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Quick take on CADA
The big picture
Q1. Does CADA, as drafted, make Europe more sovereign? Score it on each dimension (one tick per row).
Protection from foreign influence
1
2
3
4
5
Strongly weakens
No real effect
Strongly improves
Technology & infrastructure resilience
(security)
1
2
3
4
5
Strongly weakens
No real effect
Strongly improves
Competitiveness
(for technology users)
1
2
3
4
5
Strongly weakens
No real effect
Strongly improves
Q4. Will CADA be a real enabler of tripling EU data-centre capacity?
Strong enabler, it materially helps triple capacity
Helps, but only alongside other factors (grid, power, capital)
Marginal, largely a drop in the ocean
No real effect on capacity
Other (please specify)
Market reality
Q5. Of cloud providers serving the EU public sector today, how many could already meet each level as drafted?
Most
Some
Only a few
None today
Don't
know
Level 1
Level 2
Level 3
Level 4
Q6. Under the current draft, what share of existing public-sector cloud procurement would need to be ported or re-tendered over the next 3–5 years?
~1% (Level 4 only)
~10% (Levels 3&4)
~30% (Levels 2-4)
~100% (Levels 1-4)
Don't know
Other (please specify)
Level 4: ownership and exceptions
Q7. Level 4: what should be DIGITALEUROPE's position?
Accept the EU-ownership requirement as proposed
Rewrite Level 4 as control-based (no third-country control or interference, EU-controlled operations, auditable supply-chain control), with no ownership test
Delete Level 4 and make Level 3 the highest tier
Other (please specify)
Q8. Should there be an adequacy/mitigation route at Level 4 for trusted allies?
No, Level 4 should be closed (no route for third-country-controlled providers)
Yes, include a clear mitigation/adequacy route (extend Art 18 logic to Level 4)
Should be expended to NATO / close allied countries
Other (please specify)
Procurement
Q9. What should we push for on joint procurement and the EuroCloud Federation?
A budgeted EU instrument (committed MFF line + central purchasing vehicle)
A budgeted instrument, with opt-in participation for Member States
Voluntary opt-in only (no dedicated budget)
Other (please specify)
Governance
Q10. Should we accept the fragmented Member State assessment process, or push for more centralised/coordinated Commission designation?
Accept Member State-led assessment as drafted
Push for a coordinated EU methodology, with Member States still deciding
Push for centralised Commission designation (single EU classification scheme)
Other (please specify)
Q11. Should there be a binding, harmonised risk-assessment methodology (delegated act) that all Member States must apply?
Yes
No
Don't know
Priorities
Q12. Which items are most important for DIGITALEUROPE to exert influence over in CADA?
Please chose up to three (3) items.
Remove the EU-ownership requirement at Level 4 (rewrite to control-based)
Keep an adequacy/mitigation route at Level 4 for trusted allies
Closed-list scoping of Level 4 use cases
Bidirectional Commission power to cap over-classification (Art 29(5))
Harmonised risk-assessment methodology across Member States
No extension to private critical infrastructure via implementing act
Budgeted joint procurement / federation instruments
Grid-connection fast-track and deadlines
Nothing, don't touch the act
Other
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