What is the national cloud and AI strategy required by CADA?

As proposed, the Cloud and AI Development Act (CADA) requires every EU Member State to establish a national cloud and AI strategy within one year of the re

Summary As proposed, the Cloud and AI Development Act (CADA) requires every EU Member State to establish a national cloud and AI strategy within one year of the regulation's entry into force, under Article 7. These strategies must, at a minimum, cover eight elements — from objectives and governance to open hardware and software and data accessibility — and align with CADA's goals of building capacity, strengthening technological sovereignty and accelerating cloud and AI uptake. They must also include the public-procurement-of-innovation plans linked to Article 33, including how the Member State will pursue the goal of awarding at least 25% of cloud and AI procurement to innovative SMEs.

Detail

The proposed CADA creates a coordinated framework to strengthen Europe's cloud and AI ecosystem, addressing dependencies on third-country providers and a shortage of domestic compute capacity. A cornerstone is the obligation for Member States to develop national strategies that translate EU-level goals into national priorities.

The obligation to adopt a national strategy (Article 7)

Under Article 7(1), Member States must establish national cloud and AI strategies ("national strategies") by the same day as the regulation's entry into force plus one year.

The proposal allows for existing strategies. Article 7(3) requires national strategies to be consistent with the objectives of the regulation; where an existing strategy already adequately covers those objectives a new one is not needed, but gaps must be addressed.

Required content of the strategy

Article 7(2) requires national strategies to include at least the following:

Objectives and governance: Key objectives and priorities for cloud and AI adoption, in line with the "AI first" principle, plus a governance and monitoring framework.
Acceleration measures: Measures to accelerate cloud and AI development at national, regional and local level, particularly among public sector bodies, SMEs and small mid-caps (SMCs), including by supporting the Experience and Acceleration Centres for AI (Article 5) as entry points to the European AI innovation ecosystem.
Sectoral deployment: Measures to support broad deployment and uptake of AI in strategic industrial and public sectors, including healthcare, energy and mobility.
Data centre capacity: Measures to support data centre capacity, with a focus on high-value data centres delivering significant economic and societal benefits while meeting high environmental and energy-efficiency standards.
High-intensity computing: Measures to invest in high-intensity computing infrastructure — including AI factories, AI gigafactories and quantum computers — as strategic national and cross-border assets.
Procurement and innovation: Measures to support cloud and AI capabilities through public procurement, including the public-procurement-of-innovation measures in Article 33.
Open hardware and software: Measures to support cloud computing stack technologies built on open hardware and software, to strengthen technological sovereignty.
Data accessibility: Measures to ensure accessibility of high-quality data for AI development, notably by preventing data bottlenecks.

Alignment with EU targets and monitoring

National strategies must be consistent with the objectives of CADA (Article 7(3)) and, under Article 7(4), consistent with and contributing to the digital targets established under Article 4 of the Digital Decade Policy Programme (Decision (EU) 2022/2481).

Under Article 7(5), Member States must notify the Commission of their national strategies within three months of adoption, assess them at least every three years on the basis of key performance indicators and update them where necessary; the Commission monitors their adoption and revision.

The role of the European Artificial Intelligence Board

Under Article 7(6), the European Artificial Intelligence Board (the "AI Board"), established by the AI Act (Regulation (EU) 2024/1689), shall advise and assist Member States on coordinating national strategies and shall facilitate the exchange of best practices among Member States.

Link to procurement plans (Article 33)

A key operational component is the link to procurement. Article 33(1) requires Member States to monitor and report on their use of procurement of innovation in cloud computing services and AI systems.

Article 33(4) sets the relevant objective: Member States "shall pursue as objective that at least 25% of their procurement for cloud computing services and AI systems be awarded to innovative SMEs," and shall include, in their Article 7 national strategies, plans on how they intend to achieve it. Under Article 33(3), Member States report yearly to the Commission on the size of economic operators participating, SME participation trends (including the number and value share of contracts awarded to SMEs), and measures taken to improve SME access.

This creates a feedback loop: the national strategy sets the high-level sovereignty and innovation goals, while the procurement plans within it provide concrete mechanisms — such as division into lots and SME-friendly procedures (Article 33(2)) — to realise them.

What this means for you

For public-sector and procurement officers, Articles 7 and 33 would shift purchasing from ad-hoc to strategic, ecosystem-building procurement.

Strategy integration: Ensure your national or regional strategy addresses all eight elements in Article 7(2). If it lacks components on open-source stacks, data centre sustainability or procurement-of-innovation targets, it would need updating within the one-year deadline.
Procurement targets: Your procurement plans should set out a roadmap toward the 25% SME objective, designing tenders accessible to smaller, innovative EU-based providers rather than defaulting to large incumbents.
Monitoring and reporting: Prepare for yearly reporting to the Commission on the size of operators participating, the share of contracts awarded to SMEs, and the barriers they face.
Collaboration: Engage with the AI Board and the Centres for AI to align local implementation with cross-EU best practices.

Common misconceptions

"We already have an AI strategy, so we are exempt."
- Correction: Article 7(3) only spares Member States a new strategy where an existing one adequately covers the regulation's objectives. Given the new sovereignty framework, specific data centre and high-intensity-computing measures and the 25% SME objective, many existing strategies would need significant updates.
"The 25% SME target is a per-tender quota."
- Correction: Article 33(4) frames it as an objective Member States "shall pursue" for their overall cloud and AI procurement, not a quota for each individual tender. You must, however, include a plan in your national strategy for achieving the aggregate goal.
"National strategies are purely domestic documents."
- Correction: Article 7 requires consistency with the Digital Decade targets and notification to the Commission, and the AI Board facilitates cross-border coordination — so strategies should interoperate with EU-wide initiatives such as the EuroCloud Federation.

Official sources

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