Summary Under the proposed Cloud and AI Development Act (CADA), an 'open call for expression of interest' is the exclusive, mandatory gateway for a project to be recognised as a 'frontier AI priority project'. As set out in Article 8, the Commission may only grant this status to projects selected through these competitive calls. To qualify, a project must be pioneering, undertaken by a European digital infrastructure consortium (or eligible entity), involve at least three Member States, and demonstrate that those states are pooling computing resources. This recognition is the prerequisite for unlocking matched Union AI computing resources under Article 9. Unlike data centre strategic projects (Article 14), which focus on physical infrastructure, this mechanism targets the development of next-generation AI models and systems.

Detail

The proposed Cloud and AI Development Act (CADA), COM(2026) 502 final, establishes a dual-track approach to strengthening Europe's technological sovereignty: one track for physical infrastructure (data centres) and another for advanced AI capabilities. The latter is governed by Article 8, which defines the specific procedure for recognising 'frontier AI priority projects'.

The Mandatory Nature of the Open Call

Article 8 is explicit: the Commission may recognise projects as frontier AI priority projects "provided that the following criteria are fulfilled" and, critically, that they are "selected through open calls for expression of interest."

This phrasing establishes the open call not as an optional administrative step, but as the sole selection route. A project cannot be designated as a priority project through direct negotiation, national nomination, or automatic classification based on technical merit alone. The "open call" mechanism ensures a transparent, competitive, and Union-wide selection process. It allows the Commission to identify the most strategic initiatives that align with the Union's goal of developing frontier AI as a strategic asset.

The term "frontier AI" is defined in Article 2(4) as "AI models or AI systems built upon such models that can perform a wide variety of tasks and that approach, reach or exceed the current state of the art." The open call is the filter through which the Commission determines which specific projects meet this high threshold and possess the necessary strategic value to warrant Union support.

The Three Cumulative Criteria for Selection

Before the Commission can issue a formal decision recognising a project, the project must successfully navigate the open call and satisfy three cumulative criteria outlined in Article 8:

  1. Pioneering Nature: The project must be "a pioneering project, focused on the support and scaling-up of frontier AI technologies." This criterion ensures that the initiative is not merely incremental but aims to push the boundaries of current algorithmic capabilities, potentially in key sectors such as cybersecurity, as noted in the recitals.
  2. Legal Structure and Cross-Border Participation: The project must be "undertaken by a European digital infrastructure consortium established pursuant Decision (EU) 2022/2481 or another legal entity eligible for funding under Union law." Crucially, it must "involve the participation of at least three Member States." This requirement enforces a pan-European approach, preventing fragmentation and ensuring that the benefits of the project are distributed across the Union.
  3. Resource Pooling: The participating Member States must "pool computing time and other relevant resources to support the implementation of the designated project." This criterion ensures that the project is backed by tangible national commitments, creating a "flywheel" of investment and capacity that the Union can then match.

Only after a project is selected through this open call and verified against these criteria does the Commission adopt a decision to formally recognise it. This decision is the legal instrument that confers the status of 'frontier AI priority project'.

Comparison with Data Centre Strategic Projects (Article 14)

It is vital to distinguish the Article 8 mechanism for frontier AI from the Article 14 mechanism for data centre strategic projects. While both utilise "open calls for expressions of interest" as their selection vehicle, their objectives, criteria, and outcomes differ significantly:

Feature Frontier AI Priority Projects (Article 8) Data Centre Strategic Projects (Article 14)
Primary Focus Development and scaling of frontier AI models and systems. Deployment of physical data centre infrastructure.
Selection Criteria Pioneering nature; involvement of ≥3 Member States; resource pooling. Sustainability/innovation; grid stability; supply chain integration (EU chips); addressing capacity shortages.
Legal Entity European digital infrastructure consortium or eligible Union-funded entity. Project applicant (can be a single entity or consortium).
Key Benefit Matching of AI computing resources from Union EuroHPC capacity (Article 9). Eligibility for public support measures, the 'competitiveness seal', and accelerated permitting.
Strategic Goal Reducing dependence on third-country AI technologies; building sovereign AI capabilities. Increasing EU data centre capacity; reducing reliance on foreign hyperscalers for infrastructure.

Both mechanisms share the goal of reducing third-country dependencies and ensuring strategic assets are developed through transparent, merit-based processes. However, the Article 8 route is specifically designed for the software and algorithmic layer of the AI stack, requiring deep cross-border collaboration, whereas Article 14 addresses the hardware and facility layer, often focusing on sustainability and grid integration.

The Commission's Decision and Recognition

The outcome of the open call is not automatic. Once the Commission reviews the expressions of interest, it adopts a formal decision to recognise the project. This decision is the legal instrument that confers the status of 'frontier AI priority project'. Without this Commission decision, a project cannot claim the associated rights.

The most significant right unlocked by this recognition is found in Article 9. Once a project is recognised, "The Union and the Member States shall ensure that sufficient AI computing resources from their compute capacities are allocated to support the development of frontier AI priority projects." Furthermore, Article 9(2) states that "The Union shall at least match the AI computing resources contributed by Member States to frontier AI priority projects to the extent that sufficient AI computing capacity is available within the Union's share of European high performance computing access time."

Thus, the open call is the critical first step in a value chain: Open Call → Selection → Commission Decision → Recognition → Matching of Compute Resources.

What this means for you

For AI developers, research consortia, cloud service providers, and national authorities, understanding the 'open call for expression of interest' is critical for strategic planning and resource allocation.

  1. Form a Cross-Border Consortium Early: You cannot apply alone. Article 8 mandates that the project be undertaken by a European digital infrastructure consortium or similar entity involving at least three Member States. If you are a private entity, you must partner with national authorities and other Member States to form a consortium capable of pooling resources.
  2. Align with "Pioneering" Criteria: Your expression of interest must clearly articulate how your project is "pioneering" and focused on "scaling-up frontier AI technologies." Generic AI applications or incremental improvements will likely fail the selection filter. The proposal emphasises sectors like cybersecurity, physical AI, and industrial AI as areas of strategic importance.
  3. Secure National Commitments: The requirement for Member States to "pool computing time and other relevant resources" means that your application must be backed by concrete commitments from national governments. You must demonstrate that these states are prepared to contribute EuroHPC capacity or other resources to the project.
  4. Monitor Commission Publications: The Commission will issue specific calls for expression of interest. These will be published in the Official Journal and relevant EU procurement portals. Missing a deadline means missing the window for recognition and the associated compute subsidies.
  5. Prepare for the "Matching" Benefit: Once recognised, your project gains access to matched AI computing resources from the Union's EuroHPC capacity (Article 9). This can significantly lower your training costs and accelerate time-to-market for state-of-the-art models. However, this benefit is contingent on the Member States fulfilling their pooling obligations.

Common misconceptions

  • Misconception 1: Any frontier AI project is automatically a 'priority project'.
    • Reality: No. Article 8 makes it clear that recognition is contingent on being selected through an open call for expression of interest. Merely building a state-of-the-art model is insufficient; you must successfully navigate the competitive selection process.
  • Misconception 2: The 'open call' is just a formality.
    • Reality: It is the primary filter. The Commission uses these calls to ensure that only projects with broad EU participation (≥3 Member States) and strong strategic alignment receive public support. Projects failing to meet the criteria in Article 8 will not be recognised.
  • Misconception 3: This process is the same as applying for data centre funding.
    • Reality: While both use 'open calls for expression of interest,' the frameworks are distinct. Frontier AI projects (Article 8) focus on model development and compute access. Data centre strategic projects (Article 14) focus on physical infrastructure deployment and may result in different types of support (e.g., permitting acceleration, financial aid). Do not confuse the application criteria.
  • Misconception 4: Private companies can apply alone.
    • Reality: Article 8 requires the project to be undertaken by a European digital infrastructure consortium or similar eligible entity involving multiple Member States. Solo private applications will not meet the participation threshold.

Official sources

Related

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