Summary Under the proposed Cloud and AI Development Act (CADA), the European Commission establishes, operates, and administers the technical platform and governance framework for the EuroCloud Federation. However, the actual cloud and data centre services are provided exclusively by public sector bodies (Union entities and Member State public bodies) acting as "sharing entities." The system is designed to be self-sustaining, funded by fees levied on the member public authorities to cover the Commission's administrative and operational costs, rather than by the general EU budget alone.

Detail

The EuroCloud Federation represents a distinct shift in how the EU approaches public-sector cloud capacity. Rather than creating a new centralised cloud provider owned by the EU, the proposal establishes a federation mechanism where the Commission acts as the facilitator and the public sector acts as the resource provider. The division of responsibilities is clearly delineated in Title IV, Chapter III of the CADA proposal (COM(2026) 502 final).

The Commission's Role: Platform Operator and Administrator

The European Commission holds the central operational role for the federation's infrastructure and governance. Article 34(3) explicitly mandates that the Commission shall establish a platform for the EuroCloud Federation. This platform is not merely a directory; it serves two critical functions:

  1. A catalogue providing information on available public sector data centre services and cloud computing services.
  2. A service platform for the exchange and orchestration of computing, storage, and network resources and services.

Beyond the technical setup, the Commission acts as the administrator. Article 36 establishes that the costs arising from the Commission's activities under this chapter shall be jointly financed by the members through fees. The Commission is empowered to adopt implementing acts to specify the detailed rules for determining these fees, the manner of payment, and the technical, operational, and organisational measures required for the sharing of services. This confirms that the Commission is the entity responsible for the "plumbing" of the federation, ensuring that the mechanism for sharing capacity is secure, interoperable, and compliant with Union law.

The Members' Role: Providing and Consuming Services

While the Commission runs the platform, the resources come entirely from the public sector. Article 34(1) states that the EuroCloud Federation is open for the participation of Union entities and public sector bodies on a voluntary basis. Private parties are explicitly excluded from direct participation as members or providers.

The operational dynamic is defined by the relationship between a "sharing entity" and a "using entity" under Article 35:

  • The Sharing Entity: This is a public body that directly, or indirectly through an intermediate legal entity, owns the hardware and provides the service. Before sharing can occur, the sharing entity must demonstrate to the Commission that it has put in place appropriate technical, operational, and organisational measures (such as risk analysis, security policies, and incident handling) to ensure effective, secure, and resilient provision of services.
  • The Using Entity: This is another public body that accesses the shared capacity.

The sharing entity is responsible for the actual delivery of the service. The Commission assesses the sharing entity's compliance with the required measures and, upon a positive assessment, allows the entity to share services within the federation. This ensures that while the Commission manages the system, the public bodies retain responsibility for the service quality and security of their specific contributions.

Funding and Governance Structure

The proposal ensures the federation is financially independent of the general EU budget for its ongoing operations. Article 36(1) mandates that the costs arising from the Commission's activities (including the establishment of the platform and the assessment of membership applications) shall be jointly financed by the members through fees levied by the Commission.

If the initial establishment costs are borne by the general budget of the Union, Article 36(2) requires that they be reimbursed by the EuroCloud members over a period not exceeding three years. The revenues generated by these fees constitute internal assigned revenues, which are assigned to cover the specific costs of the federation's activities.

Governance is further reinforced by the Commission's power to adopt implementing acts regarding the procedure to participate in the federation and the templates for participation requests. This centralised administrative control ensures a uniform approach across all Member States, preventing fragmentation and ensuring that the federation operates as a single, coherent Union-wide mechanism.

What this means for you

For public-sector IT directors, procurement officers, and national cloud coordinators, the "who runs what" distinction under CADA has practical implications for strategy and budgeting.

  • You are the resource owner, not the platform builder. If your authority has idle capacity, you are the "sharing entity." You do not need to build a new marketplace; the Commission will provide the platform. Your primary obligation is to ensure your infrastructure meets the Commission's security and resilience standards and to demonstrate this compliance to the Commission before listing your services.
  • You access a unified market. If you need capacity, you will not negotiate bilateral deals with every potential provider. Instead, you will access the Commission's platform to find and orchestrate resources from other public bodies. This streamlines the process of finding sovereign, EU-based capacity.
  • Budget for administrative fees, not service costs. Your budget planning must account for the fees levied by the Commission to cover the federation's administration. These are distinct from the costs of the cloud services themselves. Under Article 35(5), any charges between public bodies for the actual sharing of capacity are strictly limited to cost recovery (e.g., isolating resources) and do not constitute a commercial transaction or a public contract, meaning they bypass standard procurement procedures.
  • Compliance is a prerequisite for participation. You cannot simply "join" the federation. You must proactively demonstrate that you have the necessary technical and organisational measures in place. The Commission acts as the gatekeeper, assessing your readiness before allowing you to share or use services.

Common misconceptions

"The Commission provides the cloud computing services." No. The Commission provides the platform and the administrative framework. It does not own the servers, data centres, or cloud infrastructure. The actual services are provided by Union entities and public sector bodies that volunteer their capacity.

"EuroCloud is a commercial cloud provider." No. It is a public-sector cooperation mechanism. Private companies cannot join as members or provide services directly to the federation. While private vendors may supply the hardware to the public bodies, the sharing relationship is strictly between public entities.

"Participation is free." While the exchange of capacity between public bodies is not a commercial sale, participation in the federation is not free of charge. Members must pay fees to the Commission to cover the costs of establishing and running the platform and the administrative assessment of members. These fees are mandatory for those wishing to participate.

Related

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