Table of Contents
Abstract#
The EU Cloud Sovereignty Framework provides a structured approach to assess and improve digital sovereignty when using cloud services.
Summary#
A comprehensive methodology developed by the European Commission to help organizations assess their digital sovereignty posture across eight dimensions: Strategic, Legal, Data, Operational, Supply Chain, Technology, Security, and Environmental sovereignty. This framework forms the foundation for the Norwegian Digital Sovereignty Index (NDSI).
Why Cloud Sovereignty Matters#
European organizations face increasing pressure to maintain control over their digital infrastructure and data. Key drivers include:
- Regulatory compliance - GDPR, NIS2, and sector-specific regulations
- Geopolitical risks - Dependency on non-EU technology providers
- Data protection - Ensuring data remains under European jurisdiction
- Operational resilience - Reducing single points of failure
The Eight Dimensions#
The EU framework evaluates cloud sovereignty across eight dimensions:
SOV-1: Strategic Sovereignty#
Assesses the strategic alignment and control over cloud services, including vendor independence and long-term viability.
Key questions:
- Where is the vendor headquartered?
- What is the ownership structure?
- How dependent is your organization on this single vendor?
SOV-2: Legal Sovereignty#
Evaluates the legal framework governing data access and protection, particularly regarding foreign jurisdiction claims.
Key questions:
- Is the vendor subject to the US CLOUD Act?
- Does the vendor comply with GDPR?
- Can foreign authorities compel data disclosure?
SOV-3: Data Sovereignty#
Measures control over data location, processing, and access.
Key questions:
- Where is data stored and processed?
- Can you choose data residency?
- Who has access to your data?
SOV-4: Operational Sovereignty#
Assesses operational control and the ability to manage and migrate services.
Key questions:
- Can you self-host the solution?
- What export options exist?
- How complex is migration to alternatives?
SOV-5: Supply Chain Sovereignty#
Evaluates dependencies on third-party components and infrastructure.
Key questions:
- What are the key infrastructure dependencies?
- Are there European alternatives for critical components?
- How transparent is the supply chain?
SOV-6: Technology Sovereignty#
Measures control over underlying technology, including open source availability and interoperability.
Key questions:
- Is the source code available?
- Does it use open standards?
- Can you modify or extend the solution?
SOV-7: Security Sovereignty#
Assesses security controls and the ability to implement organization-specific security measures.
Key questions:
- What certifications does the vendor hold?
- Can you use your own encryption keys?
- What security controls can you configure?
SOV-8: Environmental Sovereignty#
Evaluates environmental sustainability and alignment with European climate goals.
Key questions:
- What is the carbon footprint?
- Does the vendor use renewable energy?
- Is there transparency in environmental reporting?
Scoring Methodology#
Each dimension is scored on a scale of 1-5:
| Score | Risk Level | Description |
|---|---|---|
| 1.0-1.5 | Low | Full sovereignty control |
| 1.5-2.5 | Moderate | Acceptable with mitigations |
| 2.5-3.5 | Elevated | Significant concerns |
| 3.5-4.5 | High | Major sovereignty gaps |
| 4.5-5.0 | Critical | Unacceptable for sensitive use |
The overall score is a weighted average, with SOV-2 (Legal) often serving as a “gate” - if legal sovereignty fails, the overall assessment is flagged regardless of other scores.
Applying the Framework#
For Organizations#
- Inventory your software - List all cloud services in use
- Assess each service - Use the eight dimensions
- Identify risks - Focus on high-scoring (risky) areas
- Plan mitigations - Implement controls where possible
- Consider alternatives - Evaluate European alternatives for high-risk services
For Procurement#
When evaluating new software:
- Include sovereignty requirements in RFPs
- Weight sovereignty alongside price and features
- Consider total cost including migration risk
- Prefer vendors with clear European commitment
Norwegian Context#
For Norwegian organizations, additional considerations apply:
- Schrems II implications - US-EU data transfers remain problematic
- National security - Critical infrastructure has stricter requirements
- Sector regulations - Finance, health, and government have specific rules
- Nordic alternatives - Consider Norwegian and Nordic vendors first