Reference guide

Digital sovereignty and cloud certifications: what SecNumCloud, SEAL and CADA actually mean

Hosting your data in Europe is not enough to be sovereign. This guide untangles the three dimensions of sovereignty, the CLOUD Act risk, and the frameworks that shape the market: SecNumCloud, HDS, ISO 27001, the EU Cloud Sovereignty Framework, the SEAL levels and the CADA regulation.

Updated on October 1, 2026

"Sovereign cloud" has become a selling point, sometimes at the expense of precision. A data center in Europe does not automatically shield your data from a foreign order, and a compliance logo is not always worth the audit report that should back it. To choose with open eyes, you have to separate localisation, compliance and genuine sovereignty.

This guide sets out the definitions, maps the French and European frameworks as of 1 October 2026, and explains how to read a SEAL level or a SecNumCloud qualification. It also states plainly where Bunker and France Nuage stand: verifiable facts, not logos we do not hold.

Hosting your data in Europe is not enough: the three dimensions of sovereignty

Storing your data in the European Union is the first level of every European framework. It is necessary, but not sufficient. Sovereignty rests on three dimensions, all of which must hold.

  • Legal. Which law applies to your provider, and above all which law can compel it? A data center in Paris operated by a company subject to US law remains exposed to extraterritorial access requests.
  • Operational. Who operates, supports, updates and can cut off the service? Where are the teams, the on-call rotations, the encryption keys? Does the service survive the withdrawal of a non-European third party?
  • Technological. What is the stack made of (hardware, hypervisor, software, identity, DNS)? Is it open, auditable and substitutable, or does it depend on proprietary components controlled elsewhere?

The European Commission's Cloud Sovereignty Framework and the draft CADA regulation both use exactly this breakdown. An offer that ticks localisation alone, while leaving legal compulsion and operational control outside Europe, is not sovereign.

The extraterritorial risk: CLOUD Act, FISA and kill switch

The heart of the matter is not where the data sits, but who can demand it or cut off the service.

  • CLOUD Act (2018). It lets US authorities compel a provider subject to US law to hand over data it controls, wherever that data is stored, including a European region.
  • FISA 702 and surveillance. The US surveillance framework is behind the Court of Justice of the EU's Schrems I and II rulings. The 2023 Data Privacy Framework re-frames transfers again, but remains legally contested and politically revocable.
  • Risk of shutdown. A sanction, an embargo or a political decision can force a non-European provider to suspend a service.
  • Invisible dependencies. Even on a European cloud, identity, DNS, CDN, transactional e-mail, container registries and AI models are often American by default.

The European answer is to move past the binary yes-or-no and measure assurance levels. That is what the SEAL levels and the SecNumCloud qualification are for. For the defensive side of this exposure, see our digital resilience page and the sovereign alternative to the CLOUD Act comparison.

SecNumCloud, HDS, ISO 27001 and the European frameworks

Several frameworks coexist, with very different scopes. Some certify security, others measure sovereignty, others are regulations already in force.

FrameworkOwnerNature and value
SecNumCloud 3.2ANSSI (France)Third-party audited qualification. Demanding security plus extraterritorial immunity (capital, head office and applicable-law criteria).
HDSFrench Ministry of HealthCertification for hosting health data.
ISO/IEC 27001ISO/IECCertification of information-security management. A solid baseline, but not specific to sovereignty.
EUCSENISA (EU)Cybersecurity certification scheme, stalled since 2020. Its sovereignty criteria were dropped in 2024; not adopted to date.
Cloud Sovereignty FrameworkEuropean CommissionAssessment grid published in October 2025. Sovereignty score, eight SOV objectives, SEAL-0 to SEAL-4 levels.
CADAEuropean CommissionDraft regulation (3 June 2026). Four assurance levels, first binding on the public sector.
GDPR, Data Act, NIS2, DORAEuropean UnionRegulations and directives in force. Data protection, portability and switching, resilience, critical third-party management.

The big picture: France has a demanding but national framework, SecNumCloud, whose official list of qualified providers is authoritative on cyber.gouv.fr. Europe, for its part, failed on EUCS between 2020 and 2026, then changed method with a scoring grid (the Cloud Sovereignty Framework) and a regulation (CADA) rather than a single certification.

The SEAL levels, from 0 to 4

The SEAL levels (Sovereignty Effectiveness Assurance Levels) come from the Cloud Sovereignty Framework. They replace the yes-or-no with a scale, from fully non-European control to complete sovereignty.

LevelNameMeaning
SEAL-0No sovereigntyControl and governance entirely outside European jurisdiction.
SEAL-1Jurisdictional sovereigntyEuropean law applies formally, but its enforcement is limited and control stays non-European.
SEAL-2Data sovereigntyEuropean law applicable and enforceable; non-European hardware dependencies remain.
SEAL-3Digital resiliencePredominant European control; no non-European third party can cut off the service; non-European control marginal.
SEAL-4Complete sovereigntyFull European control, European law only, with no critical non-European dependency, down to the chips.

Where the market stands in 2026: hyperscalers present in a European region typically sit at SEAL-1 or SEAL-2; players with European capital reach SEAL-3; no one reaches SEAL-4 today, since the hardware supply chain remains largely non-European. In April 2026 the European institutions' Cloud III contract ranked its winners on this very scale, with an eligibility threshold set at SEAL-2.

CADA: a European regulation in four levels

The Cloud and AI Development Act, proposed on 3 June 2026, extends this logic as a regulation, with four assurance levels.

LevelNameMain requirements
1BaselineInfrastructure, assets and customer data within the European Union.
2EnhancedStaff, infra and assets in the EU; European cloud certification; measures blocking third-country access; full SBOM and code audit of foreign components; effective separation of non-EU subsidiaries.
3StrictEuropean ownership and control, with possible exceptions for a third country under an adequacy decision that cannot degrade the service.
4MaximalEuropean ownership and control with no exception; high-level cyber certification; effective command of the software; demonstrable absence of third-party control.

CADA first targets the public sector and EU bodies, with possible extension to essential entities under NIS2. Trilogues and then application are not expected before 2028. Nothing is yet binding on the private sector, but public tenders, banks under DORA and essential operators are already starting to ask for a SEAL level or a SecNumCloud qualification.

Localisation or sovereignty: the honest comparison

The most common confusion pits a hyperscaler present in a European region against a cloud with European capital. Both comply with the GDPR on localisation; they diverge on legal compulsion and control.

CriterionHyperscaler in an EU regionEuropean open-source cloud
Data hosted in the EUYesYes
Exposure to the CLOUD ActYes, operator subject to US lawNo
Who can cut off the serviceA non-European third party canNo non-European third party
ReversibilityLimited by proprietary servicesReal, through open source and open standards
Typical SEAL levelSEAL-1 to SEAL-2SEAL-3

This table does not say a hyperscaler is bad: its managed-services catalogue is still broader, and for non-sensitive data localisation can be enough. It says where to set the cursor when legal compulsion matters: sensitive data, public sector, health, essential operators. The right questions to ask any provider, cloud or software, stay the same: who owns the capital, where are the operations, who holds the keys, what hidden dependencies exist, what tested reversibility, and what declared level with what proof.

Where Bunker stands: facts, not logos

For the sake of honesty, here is what Bunker and France Nuage actually hold, and what remains an objective. We would rather communicate verifiable facts than display a certification logo we do not have.

  • What is acquired and verifiable. Infrastructure hosted in France, GDPR-compliant by default, reversible because built on open source and open standards (Kubernetes, S3, PostgreSQL). Gaia-X alignment. No subprocessor under US jurisdiction on the critical path, hence no exposure to the CLOUD Act.
  • What is aligned but not certified. Our information-security management system is aligned with ISO 27001, self-assessed and not third-party certified to date. The detail (security model, statement of applicability for the 93 controls) is published in our trust center.
  • What remains an objective. ISO 27001 certification is a medium-term goal, and SecNumCloud qualification a long-term one. We do not claim any ISO 27001, SecNumCloud or HDS certification today.

By design, our platform brings together several properties associated with SEAL-3: European capital and control, an open-source stack end to end, no non-European third party able to cut off the service. We do not, however, claim an audited SEAL level, which is a matter for third-party assessment. That is the distinction this guide defends throughout: ask for the audit reports, not the logos. Our compliance roadmap is detailed on the security and compliance page.

Frequently asked questions about digital sovereignty

What is a sovereign cloud?

A sovereign cloud is an infrastructure over which you keep legal, operational and technological control: the law applying to the provider is European and cannot be compelled by a foreign power, the teams and keys are in Europe, and the stack is auditable and substitutable. Hosting data in Europe is the first level, necessary but not sufficient.

Is hosting your data in Europe enough to be sovereign?

No. Localisation is the first level of every European framework, but sovereignty also requires that the law applying to the provider be European and not compellable from outside, that operations and keys stay in Europe, and that the stack be open and substitutable. A data center in Europe operated by a company subject to US law remains exposed to the CLOUD Act.

What is SecNumCloud?

SecNumCloud is the French ANSSI qualification for cloud services. It combines a deep security audit with extraterritorial-immunity criteria (majority European capital, head office and applicable law in Europe). It is France's most demanding framework, considered roughly equivalent to a third-party audited SEAL-3. The official list of qualified providers is authoritative on cyber.gouv.fr.

What is SEAL-3?

SEAL-3, called digital resilience, is the third of the five levels in the European Cloud Sovereignty Framework. It requires predominant European control, a mostly European or open-source stack, and above all that no non-European third party be able to cut off the service. In 2026 it is the level reached by players with European capital; hyperscalers in a European region sit rather at SEAL-1 or SEAL-2.

What is the CLOUD Act, in two sentences?

The CLOUD Act is a 2018 US law that lets US authorities compel a provider subject to US law to hand over data it controls, wherever that data is stored in the world. A data center in Europe changes nothing if the operator falls under US law.

Does a sovereign cloud cost more?

Not necessarily. On the compute, storage and network baseline, sovereign players' prices are historically competitive, and the Data Act removes punitive egress fees by 2027. The cost hides rather in what you must do yourself for want of an equivalent managed service, and in migration. The honest summary: sovereignty does not necessarily cost more, it asks for a little more engineering. Reason in total cost of ownership over twelve to thirty-six months, migration included.

Is Bunker certified SecNumCloud or ISO 27001?

No. We claim no ISO 27001, SecNumCloud or HDS certification today. Our information-security management system is aligned with ISO 27001, self-assessed and not third-party certified to date; ISO 27001 certification is a medium-term goal and SecNumCloud qualification a long-term one. What is acquired and verifiable: hosting in France, GDPR compliance, a reversible open-source stack and no subprocessor under US jurisdiction on the critical path. The detail is published in our trust center.

Choose with open eyes

Legal, operational and technological sovereignty: let us talk about your real need, frameworks in hand, with no logo that nobody holds.