Summary Under the proposed Cloud and AI Development Act (CADA), Croatia is legally required to designate at least one data centre acceleration zone within six months of the Regulation's entry into force, provided data centre capacity is being deployed in its territory (Article 10(1)). The specific geographic locations are not predetermined by EU law; instead, Croatian authorities must select sites based on strict criteria including grid capacity, network connectivity, waste-heat reuse potential, and a preference for brownfield sites (Article 10(1)(a)–(h)). Once designated, these zones must enforce sustainability standards defined by Delegated Regulation (EU) 2024/1364 and ensure fair, reasonable, and non-discriminatory resource allocation (Article 11).

Detail

The Legal Obligation to Designate Zones

As proposed in the Cloud and AI Development Act (COM(2026) 502 final), Member States where data centre capacity is being deployed face a mandatory obligation to designate at least one data centre acceleration zone. Article 10(1) of CADA sets a strict deadline: this designation must occur by the date of entry into force of the Regulation plus six months. For Croatia, this means the national government must identify and formally designate these zones relatively quickly after the law becomes applicable, ensuring that the regulatory framework for accelerated deployment is in place.

The designation is not arbitrary. Article 10(1) mandates that Member States consider a specific set of factors when selecting the location and dimension of the site. These factors are designed to ensure that new data centre capacity is sustainable, efficient, and integrated into the existing infrastructure rather than creating new environmental or logistical burdens. The proposal aims to triple EU capacity in the next five-to-seven years, and acceleration zones are the primary mechanism to achieve this by streamlining deployment in strategic locations.

Site Selection Criteria (Article 10(1)(a)–(h))

When Croatian authorities evaluate potential sites for acceleration zones, they must weigh the following criteria explicitly listed in Article 10(1):

  • Site Dimensions and Capacity: The location and dimension of the site, including the minimum and maximum size of facilities that could be built (Article 10(1)(a)).
  • Energy Grid Integration: The available and future power grid capacity, as well as the possibility and conditions for on-site storage and clean energy generation (Article 10(1)(b)). This is critical for ensuring that new data centres do not strain the local grid beyond its limits.
  • Network Connectivity: The available and future network connectivity capacity (Article 10(1)(c)). Low-latency connectivity is a prerequisite for high-performance computing and AI workloads.
  • Legacy Infrastructure Phase-Out: The capacity of the zone to support the phasing out of legacy copper networks (Article 10(1)(d)).
  • Waste Heat Reuse: The availability of facilities that can reuse data centre waste heat (Article 10(1)(e)). This criterion promotes circular economy principles by utilizing excess thermal energy for district heating or industrial processes.
  • Permitting Acceleration: All measures taken to accelerate the granting of necessary permits for constructing and operating data centres within the zone (Article 10(1)(f)).
  • Brownfield Preference: A preference for reusing brownfield sites (previously developed land) over greenfield sites (undeveloped land) (Article 10(1)(g)). This aims to minimize environmental impact and urban sprawl.
  • Sustainability and Climate Resilience: The ability of the site to function sustainably, particularly regarding preventing or minimizing environmental impacts, supporting carbon emission reduction, and ensuring climate resilience (Article 10(1)(h)).

Energy Planning and Grid Coordination

Beyond site selection, Article 10(2) requires Croatia to conduct a comprehensive analysis of the energy needs and their respective impacts on greenhouse gas emissions for current and future acceleration zones. This analysis must be conducted at least every three years. Crucially, this analysis must inform the national network development plans prepared by transmission and distribution system operators. This ensures that grid investments are anticipatory, accommodating future system needs rather than reacting to them after data centres are already built. The proposal explicitly links these zones to the need for "anticipatory grid investments" to avoid bottlenecks.

Conditions Within Acceleration Zones (Article 11)

Once designated, these zones operate under specific conditions outlined in Article 11.

Sustainability Standards: Article 11(1) mandates that Member States must use the key performance indicators (KPIs) specified in Delegated Regulation (EU) 2024/1364 (pursuant to Directive (EU) 2023/1791) when setting sustainability requirements for data centres deployed in acceleration zones. This includes metrics on energy efficiency (such as Power Usage Effectiveness), water usage, and other environmental impacts. Compliance with these KPIs is not optional; it is a condition of operating within the accelerated framework. It is important to note that these specific KPIs are enumerated in the Delegated Regulation, not in the CADA text itself, though CADA makes them binding for these zones.

Fair Resource Allocation: Article 11(2) requires that the allocation and use of resources within acceleration zones take place on fair, reasonable, and non-discriminatory terms. This provision is designed to prevent speculative reservation of resources (e.g., land or grid capacity) that could impede effective competition or the development of the zone. It ensures that multiple operators can access the benefits of the acceleration zone without being locked out by incumbents or speculative actors.

Strategic Projects and Permitting Speed

While Article 10 and 11 set the stage, the practical benefit for operators is the accelerated permitting process described in Article 13. Data centre projects in these zones are considered "strategic projects" under a forthcoming EU regulation on speeding up environmental assessments. This allows them to benefit from a "toolbox" of accelerated procedures. Furthermore, Member States must issue an "aggregated baseline permit" for the zone, covering common permits. Individual data centres then only need additional permits for activities outside this baseline, with the entire process capped at a maximum of 12 months from the submission of a comprehensive application (Article 13(5)).

What this means for you

For CTOs, architects, and SMEs evaluating the practical impact of CADA in Croatia, the designation of acceleration zones represents a significant shift in how you plan for compute infrastructure.

1. Site Selection Strategy: You should begin identifying potential brownfield sites in Croatia that align with the Article 10(1) criteria. Look for locations with existing industrial infrastructure (brownfield preference) that have demonstrated potential for waste-heat reuse (e.g., proximity to district heating networks). Prioritize sites with confirmed access to high-capacity grid connections and fiber optic networks. Early engagement with Croatian grid operators to understand future capacity plans will be advantageous, as Article 10(2) requires these plans to account for acceleration zone needs.

2. Sustainability Compliance: Ensure your data centre designs are optimized for the KPIs in Delegated Regulation (EU) 2024/1364. Since these KPIs will be mandatory in acceleration zones, your architectural plans should prioritize high Power Usage Effectiveness (PUE) and water efficiency. Failure to meet these sustainability standards could disqualify a project from the accelerated permitting benefits, pushing it back into standard, slower national permitting tracks.

3. Competitive Positioning: Article 11(2)'s requirement for fair, reasonable, and non-discriminatory resource allocation protects smaller players. It prevents large hyperscalers from monopolizing grid capacity or land in acceleration zones through speculative hoarding. SMEs should monitor the designation process closely to ensure they have equitable access to resources. Engaging with the single information points (established under Article 12) early can help navigate the administrative landscape.

4. Timeline Planning: With the six-month designation deadline after entry into force, Croatian authorities will move quickly. Operators should prepare their project applications in advance. The 12-month permitting cap (Article 13(5)) is a powerful tool, but it only applies if you submit a "comprehensive application." Ensure your documentation is complete to avoid delays that could push you beyond this accelerated timeline.

Common misconceptions

Misconception 1: The EU will decide exactly where the zones are. Reality: The EU sets the criteria (Article 10(1)) and the deadline for designation, but the Member State (Croatia) decides the specific geographic locations. The EU does not map out the zones itself.

Misconception 2: All data centres in Croatia will be in acceleration zones. Reality: Article 10(1) requires the designation of at least one zone where capacity is being deployed. Not all data centre projects must be located in these zones, but those that are will benefit from the accelerated permitting and specific sustainability frameworks. Projects outside these zones may face standard national permitting timelines.

Misconception 3: Acceleration zones ignore environmental concerns. Reality: On the contrary, Article 10(1)(h) and Article 11(1) impose stricter sustainability requirements. The use of KPIs from Delegated Regulation (EU) 2024/1364 ensures that accelerated deployment does not come at the cost of environmental degradation. The preference for brownfield sites (Article 10(1)(g)) further underscores this environmental focus.

Misconception 4: The "12-month permit" guarantee applies to all projects. Reality: The 12-month limit (Article 13(5)) applies specifically to data centre projects deployed in acceleration zones and only if a "comprehensive application" is submitted. Projects outside these zones, or those with incomplete applications, do not benefit from this specific cap.

Related

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