broader category — defined by reference to the Open Data Directive (A
How is frontier AI defined differently from a general-purpose AI model under CADA?
As proposed, CADA's "frontier AI" and the EU AI Act's "general-purpose AI model" (GPAI) come at advanced AI from opposite directions.
Is a colocation provider a data centre operator or a data centre service provider under CADA?
Under the proposed Cloud and AI Development Act (CADA), a colocation provider is generally a data centre service provider — CADA defines "data centre servi
Is a GPU or AI accelerator hardware or a component under CADA?
As proposed, CADA does not define "GPU" or "AI accelerator." It classifies them as "hardware" or a "component" by reference to the Cyber Resilience Act (CR
Is a private cloud vendor to government a 'public sector body' under CADA?
No.
Is a small mid-cap eligible for the same CADA support as an SME?
Not entirely.
Is a state-owned company a public sector body under CADA?
As proposed, a state-owned company is not automatically a "public sector body" under CADA just because the State holds its shares.
Is managed hosting a cloud computing service under CADA?
As proposed, managed hosting is a cloud computing service under CADA only if it provides on-demand, broad remote access to a scalable and elastic pool of s
What are audit criteria under CADA? Annex II sovereignty rules
Under the proposed Cloud and AI Development Act (CADA), "audit criteria" are the standards an auditing organisation would use to verify whether a cloud ser
What are contracting authorities under CADA?
Under the proposed Cloud and AI Development Act (CADA), "contracting authorities" are not given a new definition.
What are Union entities under CADA?
Under the proposed Cloud and AI Development Act (CADA), Article 2(7) defines "Union entities" as "the Union institutions, bodies, offices and agencies set
What counts as a cloud computing service for CADA purposes?
For CADA purposes, a "cloud computing service" is not defined from scratch.
What distinguishes an AI agent from an ordinary AI system under CADA?
Under the proposed Cloud and AI Development Act (CADA), an AI agent is distinguished from an ordinary AI system by its ability to perceive and act on its e
What does a cloud computing service mean for cloud providers under CADA?
Under the proposed Cloud and AI Development Act (CADA), a "cloud computing service" is defined by reference to Article 6, point (30), of the NIS2 Directive
What does control mean under CADA? Third-country control explained
Under the proposed Cloud and AI Development Act (CADA), "control" is not defined from scratch.
What is a cloud computing service provider (CSP) under CADA?
Under the proposed Cloud and AI Development Act (CADA), Article 2(2) defines a "cloud computing service provider" as "a legal entity which provides a cloud
What is a cloud computing service under CADA?
Under the proposed Cloud and AI Development Act (CADA), Article 2(1) defines a "cloud computing service" by reference to Article 6, point (30) of Directive
What is a component under CADA? Article 2 definition
Under the proposed Cloud and AI Development Act (CADA), a "component" would not be defined in the proposal's own words.
What is a data centre service under CADA?
Under the proposed Cloud and AI Development Act (CADA), a "data centre service" is not defined by CADA itself; it is defined by reference.
What is a manufacturer under CADA? Definition for providers
Under the proposed Cloud and AI Development Act (CADA), "manufacturer" is not defined independently.
What is an AI agent under CADA?
Under the proposed Cloud and AI Development Act (CADA), Article 2(5) defines an "AI agent" as "an AI system or a coordinated set of AI systems, that can pe
What is an AI system under CADA?
The proposed Cloud and AI Development Act (CADA) does not invent its own meaning of "AI system".
What is an audited service under CADA?
Under the proposed Cloud and AI Development Act (CADA), an "audited service" would be, per Article 2(18), "a cloud computing service being audited for the
What is an auditing organisation under CADA? Definition and role
Under the proposed Cloud and AI Development Act (CADA), an auditing organisation is defined in Article 2(17) as "an individual organisation, a consortium o
What is an open source licence under CADA?
Under the proposed Cloud and AI Development Act (CADA), an "open source licence" is not defined from scratch.
What is an SME under CADA?
Under the proposed Cloud and AI Development Act (CADA), Article 2(8) defines a "small and medium-sized enterprise" (SME) by reference to Article 2 of Annex
What is a public sector body under CADA?
Under the proposed Cloud and AI Development Act (CADA), Article 2(6) defines a "public sector body" by reference to Article 2, point (1) of Directive (EU)
What is a small mid-cap (SMC) under CADA?
Under the proposed Cloud and AI Development Act (CADA), Article 2(9) defines a "small mid-cap" (SMC) by reference to point 2 of the Annex to Commission Rec
What is audit evidence under CADA? Article 2(20) explained
Under the proposed Cloud and AI Development Act (CADA), "audit evidence" would be defined as any information an auditing organisation uses to support its a
What is frontier AI under CADA?
Under the proposed Cloud and AI Development Act (CADA), Article 2(4) defines "frontier AI" as "AI models or AI systems built upon such models that can perf
What is hardware under CADA? Definition and scope explained
Under the proposed Cloud and AI Development Act (CADA), "hardware" is not given a new, standalone definition.
What is software under CADA? Article 2 definition explained
Under the proposed Cloud and AI Development Act (CADA), "software" would not be defined on its own.
What is the difference between a data centre service and a cloud computing service under CADA?
Under the proposed Cloud and AI Development Act (CADA), a cloud computing service is defined by its delivery model — on-demand, remote access to a scalable
What is the difference between an SME and a small mid-cap under CADA?
Under the proposed Cloud and AI Development Act (CADA), an "SME" is defined by reference to Commission Recommendation 2003/361/EC (broadly: fewer than 250
What is the difference between a public sector body and a Union entity under CADA?
Under the proposed Cloud and AI Development Act (CADA), a "public sector body" and a "Union entity" are distinct categories.
What the CADA control definition means for cloud providers seeking high assurance levels
Under the proposed Cloud and AI Development Act (CADA), the definition of "control" is the threshold that determines whether a cloud provider can reach Uni
What the contracting authorities definition means for cloud buyers under CADA
Under the proposed Cloud and AI Development Act (CADA), "contracting authorities" keeps its established meaning from EU procurement law.
What the public sector body definition means for buyers under CADA
Under the proposed Cloud and AI Development Act (CADA), a "public sector body" is defined by reference to Article 2, point (1), of Directive (EU) 2019/1024
What the SME definition means for cloud and AI startups seeking CADA support
Under the proposed Cloud and AI Development Act (CADA), small and medium-sized enterprises (SMEs) are defined by reference to Commission Recommendation 200
Which bodies count as contracting authorities for CADA procurement rules?
Under the proposed Cloud and AI Development Act (CADA), "contracting authorities" are defined by reference to Directive 2014/24/EU.
Which CADA defined terms matter most for public-sector buyers?
For public-sector buyers, the defined terms in the proposed Cloud and AI Development Act (CADA) that matter most are "public sector body," "Union entities,
Which CADA definitions are original and which are imported from other laws?
As proposed, CADA defines its key terms in Article 2, mixing original definitions with imports from existing EU law for consistency.
Which CADA definitions matter most for AI developers?
For AI developers, the most important definitions in the proposed Cloud and AI Development Act (CADA) would be ‘AI system’, ‘frontier AI’ and ‘AI agent’.
Which CADA definitions matter most for cloud providers?
Under the proposed Cloud and AI Development Act (CADA), the definitions in Article 2 are the legal bedrock that would determine whether your organisation i
Who can act as an auditing organisation under CADA?
Under the proposed Cloud and AI Development Act (CADA), an "auditing organisation" is broadly defined (Article 2(17)) as an individual organisation, a cons
Why does CADA borrow so many definitions from other EU regulations?
The proposed Cloud and AI Development Act (CADA) borrows many definitions from existing EU laws — among them the AI Act, the NIS2 Directive, and the Cyber
Why does CADA import software, hardware, component and manufacturer from the CRA?
As proposed, CADA imports the definitions of "software," "hardware," "component," and "manufacturer" from the Cyber Resilience Act (CRA, Regulation (EU) 20
Why does CADA's frontier AI definition have no fixed compute threshold?
As proposed, the Cloud and AI Development Act (CADA) defines frontier AI without a fixed compute threshold to keep the definition technologically neutral a
Why does CADA skip definitions 23 and 24 in Article 2?
The Cloud and AI Development Act (CADA) proposal, COM(2026) 502 final, contains a numbering discontinuity in Article 2: the definitions jump from point (22