A Thesis

Europe's regulatory spine has stiffened (DORA, NIS2, eIDAS 2.0, Data Act). Its infrastructure is still exposed (foreign concentration, seabed fragility, extraterritorial laws). Independence is not a slogan—it's a capability: the ability to deliver lawful, reliable services regardless of outside pressure. In 2025, that capability is both feasible and economically rational.

---

1. The Resilience Dividend

Regulatory Readiness as Operational Advantage

DORA's uniform rules reduce supervisory fragmentation and force disciplined vendor management. NIS2 extends resilience across broader sectors and their supply chains. The Data Act breaks lock-in. These raise the floor for everyone and reward the prepared.

Subsea Reality

The Red Sea cable cuts (2024) and repeated incidents in the Baltic demonstrate Europe's geographic exposure to chokepoints. The EU's 2025 Action Plan on Submarine Cable Security codifies this as a strategic problem. Independence starts with the humility to assume links will break.

---

2. Strategic Autonomy ≠ Autarky

"Open Strategic Autonomy" is the EU's own framing: preserve openness while reducing critical dependencies. That means Europe remains in global markets but designs for exit from any single jurisdiction or supplier.

Cloud is the emblematic case: US hyperscalers hold about 70% of the European market; European providers sit near 15%. Policies like DMA investigations into cloud gatekeepers, plus sovereignty programs from the hyperscalers themselves, reflect this shift.

Sovereignty Features Aren't Political Decoration

AWS's European Sovereign Cloud and Microsoft's EU Data Boundary materially change where control-planes, metadata, and AI processing happen. Done well, they shrink the legal blast radius of the CLOUD Act and similar laws. Done poorly, they are marketing. Demand evidence.

---

3. Law as Leverage

DORA raises vendor governance across finance; expect spillover as "good practice" elsewhere. NIS2 turns cybersecurity and supply-chain assurance into board issues. Data Act makes portability and fair cloud switching a right, not a favor. Build products assuming customers will use it. DMA scrutiny of cloud "gatekeepers" signals willingness to reshape market power in foundational infrastructure. eIDAS 2.0 standardizes trust and identity; wallets enable cross-border services without exporting data unnecessarily.

Independence is enforceable because the legal regime aligns with technical feasibility.

---

4. AI, Contamination, and the New Commons

AI systems amplify both value and risk. Two truths can coexist:

  • OWASP's LLM Top-10 codifies the new failure modes (prompt injection, model abuse, data leakage). Ignore it and you'll ship vulnerabilities with a prose interface.
  • 2024–2025 research shows poisoning threats scaling with dataset size and openness. You need provenance, signatures, and sovereign training corpora for high-stakes use.

A Europe that curates lawful, high-integrity datasets—medical, industrial, legal, scientific—gains a compounding advantage: safer models that are actually deployable under EU law.

---

5. Scenarios You Should Actually Plan For

Scenario A – Grey-Rhino (Weekly Pain)

A third-party SaaS you rely on rolls out a new AI feature that routes prompts to a US region by default. Your DPO flags a policy breach. You need controls to pin processing to EU or to block the feature for regulated users. Microsoft and others keep evolving EU processing commitments—track and verify.

Scenario B – Red-Sea Redux (Quarterly Pain)

Cable damage degrades Europe–Asia capacity; your East-of-Suez suppliers crawl. Your edge caches save you; your write-queues prevent data loss; you re-route to northern paths and keep gold journeys live. (The last two years' incidents show this is neither rare nor purely accidental.)

Scenario C – Legal Shock (Annual Pain)

A court trims the scope of a data-transfer mechanism, or a regulator tightens AI processing rules. Because you adopted a sovereign plane and split keys, the impact is a configuration change—not a rewrite.

Scenario D – Adversarial AI (Surprise Pain)

You discover poisoning in a supplier model. You can roll back to a signed training snapshot and re-attest TEEs before releasing decryption keys for retraining. (This is why you built runtime attestation gates.)

---

6. Economics: Independence That Pays for Itself

Resilience looks like cost until something breaks. Then it looks like continuity revenue.

Data Act switching alone pressures vendors to compete on performance and openness. DORA/NIS2 bring internal discipline that reduces mean-time-to-recovery and cyber losses. Subsea fragility argues for edge execution and content locality, which also reduces latency bills.

The business case is positive under mild assumptions once you price downtime realistically.

---

7. Governance: Independence is a Board-Level, Measurable Capability

Create a Digital Independence Scorecard:

Legal Posture: Documented Data Act switching runbook; DPF alternative ready; contracts with termination assistance. Technical Posture: Sovereign plane operational; TEEs active for sensitive workloads; keys EU-resident; edge degradation tested. Operational Posture: Partition drills; TLPT; cross-provider failovers; AI red-team exercises.

Report quarterly to the risk committee.

---

8. Where to Be Bold (Without Being Reckless)

Adopt Sovereign Features Early—But Verify

AWS's EU sovereign offering and Microsoft's EU Data Boundary are material improvements; build proofs and retain artifacts.

Invest in Confidential Computing

Not just for "secret sauce"—use it for key release policies tied to attestation. That shrinks your blast radius regardless of legal jurisdiction.

Curate European Datasets

Future AI competitiveness relies on lawful, provenance-rich corpora.

---

9. What Not to Do

Don't confuse data residency with sovereignty; metadata and control planes matter just as much. (Check where logs, IAM, billing, telemetry live.) Don't over-rotate to a single niche EU provider; you're trading one concentration for another. Blend. Don't ship AI to production without OWASP LLM controls; you're gifting yourself a new attack surface.

---

10. The Strategic Arc

The EU's Open Strategic Autonomy agenda is now grounded in deployable tech and enforceable law. Independence is earned by teams who can prove they can fail over, switch out, degrade gracefully, and stay lawful when the network gets noisy and the laws get louder.

Organizations that operationalize this will ship faster, negotiate better, and sleep more. The rest will keep discovering sovereignty one incident at a time.

---

The Geopolitical Reality

Digital sovereignty isn't about rejecting globalization—it's about participating from a position of strength. When your infrastructure can survive cable cuts, your data can't be weaponized by foreign courts, and your AI models train on provenance-tracked European datasets, you operate from choice, not dependency.

The regulatory framework exists. The technology is proven. The economics work. What remains is execution: building systems that serve European law, European customers, and European strategic interests—not as an accident of vendor choice, but as an architectural principle.

This is the path to a digitally sovereign Europe: one that innovates globally but can operate autonomously when the stakes demand it.

---

Selected Sources

  • DORA applies from Jan 17, 2025 (European Commission)
  • NIS2 obligations and scope (European Commission)
  • Data Act application date Sep 12, 2025 (European Commission)
  • EU-US Data Privacy Framework upheld (CJEU Press)
  • AWS European Sovereign Cloud launch and properties
  • Microsoft EU Data Boundary completion (Feb 26, 2025)
  • Subsea cable risks & EU Action Plan (Council conclusions / 2025)
  • Red Sea/Baltic incidents (AP; analysis pieces)
  • European cloud market concentration (Synergy summaries)
  • OWASP Top-10 for LLMs / GenAI Security Project
  • Confidential computing references (AWS, Azure, GCP)
  • eIDAS 2.0 regulation and 2025 implementing acts
  • DMA gatekeeper status and cloud investigations