Cloud Sovereignty for Research and Education

Research data, student records, and institutional workloads require more than "hosted in Europe." The EU Cloud Sovereignty Framework defines eight dimensions that determine whether a cloud provider is truly sovereign, from ownership and legal jurisdiction to supply chain transparency and open-source technology.

VSHN and Exoscale deliver cloud services through the GÉANT OCRE 2024 framework with a sovereignty profile that meets the highest standards defined by the EU.

Why sovereignty matters for research institutions

Most hyperscale cloud providers (AWS, Azure, Google Cloud) are US-headquartered and subject to the CLOUD Act, which allows US authorities to compel disclosure of data stored anywhere in the world, without notifying the data subject or the institution.

For research institutions handling sensitive data (clinical trials, genomics, student records, pre-publication research), this creates legal and ethical risks that "EU region" deployments do not solve. The CLOUD Act applies to the company, not the data center location.

VSHN and Exoscale are both Swiss companies. Swiss law governs all data processing, and neither company is subject to the CLOUD Act or equivalent foreign access laws.

Shortest GDPR compliance path

Switzerland holds an EU adequacy decision, which means transfers of personal data to Switzerland are treated like intra-EU transfers under GDPR. For institutions using Exoscale's Swiss or EU data centers, this eliminates the requirement for Standard Contractual Clauses (SCCs) or a Transfer Impact Assessment (TIA).

By contrast, institutions using AWS, Azure, or Google Cloud must complete a full TIA and implement SCCs because these providers are US-headquartered and subject to FISA Section 702. The GÉANT GDPR Transfer Guide for NRENs explicitly calls out this distinction: for EU/EEA-operated platforms from non-US companies, the compliance checklist reduces to verifying encryption in transit and at rest.

VSHN sovereignty self-assessment

We applied the EU's Cloud Sovereignty Framework (v1.2.1, October 2025) to our own services. This framework was used to score providers in the EU's EUR 180M sovereign cloud tender in April 2026. Three pure-European providers achieved SEAL-3, while a consortium involving Google Cloud scored only SEAL-2.

This is a self-assessment, not a formal SEAL certification. We publish it for transparency so institutions can evaluate our sovereignty profile using the same structured criteria the EU uses.

# Dimension Weight Assessment Evidence
SOV-1 Strategic 15% Strong Swiss AG, no foreign parent, all shareholders Swiss citizens (Commercial Register)
SOV-2 Legal 10% Strong Swiss law (GTC), no CLOUD Act, EU adequacy decision
SOV-3 Data & AI 10% Strong Data centers in CH/DE/AT/HR/BG with guaranteed data location. Sovereign key management via Managed OpenBao + Swiss HSM
SOV-4 Operational 15% Strong Swiss 24/7 ops, Swiss-only support option. All services on vanilla Kubernetes
SOV-5 Supply Chain 20% Strong Infrastructure-agnostic: customer chooses provider. Open-source software throughout
SOV-6 Technology 15% Strong 100% open source. VSHN contributes to K8up (CNCF), Crossplane providers, Project Syn
SOV-7 Security 10% Strong ISO 27001, ISAE 3402 Type II, Swiss SOC. FINMA-regulated customers
SOV-8 Environmental 5% Strong 90% renewable energy across Exoscale zones (100% in CH/DE/AT). Equinix + A1 Group targeting carbon neutrality by 2030. Exoscale sustainability. VSHN CSR policy

Overall: SEAL-3 equivalent, the same level achieved by the winners of the EU's own sovereignty tender. No provider worldwide achieved SEAL-4: it requires fully EU/EEA-sourced hardware supply chains and open-source foundations, structural gaps shared by every cloud provider.

Exoscale: European cloud infrastructure

Exoscale is Swiss-headquartered (part of A1 Telekom Austria Group) and operates data centers in seven European cities across Equinix and A1 Group facilities:

Zone City Facility Renewable energy
CH-DK-2 Zürich Equinix 100% (Swiss hydro)
CH-GVA-2 Geneva Equinix 100% (Swiss hydro)
DE-FRA-1 Frankfurt Equinix 100%
DE-MUC-1 Munich 100%
AT-VIE-1 Vienna Arsenal 100%
AT-VIE-2 Vienna A1 Next Generation DC 100%
HR-ZAG-1 Zagreb A1 Hrvatska DC 91%
BG-SOF-1 Sofia 75%

90% of Exoscale's electricity comes from renewable sources across all zones. Both Equinix and A1 Group target carbon neutrality by 2030. Sustainability carries 10% weight (AC8) in the GÉANT evaluation scoring, where Exoscale's renewable energy profile scored competitively. See Exoscale sustainability for details and green energy certificates.

Key sovereignty features:

Sovereignty compared: hyperscalers vs. VSHN + Exoscale

Dimension AWS / Azure / Google Cloud VSHN + Exoscale
Headquarters USA Switzerland
Governing law US law (CLOUD Act applies) Swiss law (no CLOUD Act)
GDPR compliance Requires SCCs + Transfer Impact Assessment No SCCs needed (Swiss adequacy decision)
Data location Configurable, but company subject to US jurisdiction European-only, guaranteed data location
Ownership US publicly traded Swiss AG + Austrian group
Data egress to GÉANT Standard egress charges apply 100% waived
Open source Proprietary platforms Open-source operations stack
OCRE framework Available through OCRE Available through OCRE

Request a sovereignty assessment

Concerned about data sovereignty for your research workloads? We can assess your current cloud setup against the EU framework and propose a migration path to sovereign European infrastructure.

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Request a trial voucher

Interested in using Exoscale or VSHN-managed services in your research or education institution through OCRE 2024? Tell us about your workloads and we will follow up with more information and a trial voucher.

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