European Digital Sovereignty (part 1)

Digital sovereignty may sound like an abstract concept to many organizations. Yet it touches on classic boardroom themes such as continuity, risk management, costs, customer trust and strategic agility. The EU is accelerating this with new legislation, stricter security requirements and growing dependence on major technology platforms.

In this first blog of a three‑part series, we explain:

• what European digital sovereignty is (and is not),
• why the topic has become so urgent,
• and which concrete questions and actions leadership teams can start with today.

This article is intended for directors, management teams and board members who want to gain control over digital dependencies and make future‑proof decisions.

1) What do we mean by European digital sovereignty?

A practical, business‑focused definition:

“The ability to make independent decisions about digital assets (data, systems, suppliers) without unwanted dependencies, while remaining open to international collaboration.”

So it is not about “keeping everything within Europe,” but about control: consciously managing risks, dependencies and ownership of your critical data and systems.

The European approach is broad and spans several domains:

• Rights & trust – who can do what with your data?
• Market functioning & competition – how do you prevent lock‑in?
• Secure infrastructure & data – is your digital landscape resilient?
• Governance – can you demonstrate that you are in control?

In short: digital sovereignty is about control. Control over your data. Control over your suppliers. Control over your digital continuity.

2) Why is this now high on the agenda?

There are three developments that greatly increase urgency.

a) Dependencies have become very real

Many organizations run on a small number of major cloud services and platforms. That works efficiently—until something changes:

• pricing models
• contract terms
• geopolitical pressure
• supply conditions

The conversation shifts from: “Does it work?” to “Can we continue operating under all circumstances?”

b) EU legislation makes “control” mandatory

New European regulations raise the bar for governance, supply‑chain security and data access.
Key examples include:

• NIS2 – requires organizations to demonstrate cyber‑risk management and supply‑chain responsibility.
  
  
• Data Act – introduces rules for fair access to and use of data, and includes provisions to make switching cloud/data‑processing providers easier to reduce lock‑in.
  
  
• DSA/DMA – part of the EU’s digital services package to make the digital ecosystem safer and the market fairer/more competitive, relevant because platform dependencies and market power directly affect the organizations that use them.

These laws don’t require leadership teams to know every detail, but they do require them to have control over choices, risks and dependencies.

c) “Demonstrably secure” is becoming a market requirement

Customers, partners and regulators increasingly demand proof:

• can you demonstrate that your security and governance are in order?
• can you show that supply‑chain risks are under control?

Digital sovereignty is therefore not only a compliance issue, but also a trust issue.

3) The core for leadership teams: decide where you need control

Which digital components are so important that you must retain direct control?

Consider questions such as:

• Critical processes: what must never suffer long outages (production, planning, customer portals)?
• Critical data: which data affects customer trust, competitive advantage or compliance (customer data, intellectual property, personal data)?
• Critical dependencies: which supplier is a single point of failure? And could you switch if needed?

A concrete example: What happens if your main cloud provider changes its terms tomorrow? Can you still deliver, stay compliant and protect your customers?

4) Five questions you can ask today

These questions give immediate insight into your current risks:

1. Continuity: If our main digital supplier changes its terms tomorrow, which processes are at risk?
2. Freedom of choice: Do we have a credible, executable exit strategy for our most important cloud services?
3. Supply‑chain responsibility: Do we know which suppliers contribute to our security, and can we demonstrate that their risks are under control (as required by NIS2)?
4. Data control: Who has access to our most sensitive data, and under which jurisdictions does that fall?
5. Demonstrability: Can we show customers, partners and regulators that our security and governance processes are in order?

No clear answer? That’s not a failure, but a sign that digital sovereignty needs more attention.

5) Three practical steps to get started

You don’t need a large program. Start with three accessible steps:

Step 1 — Make dependencies visible (1–2 sessions)

Map out your:

• top‑5 critical processes
• top‑5 critical systems
• top‑5 suppliers

Step 2 — Define what is “critical” and set minimum requirements

Document your minimum requirements for:

• continuity
• data access and privacy
• incident response
• supply‑chain agreements

These requirements align well with the direction of NIS2.

Step 3 — Embed it in governance and contracts

Make control a standard part of decision‑making:

• exit options
• audit and reporting agreements
• responsibilities across the supply chain