Standard · Levels

Four levels. A hierarchy of trust.

From the opaque black box to structural sovereignty — a graduated scale with clear minimum requirements per domain.

L0 — Opaque black box§

No verifiable transparency. Structurally unsuitable for sovereignty-critical workloads.

L0 means that none of the assessment domains reaches the transparency required for sovereignty. Ownership, jurisdiction, sub-contractors and technical architecture are neither documented nor independently auditable. Operational levers lie beyond the customer's reach — intervention is not possible in a crisis.

Typical profile: non-certified mass-market services, dark SaaS, shadow IT, tools with unclear provider structure. Certified services can also fall into L0 if they document security but not sovereignty.

Use cases: none. L0 is explicitly a finding, not a recommended level — it signals the presence of a structural sovereignty risk.

What changes at L0 per domain
DomainMinimum requirement
D1Ownership or jurisdiction undocumented.
D2Access paths and key roles not transparent.
D3Closed stack, no documented exit paths.
D4Supply chain largely unknown.

L1 — Transparency foundation§

Structurally intelligible, but still without operational levers on the customer side.

L1 marks the foundation of the sovereignty assessment. Ownership, jurisdiction, sub-contractors, architecture and supply chain are fully documented and independently auditable. The customer can understand what is being used — but cannot yet intervene operationally or control core levers themselves.

Typical profile: certified hyperscaler services with high technical maturity but without structural EU control; established SaaS providers with extensive documentation; mature European services in the build-out phase of their sovereignty functions.

Use cases: non-critical workloads, marketing, general office applications, collaboration for non-sensitive content.

What changes at L1 per domain
DomainMinimum requirement
D1Ownership, jurisdiction, sub-contractors fully documented.
D2Access paths and key roles fully described, log inspection possible.
D3APIs and export paths documented, data export in open formats.
D4Full SBOM and hardware supply chain; choke points identified.

L2 — Operational control§

The customer controls core operational levers themselves — keys, access, data location, exit.

L2 requires demonstrable operational control. Key sovereignty (e.g. HYOK), customer-side access revocation, enforceable data location and a documented exit path with proven migration capability are the minimum requirements. The customer can act strategically — not merely document.

Typical profile: sovereign EU services with a clear architecture, European providers with an open-source stack, regulated public-cloud offerings with genuine external key management and a documented migration reference.

Use cases: NIS2- and DORA-regulated functions, electronic health records, sector-critical workloads, public-sector standard applications.

What changes at L2 per domain
DomainMinimum requirement
D1Contractually secured data-access rules under EU law; notification rights.
D2Key sovereignty (HYOK or equivalent); access revocation and data location enforceable.
D3Proven exit at acceptable cost and within acceptable timeframes; full SBOM.
D4Diversified sources for critical components; substitution strategy.

L3 — Structural sovereignty§

Structural independence from individual providers and non-European jurisdictions.

L3 marks structural sovereignty. The service can be switched without loss of control or continuity; the technical and legal supply chain is diversified and EU-resilient. Sovereignty is no longer a property of the provider alone, but a property of the whole stack and its alternatives.

Typical profile: multi-cloud architectures fully based on open source, specialised KRITIS-grade providers with their own stack, state-backed digital infrastructures with documented diversification.

Use cases: critical infrastructure, security-relevant public administration, defence-adjacent applications, highest sovereignty protection goals.

What changes at L3 per domain
DomainMinimum requirement
D1No extraterritorial access rights; structural EU independence.
D2Provider access to content data technically excluded; external notarisation.
D3Predominantly open source; reproducible migration to at least two competing targets.
D4Viable EU alternatives for every critical component.

Which level for which use case?§

The following recommended minimum levels are indicative — the binding determination is made sector-specifically via protection goals and minimum levels per domain (see Aggregation principle).

Use caseRecommended minimum level
Marketing CRM, newsletters, analytics-free external reachL1
General office and collaboration environments without special-category personal dataL1
HR records, general HR systemsL2
Financial accounting, ERPL2
NIS2-regulated services (energy, health, transport)L2 (D2 ≥ L2)
DORA-regulated core functions in the financial sectorL2 (D3 ≥ L2)
Electronic health records (EHR) and hostingL2 (D2 ≥ L3)
Authorities handling classified material (VS-NfD level)L3
Critical-infrastructure control systemsL3
Security-relevant administration, defence-adjacent applicationsL3 across all domains