Summary As proposed in the Cloud and AI Development Act (CADA), an "ecosystem approach" is a coordinated, EU-wide strategy combining supply-side measures to boost domestic capabilities, demand-side measures to drive adoption, and enablers to foster innovation and investment. The explanatory memorandum describes integrating networks, cloud, AI and software into coherent ecosystems. For public-sector procurement officers, it means moving beyond isolated purchases toward a resilient, sovereign and integrated European digital infrastructure.

Detail

The term "ecosystem approach" is central to the rationale of the proposed CADA. It reflects the Commission's view that the EU's dependence on third-country providers and its compute-capacity deficit require more than isolated regulatory fixes — they require a framework addressing the whole cloud and AI value chain.

A holistic framework: supply, demand and enablers The explanatory memorandum states that the proposal "responds to the need for a coordinated 'ecosystem approach' to make the EU more competitive and resilient in the cloud and AI area." As described there, it "combines supply-side measures to boost domestic capabilities, demand-side measures to drive adoption, and enablers to foster innovation and investment into cloud and AI." These three dimensions work together:

  1. Supply-side measures: boosting domestic capability by increasing computing capacity, developing cutting-edge cloud and AI technologies and supporting research and innovation — for example through the Cloud and AI Leadership Initiatives and their grand challenges (frontier AI, physical AI, industrial AI).
  2. Demand-side measures: driving adoption across the public and private sectors — including procurement rules, risk assessments for public-sector activities and promotion of open source. (Title IV, Chapter II is headed "Demand-side measures.")
  3. Enablers: fostering innovation and investment, with a specific focus, as the memorandum notes, on open source as a lever for technological sovereignty.

Integration of networks, cloud, AI and software A key component is integration across technology layers. The memorandum states that the research and innovation initiative launched under this framework "will integrate networks, cloud, AI and software into coherent ecosystems" to address: future challenges across energy-efficient compute infrastructure; autonomy across the cloud stack; advanced EU capabilities in frontier, physical and industrial AI; and adoption of cloud and AI across the public and private sectors. As proposed, this aligns hardware, software and connectivity developments rather than treating them in isolation.

A coordinated EU-wide response The ecosystem approach also stresses a unified EU response to fragmentation and dependence on a limited pool of third-country providers. By establishing a single EU-wide sovereignty framework and harmonised criteria for sovereign cloud computing services (Title IV), CADA aims to remove internal-market barriers and level the playing field for European providers. This involves cooperation between Member States, the Commission and stakeholders, and — as the memorandum emphasises — open source as a sovereignty lever, in line with the EU Open Source Strategy.

What this means for you

For public-sector procurement officers, the ecosystem approach has practical implications for how you plan and execute procurement.

Strategic procurement planning You would not just be buying a service; your decisions would contribute to strengthening the EU's digital sovereignty. As proposed, Article 32 would require contracting authorities to apply Union added value (non-price) award criteria in procurement of innovative cloud computing services and AI systems, letting you evaluate a tenderer's contribution to a European cloud and AI ecosystem.

Risk assessment and sovereignty levels CADA would introduce a Union cloud computing sovereignty framework with four assurance levels (Article 16). Under Article 29, Member States and Union entities would conduct risk assessments to determine the assurance level required for given activities — weighing data sensitivity, criticality and impact on public order. The ecosystem approach helps situate these assessments within the broader goal of protecting public order and operational autonomy.

Collaboration and federation The proposal would establish the European public sector cloud federation ("EuroCloud Federation") under Article 34, to facilitate the sharing of public-sector data-centre and cloud computing services between Union entities and public sector bodies on a voluntary basis. As a procurement officer, you should be aware of this platform as a route to trusted, shared services.

Open source and innovation As proposed, Article 41 would have Union entities and public sector bodies encourage and facilitate open-source solutions over proprietary ones, reducing lock-in and improving transparency — consistent with the proposal's sovereignty goals.

Common misconceptions

Misconception 1: CADA is only about data centres. While CADA includes significant data-centre provisions, the ecosystem approach is broader: it spans the cloud and AI value chain, from hardware and software to AI models, cybersecurity and skills.

Misconception 2: It's just about replacing non-EU providers with EU ones. As proposed, the goal is to build a resilient, competitive and innovative European ecosystem — fostering new providers, encouraging innovation and ensuring high security and sovereignty standards — rather than simple geographic substitution.

Misconception 3: Procurement officers are solely responsible for implementation. The ecosystem approach requires coordinated action across Member States, the Commission, industry, academia and civil society. Procurement officers drive demand, but success depends on combined efforts and information sharing.

Related

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