This analysis reconstructs the European Commission’s impact assessment for the Cloud and AI Development Act (CADA), published on 3 June 2026 as SWD(2026) 502 (Impact Assessment, Part 1 and Part 2 with Annexes).
More infrastructure can be created without automatically reducing dependence on a small number of large providers.
This is where a tension begins that runs throughout the entire document. One of the central objectives of CADA is the expansion of digital infrastructure in Europe. The rationale is straightforward. Demand for cloud and AI computing capacity is growing, while large parts of the market remain concentrated among a small number of providers and locations.
At first glance, the logic appears simple. More infrastructure should strengthen Europe’s position.
However, reading the impact assessment produces a more differentiated picture. The document devotes considerable attention to the expected capacity gap. Permitting procedures, grid bottlenecks, and infrastructure constraints are described as key obstacles to further growth. The proposed response is correspondingly clear: accelerate permitting, create fast-track areas, and facilitate investment (Part 1).
Taken together, these measures are intended to increase the computing infrastructure available within the European Union. Up to this point, the argument is relatively straightforward.
The document becomes more interesting elsewhere.
The impact assessment treats dependence as a separate problem. It repeatedly distinguishes between infrastructure located in Europe and infrastructure controlled by European providers. This distinction becomes particularly visible in the proposed sovereignty framework.
Most public-sector use cases would remain open to non-European providers, provided they meet the relevant requirements. Only the highest sovereignty tiers are effectively reserved for EU-controlled providers (Part 1).
This creates a tension that runs throughout much of the document. The mechanisms for expanding capacity are largely provider-neutral. The mechanisms for reducing dependence are provider-selective. Both objectives appear within the same policy package, but they operate through different logics.
One consequence follows from this distinction. Additional capacity can be created in Europe without automatically changing who controls the market.
The capacity gap and the dependence gap are therefore related, but they are not the same thing.
Closing one does not automatically mean closing the other.
If dependency cannot be reduced through infrastructure alone, a different question emerges. What problem is CADA actually trying to solve?
That question is the focus of Part 2.