Summary Under the proposed Cloud and AI Development Act (CADA), Member States are required to designate at least one "data centre acceleration zone" where data centre capacity is being deployed. Article 10(1) of the proposal mandates that authorities evaluate eight specific aspects before designating these zones. These criteria cover: (a) site location and dimensions; (b) power grid capacity and clean energy generation; (c) network connectivity; (d) the capacity to phase out legacy copper networks; (e) facilities for waste heat reuse; (f) measures to accelerate permit granting; (g) a preference for brownfield over greenfield sites; and (h) the site's overall sustainability and climate resilience. These requirements ensure that accelerated deployment does not come at the expense of energy security, environmental standards, or future-proof infrastructure.
Detail
The Cloud and AI Development Act (CADA), as proposed in COM(2026) 502 final, seeks to address the Union's critical shortage of computing capacity and the concentration of data centre deployment in a limited number of hubs. To achieve this, the proposal introduces a framework for "data centre acceleration zones" (acceleration zones). These are specific geographic areas where the development, expansion, and modernisation of data centres are facilitated through streamlined regulatory processes and targeted infrastructure support.
Article 10 of the CADA proposal places a direct obligation on Member States to designate at least one acceleration zone within their territory where data centre capacity is being deployed. However, this designation is not a matter of administrative discretion alone. To ensure that these zones contribute effectively to the Union's digital sovereignty, energy efficiency, and industrial competitiveness, Member States must consider a specific set of eight aspects outlined in Article 10(1)(a) through (h).
The proposal states that when designating acceleration zones, Member States shall consider the following aspects:
1. Location, Dimension, and Facility Size [Article 10(1)(a)]
The first aspect requires Member States to evaluate the physical characteristics of the proposed zone. Authorities must consider "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 criterion ensures that the zone is appropriately scaled for the intended data centre projects. It prevents the designation of sites that are too small to host strategic, large-scale facilities or, conversely, sites that are so vast they lead to land speculation or inefficient use of resources. By defining the minimum and maximum size parameters, Member States can align the zone's capacity with the specific needs of the EU's growing demand for compute, ensuring that the infrastructure deployed matches the scale required for frontier AI and industrial applications.
2. Power Grid Capacity and Clean Energy Generation [Article 10(1)(b)]
Energy availability is identified as a fundamental enabling condition for data centre deployment. The second aspect mandates that Member States assess "the available and future power grid capacity and the possibility and conditions for on-site storage and clean energy generation."
Data centres are energy-intensive, and their deployment in areas with constrained grid capacity could lead to supply instability or delays. This criterion requires authorities to look beyond current capacity and evaluate future grid needs. Crucially, it explicitly links acceleration zones to the green transition by requiring an assessment of the potential for on-site energy storage and clean energy generation. This ensures that new capacity is not merely added to a strained grid but is integrated with renewable sources, supporting the EU's climate goals while securing the energy supply necessary for AI workloads.
3. Network Connectivity Capacity [Article 10(1)(c)]
Data centres are ineffective without high-speed, low-latency connectivity. The third aspect requires consideration of "the available and future network connectivity capacity."
This ensures that acceleration zones are situated where they can support the rigorous bandwidth and latency requirements of modern cloud and AI workloads. It prevents the designation of zones that, while energetically viable, are disconnected from the high-speed fibre or 5G/6G networks required to serve the digital economy. By mandating an assessment of future connectivity, the proposal ensures that the infrastructure deployed today remains viable for the next generation of data-intensive applications.
4. Capacity to Phase Out Legacy Copper Networks [Article 10(1)(d)]
In line with the EU's broader digital connectivity goals, Member States must consider "the capacity of the zone to support the phasing out of legacy copper networks."
This aspect promotes the transition from outdated copper-based infrastructure to modern, fibre-based or advanced wireless technologies. Legacy copper networks are often insufficient for the high-speed data transfer required by AI and cloud services and are increasingly costly to maintain. By prioritising zones capable of supporting this phase-out, CADA ensures that acceleration zones are built on future-proof communication infrastructure, facilitating the digital transformation of the regions they serve.
5. Facilities for Waste Heat Reuse [Article 10(1)(e)]
Sustainability is a central pillar of the CADA proposal. The fifth aspect mandates that Member States consider "the available and future facilities that can reuse data centre waste heat."
Data centres generate significant amounts of heat as a byproduct of their operations. Rather than dissipating this energy into the atmosphere, the proposal encourages its capture and reuse for district heating, industrial processes, or other applications. By requiring an assessment of waste heat reuse facilities, Member States can ensure that acceleration zones are integrated into local energy ecosystems. This maximises energy efficiency, reduces the overall environmental footprint of the data centre, and provides a tangible benefit to the local community through shared thermal resources.
6. Measures to Accelerate Permit Granting [Article 10(1)(f)]
The primary purpose of an acceleration zone is to speed up deployment. Therefore, the sixth aspect requires Member States to consider "all the measures taken to accelerate the granting of the necessary permits for constructing and operating data centres within the given zone."
This criterion focuses on the administrative and regulatory environment. It requires authorities to evaluate whether existing frameworks are sufficient to reduce permitting times or if additional measures are needed. This aligns with the broader CADA objective of reducing the time limit for permit-granting procedures for data centre projects in acceleration zones to no more than 12 months. By assessing these measures upfront, Member States ensure that the "acceleration" promised by the zone designation is backed by concrete administrative reforms.
7. Preference for Brownfield Sites [Article 10(1)(g)]
To minimise environmental impact and promote urban regeneration, the proposal explicitly states a "preference for reusing brownfield sites over using greenfield sites."
Brownfield sites are previously developed lands that may be contaminated, underutilised, or located in industrial areas. Greenfield sites are undeveloped land, often in natural or agricultural settings. By mandating a preference for brownfield sites, CADA aims to reduce pressure on natural landscapes, promote sustainable land use, and revitalise existing industrial areas. This criterion ensures that the expansion of digital infrastructure contributes to the regeneration of the built environment rather than the consumption of new land.
8. Sustainability and Climate Resilience [Article 10(1)(h)]
Finally, Member States must assess "the ability of the site or area to function sustainably, particularly as regards preventing or minimising environmental impacts and supporting the reduction of carbon emissions and its climate resilience."
This broad criterion acts as a comprehensive sustainability check. It requires authorities to evaluate not just the immediate environmental impact of the data centre, but also the site's long-term resilience to climate change (e.g., flood risks, extreme heat). It ensures that acceleration zones are not only technically viable and energy-efficient but also environmentally responsible and capable of withstanding future climate-related disruptions. This aligns with the proposal's objective to triple EU data centre capacity while ensuring balanced geographic deployment and high environmental standards.
What this means for you
For public-sector bodies, local planners, and cloud service providers, understanding these eight aspects is critical for strategic planning and compliance under the proposed CADA.
1. Strategic Site Selection for Public Procurement
If you are a contracting authority or a public-sector body planning to procure cloud services or build public data centre infrastructure, you should prioritise locations within designated acceleration zones. These zones are designed to offer a predictable regulatory environment, faster permitting, and better integration with green energy and waste heat reuse facilities. Under CADA's sovereignty framework, services hosted in these zones are more likely to meet the high environmental and operational standards required for public-order-relevant activities.
2. Compliance for Data Centre Operators
For data centre operators and investors, the eight aspects of Article 10(1) serve as a checklist for site viability. Before investing in a new facility, operators should verify that the site meets the criteria for an acceleration zone, particularly regarding grid capacity, connectivity, and waste heat reuse. Failure to align with these criteria could result in a site being excluded from the accelerated permitting regime, leading to longer deployment times and higher regulatory uncertainty.
3. Local and Regional Planning Integration
Local and regional authorities must ensure that their spatial and development plans account for these acceleration zones. This involves coordinating with national authorities to ensure that the necessary grid connections, waste heat reuse facilities, and network infrastructure are in place to support the designated zones. The preference for brownfield sites also implies a need to identify and remediate underutilised industrial lands, turning them into hubs for digital infrastructure.
4. Monitoring and Reporting
Member States are required to conduct comprehensive analyses of the energy needs and impacts of acceleration zones and review them at least every three years. Stakeholders should be prepared to provide data and feedback during these reviews to ensure that the zones continue to meet the evolving needs of the EU's cloud and AI ecosystem.
Common misconceptions
Misconception 1: Acceleration zones are only for large hyperscalers. While hyperscalers may be significant players, the CADA aims to support a diverse range of providers, including European cloud providers and smaller operators. The designation of acceleration zones is intended to boost the overall EU cloud ecosystem, not just benefit a few large players. The criteria in Article 10(1) apply to all data centre projects within the zone, regardless of the provider's size.
Misconception 2: Brownfield preference means greenfield sites are banned. The CADA expresses a preference for brownfield sites, not a prohibition on greenfield development. Greenfield sites may still be designated as acceleration zones if they meet the other criteria, particularly regarding sustainability and grid connectivity. However, authorities must justify why a brownfield site was not suitable if they choose a greenfield location. The preference is a guiding principle to encourage sustainable land use, not an absolute ban.
Misconception 3: Designation guarantees automatic permits. Designating an acceleration zone does not mean that permits are automatically granted. It means that the regulatory process is streamlined and accelerated. Projects still need to meet all relevant environmental, safety, and technical standards, but the administrative hurdles are reduced. The 12-month time limit for permit granting applies only where a comprehensive application has been submitted and the project meets the necessary criteria.
Misconception 4: The criteria are optional guidelines. Article 10(1) uses the mandatory language "shall consider." This means that Member States are legally obliged to evaluate all eight aspects when designating a zone. Failure to consider any of these aspects could render the designation non-compliant with the proposed regulation, potentially leading to legal challenges or the inability to access EU support measures for strategic projects.
Related
- Must Member States analyse the energy needs of acceleration zones under CADA?
- CADA Article 13: What must Member States do before issuing the aggregated baseline permit?
- How many data centre acceleration zones must a Member State designate under CADA?
- Are CADA acceleration zones mandatory or optional for Member States?
- Which KPIs must data centres in acceleration zones use under CADA?
This is general information about a draft EU regulation, not legal advice.