Summary There is currently no publicly available request template for joining the EuroCloud Federation under the proposed Cloud and AI Development Act (CADA). Article 34(4) explicitly empowers the European Commission to adopt implementing acts that will specify the procedure for participation and define the template concerning the content and other details of the request for participation. Until these secondary legislative acts are finalized and published following the examination procedure under Article 46(2), no official form exists for legal or compliance teams to use.

Detail

The EuroCloud Federation, established under Title IV, Chapter III of the proposed CADA (COM(2026) 502 final), is designed to facilitate the voluntary sharing of public sector data centre services and cloud computing services between Union entities and public sector bodies. While the primary legislation establishes the Federation's existence and its core objectives, the specific administrative mechanics for admission are intentionally left to secondary legislation.

The Legal Basis: Article 34(4)

The governing provision for the admission process is Article 34(4). This article creates a clear legislative delegation:

"The Commission is empowered to adopt implementing acts to specify the procedure to participate in the EuroCloud Federation and template concerning the content and other details of the request for participation. Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 46(2)."

This provision establishes a two-stage legislative framework:

  1. Primary Legislation (CADA): Establishes the Federation, defines eligible participants (Union entities and public sector bodies), and grants the Commission the power to define the entry mechanism.
  2. Secondary Legislation (Implementing Acts): Will contain the actual form, specific data requirements, procedural steps, and the detailed template for the membership request.

The Examination Procedure (Article 46(2))

The implementing acts, including the final request template, must be adopted under the examination procedure referenced in Article 46(2). This is a standard EU comitology mechanism where a committee composed of representatives from Member States assists the Commission. This procedure ensures that the template and admission criteria are harmonized across the Union, preventing fragmented national approaches to EuroCloud membership and ensuring consistent application of the sovereignty framework.

Anticipated Scope of the Template

While the specific fields are not yet defined in the proposal, Article 34(4) indicates the template will cover the "content and other details" of the request. Based on the broader context of Title IV, particularly the sovereignty framework (Articles 16–24) and the sharing conditions in Article 35, the future template will likely require:

  • Proof of Eligibility: Evidence of status as a Union entity or public sector body as defined in Article 2.
  • Sovereignty Compliance: Confirmation of compliance with the relevant Union assurance level (Levels 1–4) required for the specific services being shared, potentially referencing the risk assessment outcomes under Article 29.
  • Technical & Operational Readiness: Evidence that the sharing entity has put in place the necessary technical, operational, and organizational measures to ensure effective, secure, and resilient service provision, as required by Article 35(2).
  • Hardware Ownership: Confirmation that the sharing entity directly, or indirectly through an intermediate legal entity, owns the hardware through which the service is made available, and exercises control over that entity, per Article 35(1).
  • Fee Acceptance: Acknowledgement of the cost-recovery mechanism and fee structures outlined in Article 36.

Timeline for Availability

As CADA is currently a proposal, the implementing acts under Article 34(4) will only be developed after the Regulation is formally adopted by the European Parliament and the Council. Article 48 states the Regulation will apply one year after its entry into force. Consequently, the template will not be available until the Commission initiates the drafting process for the necessary implementing acts post-adoption.

What this means for you

For in-house counsel, compliance officers, and IT directors in public sector bodies or Union entities, the absence of a current template requires proactive preparation rather than immediate application.

  1. Monitor the Official Journal: You must monitor for the publication of the implementing acts under Article 34(4). These acts will define the exact data points required for the application. Preparing internal data inventories now regarding your infrastructure ownership and sovereignty status will streamline future compliance.
  2. Assess Sovereignty Readiness: Before applying, ensure your cloud infrastructure aligns with the Union assurance levels required for your specific use cases. Article 29 mandates risk assessments to determine the appropriate assurance level. Your future membership request will likely require evidence that your services meet these sovereign standards.
  3. Review Sharing Conditions: Article 35 outlines strict conditions for sharing services, including the requirement for the sharing entity to own the hardware (directly or indirectly) and exercise control. Ensure your organizational structure and hardware ownership models comply with these definitions before submitting a request.
  4. Budget for Fees: Article 36 establishes that the costs of the EuroCloud Federation, including the assessment of membership requests, will be financed by fees levied on members. Factor these potential administrative and operational costs into your IT budgeting.

Common misconceptions

  • "The template is already available online." Incorrect. Article 34(4) explicitly delegates the creation of the template to future implementing acts. No official template exists in the current proposal text.
  • "Any cloud provider can join the EuroCloud Federation." Incorrect. Article 34(1) limits participation to Union entities and public sector bodies. Private sector entities are excluded from direct participation, although they may supply services to members.
  • "Joining is automatic upon application." Incorrect. Article 35(4) states that the Commission must assess the information provided by the sharing entity and allow sharing only where the conditions laid down in paragraphs 1 and 2 are fulfilled. This implies a vetting process, the details of which will be clarified in the implementing acts.

Related

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