Summary Under the proposed Cloud and AI Development Act (CADA), Slovenia is required to designate at least one data centre acceleration zone within six months of the regulation's entry into force, provided it is deploying data centre capacity. The specific geographic locations are not predetermined by EU law; instead, Slovenian national authorities must select sites based on strict criteria in Article 10, including grid capacity, connectivity, waste-heat reuse, and a preference for brownfield sites. Once designated, these zones must enforce sustainability Key Performance Indicators (KPIs) from Delegated Regulation (EU) 2024/1364 and ensure fair, non-discriminatory resource allocation under Article 11.

Detail

The Cloud and AI Development Act (CADA), as proposed in COM(2026) 502 final, introduces a mandatory framework for Member States to accelerate the deployment of data centres through the creation of "acceleration zones." For Slovenia, this represents a significant shift in how data centre infrastructure is planned, permitted, and regulated. The following section breaks down the specific obligations under Article 10 and Article 11 of the proposal, clarifying the timeline, criteria, and operational conditions.

The Obligation to Designate (Article 10)

Article 10 of the CADA proposal places a direct obligation on Member States. It states that "where data centre capacity is being deployed within the territory of a Member State, that Member State shall designate at least one data centre acceleration zone ('acceleration zone') within its territory."

For Slovenia, the timeline is strict. The regulation specifies that this designation must occur "by [P.O. insert the date of entry into force of this Regulation plus 6 months]." This means that once CADA enters into force, Slovenia has a half-year window to identify, evaluate, and officially designate these zones.

The regulation does not dictate where in Slovenia these zones must be located. Instead, it provides a detailed list of factors that Slovenian authorities must consider when designating these zones. According to Article 10(1), the following eight aspects are mandatory considerations:

  • Site Dimensions: The location, dimension, and the minimum and maximum size of the facilities that could be built on the site [Article 10(1)(a)].
  • Energy Grid Capacity: The available and future power grid capacity, and the possibility and conditions for on-site storage and clean energy generation [Article 10(1)(b)].
  • Network Connectivity: The available and future network connectivity capacity [Article 10(1)(c)].
  • Legacy Infrastructure: The capacity of the zone to support the phasing out of legacy copper networks [Article 10(1)(d)].
  • Waste Heat Reuse: The available and future facilities that can reuse data centre waste heat [Article 10(1)(e)].
  • Permitting Acceleration: All measures taken to accelerate the granting of the necessary permits for constructing and operating data centres within the given zone [Article 10(1)(f)].
  • Brownfield Preference: The preference for reusing brownfield sites over using greenfield sites [Article 10(1)(g)].
  • Sustainability: The ability of the site or area to function sustainably, particularly as regards preventing or minimising environmental impacts and supporting the reduction of carbon emissions and its climate resilience [Article 10(1)(h)].

Furthermore, Article 10(2) requires Slovenia 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 reviewed at least every three years. The results of this analysis must feed into national network development plans to ensure that grid investments are anticipatory and accommodate future system needs.

Conditions Within Acceleration Zones (Article 11)

Once designated, the acceleration zones are subject to specific operational and sustainability conditions outlined in Article 11.

Sustainability Requirements Article 11(1) mandates that when setting sustainability requirements for data centres deployed in acceleration zones, Member States "shall use the key performance indicators specified in Commission Delegated Regulation (EU) 2024/1364 pursuant to Directive (EU) 2023/1791." This links the CADA directly to existing EU energy efficiency frameworks. The KPIs from Delegated Regulation (EU) 2024/1364 cover metrics such as Power Usage Effectiveness (PUE), Water Usage Effectiveness (WUE), and carbon emissions. By referencing this delegated regulation, CADA ensures that data centres in Slovenia's acceleration zones must meet harmonized, high-level environmental standards.

Fair and Non-Discriminatory Allocation Article 11(2) addresses market fairness. It requires Member States to ensure that the allocation and use of resources within acceleration zones takes place on "fair, reasonable and non-discriminatory terms." The regulation explicitly prohibits practices that give rise to "speculative reservation or foreclosure practices capable of impeding effective competition or the effective development or use of those zones." This is crucial for preventing large incumbents from locking up land or grid capacity without deploying infrastructure, thereby ensuring that SMEs and new market entrants in Slovenia have equitable access to these strategic zones.

Strategic Context: Why Acceleration Zones?

The explanatory memorandum of the CADA highlights that the EU currently faces a significant shortage of computing capacity, with deployment lagging and concentrated in a few hubs. This creates structural imbalances, higher costs, and increased latency for peripheral regions. By mandating acceleration zones, the EU aims to:

  1. Streamline Permitting: While Article 10 sets the designation criteria, Article 13 (which applies to projects in these zones) allows for an "aggregated baseline permit" for the zone. This permit covers common permits and excludes only installation-specific ones, drastically reducing the administrative burden for operators. The permit-granting procedure for data centre projects in these zones shall not exceed 12 months.
  2. Balance Geography: Encouraging deployment in underserved areas to reduce latency and improve resilience across the Union.
  3. Ensure Sustainability: Linking deployment to strict energy efficiency KPIs to align with the EU's green transition goals.

For Slovenia, this means that the government will likely prioritize sites that can integrate with existing energy grids, offer waste heat reuse opportunities (such as near urban heating networks), and utilize brownfield sites to minimize environmental impact.

What this means for you

For CTOs, architects, data centre operators, and SMEs evaluating the practical impact of CADA in Slovenia, the designation of acceleration zones presents both opportunities and constraints.

1. Site Selection Strategy If you are planning to build or expand data centre capacity in Slovenia, you must closely monitor the Slovenian government's upcoming designation of acceleration zones. Once designated, these zones will offer streamlined permitting processes (via aggregated baseline permits) and potentially faster grid connections. However, you must ensure your project aligns with the sustainability KPIs from Delegated Regulation (EU) 2024/1364. Projects that fail to meet these energy efficiency standards may face delays or rejection.

2. Brownfield Opportunities Article 10(1)(g) explicitly favors brownfield sites. If you have expertise in repurposing industrial or commercial land, this could be a competitive advantage. The EU's preference for brownfield redevelopment aims to reduce the environmental footprint of data centres. Architects and developers should look for underutilized industrial sites in Slovenia that have existing grid and network infrastructure.

3. Grid and Connectivity Planning Article 10(1)(b) and (c) highlight the importance of grid capacity and network connectivity. Operators should engage early with Slovenian transmission and distribution system operators to understand future grid capacity plans. The requirement for anticipatory grid investments means that projects in acceleration zones may benefit from prioritized grid connections, but only if they align with the national network development plans.

4. Market Access and Competition Article 11(2)'s prohibition on speculative reservation is a positive signal for SMEs. It prevents large players from hoarding resources without deploying them. This ensures that smaller providers have a fair chance to access land and grid capacity in acceleration zones. However, it also means that operators must demonstrate serious intent and capability to deploy quickly, as "shelf-warming" sites will not be tolerated.

5. Waste Heat Integration Article 10(1)(e) requires consideration of waste heat reuse. This is particularly relevant in urban or semi-urban areas where district heating networks exist. Integrating waste heat recovery systems can not only help meet sustainability KPIs but also create additional revenue streams and community goodwill. Architects should design data centres with heat export capabilities in mind from the outset.

Common misconceptions

Misconception 1: CADA designates specific locations in Slovenia. Reality: CADA does not name specific cities or regions in Slovenia as acceleration zones. It sets the criteria and obligation for the Slovenian government to designate them. The actual locations will be determined by national authorities based on the factors in Article 10(1).

Misconception 2: Acceleration zones apply to all data centres in Slovenia. Reality: The specific streamlined permitting and sustainability conditions under Articles 10 and 11 apply only to data centres deployed within designated acceleration zones. Data centres outside these zones may still operate but will not benefit from the aggregated baseline permits or the specific grid prioritization mechanisms tied to the zones.

Misconception 3: Sustainability KPIs are optional guidelines. Reality: Article 11(1) states that Member States shall use the KPIs from Delegated Regulation (EU) 2024/1364. This makes them mandatory requirements for data centres in acceleration zones. Non-compliance could result in permit denial or operational restrictions.

Misconception 4: Brownfield sites are the only option. Reality: While Article 10(1)(g) expresses a preference for brownfield sites, it does not explicitly ban greenfield development. However, given the EU's emphasis on sustainability and the explicit preference, greenfield projects will likely face higher scrutiny and must demonstrate exceptional sustainability credentials to be competitive.

Related

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