Summary The proposed Cloud and AI Development Act (CADA) does not pre-select sites in Belgium. As proposed in Article 10, where data centre capacity is being deployed in its territory, Belgium would have to designate at least one data centre acceleration zone within six months of entry into force. Locations would be chosen against the aspects in Article 10(1)(a)–(h) — grid capacity, network connectivity, waste-heat reuse, a preference for brownfield over greenfield sites and sustainability. Once designated, Article 11 requires sustainability requirements based on the key performance indicators in Delegated Regulation (EU) 2024/1364 and resource allocation on fair, reasonable and non-discriminatory terms.

Detail

CADA, COM(2026) 502 final, is a proposed Regulation introducing a harmonised framework to accelerate data centre deployment across the EU. For Belgium, an active market for digital infrastructure, the obligation is direct and time-bound — but CADA does not name the sites; that is for the Belgian authorities to determine by applying the Article 10 criteria.

The obligation to designate: Article 10

As proposed in Article 10(1), where data centre capacity is being deployed, a Member State "shall designate at least one data centre acceleration zone" within six months of entry into force. When designating, Belgium would consider:

  • Site location and dimension, including minimum and maximum facility size (Article 10(1)(a)).
  • Current and future power-grid capacity, and the scope for on-site storage and clean-energy generation (Article 10(1)(b)).
  • Current and future network connectivity (Article 10(1)(c)).
  • Support for phasing out legacy copper networks (Article 10(1)(d)).
  • Waste-heat reuse facilities (Article 10(1)(e)).
  • Permitting acceleration measures (Article 10(1)(f)).
  • A preference for brownfield over greenfield sites (Article 10(1)(g)).
  • The site's ability to function sustainably and support carbon-emission reductions and climate resilience (Article 10(1)(h)).

Beyond designation, Article 10(2) requires Belgium, where appropriate, to conduct and review at least every three years an analysis of the energy needs and greenhouse-gas impacts of current and future zones, feeding into transmission and distribution system operators' network development plans. Article 10(3) requires spatial- and development-planning authorities to consider including provisions for zone projects and to combine environmental assessments where Directive 2001/42/EC and Article 6 of Directive 92/43/EEC apply. Article 10(4) requires coordination among national, regional and local authorities and with telecoms, transmission and distribution operators.

Conditions within zones: Article 11

As proposed in Article 11(1), when setting sustainability requirements for data centres in zones, Member States "shall use the key performance indicators specified in Delegated Regulation (EU) 2024/1364" (adopted under the Energy Efficiency Directive (EU) 2023/1791), Annex II, points (a) to (n). Article 11(2) requires that resource allocation and use within zones take place on fair, reasonable and non-discriminatory terms and not give rise to speculative reservation or foreclosure practices capable of impeding competition or the effective development or use of the zones.

Faster permitting: Article 13

Designation triggers procedural benefits under Article 13. Data centre projects in zones are treated as strategic projects under the proposed Regulation on speeding-up environmental assessments and benefit from its toolbox (Article 13(1)). Belgium would prepare and issue an aggregated baseline permit per zone, covering the permits and authorisations required for projects in the zone except installation-specific permits (Article 13(2)–(4)); before issuing it, Belgium would carry out the necessary procedures and assessments — including relevant environmental assessments, planning procedures and evaluations — at the level of the zone (Article 13(3)). Data centres in a zone then need additional permits only for activities falling outside the baseline permit (Article 13(4)). The permit-granting procedure must not exceed 12 months from a comprehensive application (Article 13(5)), without prejudice to shorter national limits; and where a "highest national significance" status exists in national law, projects are to be allocated that status — though Article 13(5) does not oblige Belgium to create such a status if it does not already have one.

The single information point: Article 12

Under Article 12(1), a data centre operator has the right, on request, to be assisted by a single information point throughout the entire lifecycle of a project in an acceleration zone, in respect of all authorisations required for deployment. Belgium would designate one or more such points. In a country where authorisations can sit with federal, regional and local bodies, this one-stop function is meant to spare operators from assembling and chasing a patchwork of separate procedures; it is the practical counterpart to the aggregated baseline permit, channelling the operator's interactions through a single contact.

What this means for you

For CTOs, architects and SMEs assessing CADA's impact in Belgium:

Site selection. Expect Belgium to publish its designated zone(s) within six months of entry into force. Direct your site strategy toward those zones; projects outside them would not get the zone-specific facilitations. Inside a zone, the aggregated baseline permit pre-clears many approvals — but you must still meet the Article 11 / Delegated Regulation (EU) 2024/1364 sustainability KPIs.

Sustainability and energy planning. The emphasis in Article 10(1) on grid capacity, clean-energy generation and waste-heat reuse means your designs should show how the facility integrates with the local energy system rather than simply drawing from the grid.

Competitive positioning. Article 11(2)'s fair, reasonable and non-discriminatory allocation is a safeguard for smaller players against incumbents reserving resources without building. As an SME you must still be ready to build and operate, since speculative reservation is prohibited.

Compliance and engagement. Engage early with the single information point Belgium designates for your zone (Article 12), which assists with authorisations, assessments and grid connections, and have documentation ready to demonstrate KPI compliance. Two practical points follow from the structure of Article 13: first, the "comprehensive application" is what starts the 12-month clock, so front-loading a complete, well-evidenced application is the single biggest lever you have over timeline; second, because the baseline permit is prepared at zone level, items that are genuinely installation-specific will still need separate authorisation — mapping early which of your requirements fall inside versus outside the baseline permit avoids surprises late in the project.

Reading the zone designation as a signal. Because Belgium must weigh grid capacity, connectivity and waste-heat reuse when choosing a zone (Article 10(1)(b), (c) and (e)), the eventual designation is itself information: it tells you where Belgium believes the energy and network headroom exists. For capacity planning, the designated zone(s) and the supporting energy-needs analysis under Article 10(2) are a more reliable guide to where large loads can realistically connect than general market commentary.

Why the planning integration in Article 10(3) and (4) matters

Two procedural features separate a zone that merely exists from one that actually accelerates deployment. First, Article 10(3) pulls data centre provisions into national, regional and local spatial and development plans and, where Directive 2001/42/EC (strategic environmental assessment) and Article 6 of Directive 92/43/EEC (Habitats) apply, requires those assessments to be combined — and, where applicable, to address impacts on water bodies under Directive 2000/60/EC. Doing this work at zone level is what allows the later, project-level baseline permit under Article 13 to issue quickly. Second, Article 10(4) requires Belgium to coordinate among all relevant national, regional and local authorities and with telecoms, transmission and distribution system operators. In Belgium's multi-level system this coordination is precisely the friction the zone framework is meant to remove, so the quality of that coordination is a fair proxy for how much faster a zone will really be.

Sustainability as a gate

Article 11(1) ties zone sustainability requirements to the KPIs in Delegated Regulation (EU) 2024/1364 — points (a) to (n) of its Annex II — which set the energy, water and related indicators under the Union data centre rating framework. These are fixed at EU level, not negotiable locally, so designing and instrumenting facilities against them from the start is far cheaper than retrofitting measurement later. Treat the KPIs as an entry condition for operating in a zone rather than as reporting overhead.

Common misconceptions

"CADA selects the locations." Incorrect. CADA sets the framework and criteria; the designation is the Member State's responsibility, which in Belgium would involve federal, regional and local coordination, guided by Article 10.

"Zones automatically guarantee permits." Incorrect. Article 13 provides an aggregated baseline permit and a 12-month maximum, but projects must still meet environmental and technical standards, and installation-specific permits remain.

"Only large hyperscalers benefit." Incorrect. Article 11(2) requires fair, reasonable and non-discriminatory allocation, designed to keep zones open to smaller operators — who must meet the same sustainability and technical standards.

"Brownfield sites are mandatory." Incorrect. Article 10(1)(g) states a preference for brownfield over greenfield; greenfield is not banned, but expect to justify it against the sustainability criteria.

Related

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