Summary Under the proposed Cloud and AI Development Act (CADA), the aggregated baseline permit would be a single, zone-level authorisation that Member States issue for each designated data centre acceleration zone. As proposed in Article 13(2), it would cover the permits and administrative authorisations commonly required for data centre projects in that zone, excluding installation-specific permits. Before issuing it, the Member State would carry out the zone-level procedures and assessments — including relevant environmental assessments and planning procedures (Article 13(3)) — so that individual operators need to obtain additional permits only for activities falling outside the baseline permit (Article 13(4)). This is a proposal and is not yet in force.

Detail

CADA (COM(2026) 502 final) aims to accelerate data centre deployment across the EU. Within data centre acceleration zones (Article 10), it introduces a new permitting instrument — the aggregated baseline permit — in Article 13.

What it would be

As proposed in Article 13(2), "for each designated acceleration zone, Member States shall prepare and issue an aggregated baseline permit authorising the deployment of data centres in that acceleration zone." It would be issued per zone, not per project. The permit "shall cover the permits and administrative authorisations required for the data centre projects located within the acceleration zone, excluding installation-specific permits." That carve-out is the key boundary: the baseline permit clears the generic, zone-wide hurdles, while site-specific approvals remain with the individual operator.

(For context, recital 41 of the proposal describes the baseline permit as covering permits commonly required within the area "excluding the grid connection permits." The operative provision in Article 13(2) instead excludes "installation-specific permits"; where the recital and the article diverge, the operative article governs.)

What it would cover — and the prior assessments

To issue the permit, the Member State must do the zone-level groundwork first. Under Article 13(3), before issuing the aggregated baseline permit "Member States shall carry out all necessary procedures and assessments, including any relevant environmental assessments, planning procedures and evaluations applicable at the level of the acceleration zone." In practice this means the environmental impact, spatial-planning compatibility and other general checks for the zone are performed once, producing a pre-cleared status for compliant projects.

What stays with the operator

The baseline permit is not a blanket waiver. Article 13(4) provides that data centres in acceleration zones "shall be required to obtain additional permits only for activities falling outside the aggregated baseline permit." This creates a two-tier structure:

  1. Zone level — the aggregated baseline permit covers common, non-site-specific approvals (general environmental compatibility, broad spatial planning) cleared under Article 13(3).
  2. Project level — the operator still secures installation-specific permits for the particular facility (for example, specific construction approvals, detailed grid-connection arrangements, or site-specific measures not covered at zone level).

The precise dividing line between "common" and "installation-specific" permits would be set by each Member State in implementation.

Why this matters

EU data centre permitting is currently fragmented, with divergent national approaches causing delay. By doing the general assessments once at zone level, CADA aims to remove repetitive administrative work. The aggregated baseline permit turns the Member State's zone-level analysis into a single legal instrument that subsequent projects can build on.

How it fits with the rest of CADA

  • Article 10 requires Member States to designate acceleration zones, weighing factors such as power-grid capacity, network connectivity, waste-heat reuse and sustainability. The baseline permit is the permitting output of that planning.
  • Article 13(1) treats projects in zones as strategic projects under the proposed Regulation on speeding-up environmental assessments, giving them an accelerated environmental "toolbox."
  • Article 13(5) caps the permit-granting procedure at 12 months from a comprehensive application — realistic precisely because the baseline permit has pre-cleared the generic hurdles.
  • Article 12 establishes single information points to assist operators across the project lifecycle, including help in working out which approvals the baseline permit already covers.

What this means for you

For cloud and data centre operators, the aggregated baseline permit would reshape site selection and compliance planning. To prepare for a possible CADA adoption:

1. Prioritise acceleration zones

Sites inside designated zones would benefit from the pre-cleared status of the baseline permit, reducing early regulatory uncertainty and improving cost and schedule certainty.

2. Focus on installation-specific compliance

The baseline permit removes redundant zone-level assessments but not site-specific approvals. Use the single information point (Article 12) to confirm which activities fall outside the baseline permit for your project (Article 13(4)).

3. Engage early with authorities

Because Member States complete zone-level assessments before issuing the permit (Article 13(3)), engaging during zone designation can help ensure the baseline permit reflects your intended deployment and surface installation-specific issues early.

4. Track national implementation

CADA is a proposal and may change; Member States will also have discretion over zone scope and what counts as "installation-specific." Verify the "common vs installation-specific" line locally.

5. Use the 12-month cap

For permits you still need, Article 13(5) sets a 12-month maximum from a comprehensive application. Complete, robust dossiers are what start that clock.

Common misconceptions

"The aggregated baseline permit replaces all permits." No. It covers common, zone-wide permits only; Article 13(4) requires operators to obtain additional permits for activities outside it.

"It is issued for each individual data centre project." No. Article 13(2) requires one aggregated baseline permit per acceleration zone, covering compliant projects within it.

"You need no environmental assessment at all." No. The Member State runs the zone-level environmental assessment (Article 13(3)); site-specific environmental impacts not covered there fall under the additional permits in Article 13(4).

"It is automatic for any site in a zone." No. The Member State issues it after completing the necessary procedures and assessments; it is a pre-authorisation that simplifies — but does not eliminate — your own application.

Related

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