When sovereignty comes up on the agenda

In our conversations, it rarely starts with the concept of a sovereign cloud. It starts with one of these triggers.

01

Your customer demands it


Software vendors that serve government and healthcare customers face requirements on data location and jurisdiction in tenders.

More for software vendors

02

NIS2 or DORA


The regulator wants to know which suppliers you rely on. DORA requires an exit strategy for critical ICT services that you can actually execute.

03

A renewal or a price increase


The contract is expiring, and the bill is going up. Starting 12 January 2027, cloud providers will no longer be allowed to charge switching fees.

04

AI on sensitive data


You want to run models on customer or design data that cannot be stored with a U.S. provider.

05

Failover


A failover environment at the same provider doesn't help if that provider itself goes down.

Sovereign cloud

Sovereign cloud and digital sovereignty

A sovereign cloud is a cloud environment in which you determine where your data is stored, who holds the keys, who manages it, and which laws govern it.

A European region of a U.S. provider only handles the first part. The CLOUD Act can require such a provider to disclose data, even if it is located in Europe.

Digital sovereignty is a broader concept. It also involves your software, your identity management, and the knowledge within your team: can you take those with you when you switch?

When staying is the better choice

For many workloads, an EU region with your own keys and a tested exit plan is sufficient. Moving away takes time; you give up managed services, and your team will have to learn a new platform. If the risk doesn’t justify that, we advise staying and preparing the exit. The roadmap then says so.

Where vendor lock-in occurs

Vendor lock-in rarely occurs at the server level. It occurs in the layers above it. Operating completely independently of providers is expensive, so decide for each layer which dependencies you’re willing to accept and write down how you would get out.

01

Managed cloud services


Where you're stuck: proprietary databases, serverless functions, AI services, and message queues from a single provider. Switching: difficult. What helps: making informed choices for each service, and opting for open-source alternatives when the service isn't worth it.

02

Identity


Where you're stuck: permissions and roles in AWS IAM or Microsoft Entra ID, linked to all other services. Switching: difficult. What helps: designing identity management separately from the workload and defining roles as code.

03

Data


Where you're stuck: large datasets and the costs of transferring them out (egress). Switching: moderate to difficult. What helps: open formats, testing the export annually. The Data Act limits switching charges.

04

Infrastructure


Where you're stuck: templates that only work with a single provider. Kubernetes also locks you in, through storage classes, load balancers, and its integration with IAM. Switching: moderate. What helps: Infrastructure as Code with provider-agnostic tooling.

05

Knowledge and contracts


Where you're stuck: a team that only knows one provider, and a multi-year purchase commitment. Switching: moderate. What helps: an exit plan that outlines the steps and costs, and a contract term that aligns with that plan.

What an exit plan includes

Four routes to a sovereign cloud

You don’t have to choose just one route. Most organizations end up with a mix: sensitive data closer to home, and the rest with a hyperscaler. SUE carries out migrations using all four routes. To find out which European providers are available and what they offer, read “Saying Goodbye to the Big 3: Why European Cloud Providers Are a Serious Alternative.”

01

An EU region of AWS, Azure, or Google Cloud, with your own keys


Applies when data must be stored in the EU, but a foreign jurisdiction is not strictly prohibited. You give up no services. The CLOUD Act risk remains, but using your own keys mitigates it. Remaining lock-in: high, but manageable with an exit plan.

02

A hyperscaler's sovereign cloud


For example, the AWS European Sovereign Cloud. It’s a good fit if you want the services of a hyperscaler, managed by EU residents. You give up services and regions, and new features arrive later. It’s a separate environment: you migrate to it. The resulting lock-in is high.

03

European provider


Such as STACKIT, OVHcloud, Scaleway, IONOS, or Leaseweb. Suitable if a European jurisdiction is required and your workloads are standard: VMs, Kubernetes, object storage. You give up managed services and do more yourself. Remaining lock-in: low to moderate.

04

Your own or a private cloud


On OpenStack, Apache CloudStack, or Kubernetes. A good fit if you want full control or have heavy workloads with predictable load. You sacrifice elasticity and are responsible for hardware and operations, either yourself or through a managed services partner. Remaining lock-in: low.

Rules

What the rules require

Have your legal counsel or privacy officer review the legal assessment.

  • CLOUD Act. A U.S. provider may be required to disclose data, even if it is located in a European region.
  • Data Act. Applies to cloud services since 12 September 2025. The notice period for a switch is at most two months, and the transition takes at most thirty days. As of 12 January 2027, cloud providers may no longer charge switching fees.
  • NIS2. You are responsible for the risks associated with your suppliers, including your cloud provider.
  • DORA. As of 17 January 2025, financial institutions must have an exit strategy for critical third-party IT services.

You can read more about the rules in the Cloud Migration guide and the cloud security guide.

How SUE works


SUE is a partner of AWS, Microsoft Azure, and Google Cloud, as well as Red Hat and SUSE. We also handle migrations to European providers. That is precisely why we document the trade-offs for each workload in the assessment, so you can evaluate them yourself.

SUE focuses on infrastructure, platforms, and applications, not on the workplace: we are not the right partner for Microsoft 365, email, and collaboration.

01

Free Data Sovereignty Assessment


In just one week, you'll know, for each data domain, where your data is located, which laws it is subject to, and where you are locked in.

More about the assessment

02

A choice per workload


For each workload, a route and an exit plan with the order and cost of a switch.

03

Migration in waves


We migrate in waves, so you can test each step before the next one begins.

More about Cloud Migration

04

Management


We then manage the platform, also at a European provider or on your own infrastructure.

More about Managed Kubernetes

In practice

This is how SUE handled it at NXP and SIDN.

About SUE

Modernize the code. Optimize the cloud. Run the platform.

SUE is a Dutch cloud native solutions partner that modernizes mission-critical applications, reduces cloud costs, and manages your platform. Specialists in Linux, Kubernetes, and the cloud.

More about SUEView Our Approach

29+

Years Experience

150+

Engineers and consultants

1.150+

Certifications

ISO

9001 & 27001

500+

Projects

75+

Research papers

Frequently asked questions

All frequently asked questions
A cloud environment where you decide where your data is stored, who holds the keys, who manages it, and which laws govern it. This could be an EU region of a hyperscaler with your own keys, a hyperscaler’s sovereign cloud, a European provider, or your own infrastructure. SUE selects which of these four options is best suited for each workload.
Especially in managed services and identity: proprietary databases, serverless functions, and permissions in IAM or Entra ID. Data and contracts come next. Operating completely independently of providers is expensive. SUE defines, layer by layer, which dependencies you accept and how you get out.
Usually not for everything. Many workloads can remain in an EU region, with encryption where you manage the keys and a tested exit plan. For the most sensitive data, choose a sovereign cloud, a European provider, or your own infrastructure. The Data Sovereignty Assessment shows what’s appropriate for each data domain.
As of 12 September 2025, the notice period is limited to a maximum of two months, and the transition period is limited to a maximum of thirty days. Starting 12 January 2027, cloud providers will no longer be allowed to charge switching fees. The law does not address the technical aspects of the switch; for that, you’ll need an exit plan.
That depends on how many managed services you use, how much data you transfer, and whether your applications need to be modified. A workload running on VMs or Kubernetes is relatively easy to migrate. An application that relies on services from a single provider requires modification. The Data Sovereignty Assessment provides an estimate for each workload.
SUE is a Dutch cloud partner based in Geldermalsen that has been active in the infrastructure sector since 1997. SUE migrates to AWS, Azure, and Google Cloud; to European providers such as STACKIT, OVHcloud, and Leaseweb; and to your own infrastructure on OpenStack or Apache CloudStack, and subsequently manages those environments.
No. SUE focuses on infrastructure, platforms, and applications. For a sovereign workplace, email, and collaboration tools, you should look for a specialized provider.

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Jonah Sanderse
Jonah Sanderse

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