There have been major developments regarding the concept of EU cloud sovereignty in the last few years. Viewed for a long time as a technical or regulatory issue and only a topic for discussion in legal departments or amongst IT specialists, it has gradually evolved into an objective assessment criterion in European organizations’ decision-making processes. In particular, today cloud sovereignty is increasingly central to decisions concerning procurement, risk management and compliance, especially in regulated sectors and in organizations that handle large volumes of personal or critical data.
From formal compliance to structural responsibility
This change hasn’t arisen from a single regulation or a one-off regulatory deadline. Quite the opposite: it is the outcome of the cumulative pressure of multiple factors: the increase in dependence on the cloud; the growing complexity of the digital supply chain; and the aggravation of geopolitical risks.
Without a doubt, one of the decisive factors in this transformation is a European regulatory framework that places more and more responsibility on organizations.
Regulations such as DORA (in force from January 17th, 2025), the more rigorous enforcement of the NIS2 Directive and the coming into effect of the Data Act in September 2025 are all helping to reshape the way in which businesses assess their digital vendors. The focus is shifting from mainly functional or cost-based criteria to structural guarantees of control, resilience and reliability over time.
In this context, European cloud sovereignty becomes a pragmatic response to real risks, with direct implications for the organization’s responsibility.
With the spread of the cloud, the issue of sovereignty becomes central
To understand why cloud sovereignty has become a top priority for procurement and risk management, we can start from a statistical finding: according to Eurostat, in 2025 52.7% of businesses in the European Union used vendor-provided cloud computing services, an increase of more than 7 percentage points compared to 2023.
This figure clearly reveals that the cloud is no longer an experimental or secondary technology: it has become a structural component of corporate processes and a genuine basic infrastructure for most European organizations.
However, the inevitable corollary of the expansion in adoption of the cloud is greater dependence on external infrastructures and vendors. The transfer of more and more critical processes to cloud platforms goes hand-in-hand with a parallel rise in exposure to risks – technical, legal, operating and strategic.
It is in this transition that the issue of sovereignty and governance becomes crucial. The more pervasive the cloud, the greater the need to govern it becomes.
EU sovereignty as a response to legal, operating and continuity risks
In terms of procurement and risk management, European cloud sovereignty provides effective answers to multiple risks, which can be subdivided into three main categories.
- The first is legal risk. Data localization, the jurisdiction under which vendors operate and the possibility of extraterritorial access are all of crucial importance in risk assessment. It is a matter not merely of formal compliance with the GDPR but rather of being able to demonstrate effective legal control over data throughout the supply chain.
- The second is operating risk. Accidents, interruptions in service or prolonged lack of access directly impact the organization’s business continuity and reputation. Therefore, cloud infrastructures’ resilience and the ability to respond to critical events have become an integral part of risk assessment procedures.
- The third is strategic risk, linked to dependence on single vendors, vendor lock-in and the difficulty of changing architecture or provider over time. In an unstable geopolitical context, these dependences can quickly become vulnerabilities.
Reactive procedures are not sufficient for managing these risks: a proactive approach is essential. This is exactly where European cloud sovereignty comes into play, not as an alternative to the cloud but as a framework of reference for governing its adoption, coherent with the European regulatory and geopolitical context.
Data residency ≠ cloud sovereignty
One of the most common misconceptions in the debate over sovereignty is the tendency to confuse data residency with cloud sovereignty. Although connected, these two terms are not synonymous.
Data residency refers to the physical localization of data inside the European Union. It is an important requirement, but it is only one aspect of the matter. Cloud sovereignty, on the other hand, is a broader, more structured concept, which embraces:
- effective legal and jurisdictional control;
- platforms’ operating governance;
- processes’ auditability;
- the portability of data and services;
- the ability to change vendor without systemic impacts.
In other words, a service may be “EU-hosted” without really being “EU-sovereign”. This distinction is becoming more and more important in requests for proposals (RFPs) and vendor assessment processes, when organizations seek guarantees extending beyond servers’ mere geographical localization.
Procurement and risks require European-level guarantees
In the new scenario, procurement and risk management functions no longer merely verify vendors’ formal compliance. Their role is evolving to include structural assessment of digital risk.
The concept is now emerging of “EU-grade assurance”, defined as a set of guarantees relating to not only where data reside but also who exercises control, how accesses are managed, how business continuity is guaranteed and how auditability is supported over time.
The requirements of companies and institutions are moving beyond vague declarations in the direction of verifiable guarantees throughout the data chain. This also applies to the digital communication models adopted at the national and international levels, where appropriate infrastructural choices are becoming an essential factor in reliability.
The examples of some European countries have shown that the systemic digitalization of communications requires solid, scalable, governable technological foundations able to support high volumes, multiple channels and strict regulatory requirements without jeopardizing overall control.
The role of digital communication in the paradigm shift
One aspect of the cloud sovereignty debate that’s often underestimated is the role of digital communication. And yet this is where many of the risks become immediately visible. Communication with customers, the public and end users is the contact point between:
- personal data;
- regulated processes;
- external channels;
- technology providers.
When communication is fragmented across multiple systems or vendors, auditing difficulties, the likelihood of error and the risk of inconsistency all increase. Therefore, communication is being viewed more and more as a critical control area.
In the last few years, cloud sovereignty has gradually moved inside the perimeter of procurement and risk assessments because it directly affects business continuity and vendors’ regulatory responsibility. In this scenario, digital communication is the key factor able to create solid contact points between IT, businesses and end users.
Therefore, today aligning technological infrastructure and business objectives in digital communication is crucial in reducing risk and improving overall governance.
Vendor selection as a critical moment for real control
In the new cloud sovereignty paradigm we’ve just described, vendor selection constitutes the moment when sovereignty stops being an abstract principle and becomes part of real decision-making.
In fact, vendor selection is the only step in which the organization can exert effective, structural control over risk, sovereignty and compliance. Once the contract has been signed and platforms have been integrated, many constraints – technological lock-in, jurisdictional dependence, portability limits, exit complexity – are hard to remove.
To reduce these criticalities before they become unresolvable, as well as functional and SLA requirements RFPs are increasingly including questions on:
- applicable jurisdiction;
- data governance models;
- operating resilience;
- auditability;
- exit and switching strategies.
From compliance to strategic responsibility
The European regulatory framework provides the context for but does not replace organizations’ decision-making responsibility. DORA, NIS2 and the Data Act don’t impose a single “correct” architecture; rather, they require organizations to demonstrate control, resilience and the ability to manage risk throughout the digital supply chain.
Given this scenario, cloud sovereignty has acquired the status of a real organizational capability, reflected in choices of platform, governance models and communication processes. European cloud sovereignty thus becomes a selection criterion for procurement and risk management, because it directly affects legal risk, business continuity and regulatory responsibility.
Understanding the difference between data residency and cloud sovereignty, recognizing the role of digital communication and appreciating the importance of vendor selection as an opportunity for exerting real control are all fundamental in building a mature, sustainable approach.
Find out how European sovereignty is also becoming a strategic issue for customer communication. Download the TLC “European Sovereignty and the Future of Customer Communication”.
1. What do we mean by EU cloud sovereignty?
EU cloud sovereignty refers to an organization’s ability to maintain legal, operating and strategic control over its cloud data and services, in line with the European regulatory and geopolitical framework.
2. Why has cloud sovereignty become important for procurement and risk management?
Because increasing use of the cloud has amplified exposure to legal, operating and strategic risks, leading to the need for strategic assessments that extend beyond cost-based and functional considerations.
3. How does the European regulatory framework affect cloud choices?
Regulations such as DORA, NIS2 and the Data Act are requiring organizations to demonstrate control, resilience and governance throughout the supply chain, directly affecting vendor selection criteria.
4. What is the difference between data residency and cloud sovereignty?
Data residency refers to the location where data are physically stored. Cloud sovereignty is broader and also includes legal control, operating governance, auditability and portability, as well as the ability to switch provider without systemic impacts.
5. Why is digital communication a critical factor with regard to sovereignty?
Because it is the contact point between personal data, regulated processes, external channels and technology providers, where compliance, continuity and governance risks become immediately visible.
6. Why is vendor selection considered a moment when real control can be exerted?
Because it is the only step in which the organization has structural influence over risk, sovereignty and compliance. Once the vendor has been chosen, constraints such as lock-in and dependence become hard to remove.
