Huvigruppide kaasamine: avalik konsultatsioon EL AI & pilveandmetöötluse määrus (tähtaeg 16.05)

Open Public consultation questionnaire on the proposal for a Cloud and AI Development Act Fields marked with * are mandatory. Introduction This consultation on the Cloud and AI Development Act is structured along three sections: Section 1: General questions for all respondents This section includes a set of general questions applicable to all respondents. Your responses here will guide which subsequent questions you receive in Section 2, based on your stakeholder category. Section 2: Stakeholder-Specific Questions To tailor the consultation to your area of expertise, please begin by selecting "I am giving my contribution as" to identify your stakeholder category. To begin, please choose "I am giving my contribution as" to select your specific stakeholder category. You can choose from the following: Public Administrations Citizens NGOs Academic/Research Institutions Business Associations Consumer Organisations Environmental Organisations Trade Unions Company/Business If you select "Company/Business," please specify further as follows: Data Centre Operators Cloud / Telco / Edge Providers AI Developers and Providers Cloud / Edge / AI Users Financial Institution, Investor, Fund Your selection will help us direct you to the relevant questions for your category, ensuring a more focused and effective consultation. Section 3: EU Policy 1  In the final section, all participants are asked to share their views on potential policies to be adopted on cloud policy. About you * First name * Surname * Email (this won't be published) * Language of my contribution Bulgarian Croatian Czech Danish Dutch English Estonian Finnish French German Greek Hungarian Irish Italian Latvian Lithuanian Maltese Polish Portuguese Romanian Slovak 2  Slovenian Spanish Swedish * I am giving my contribution as Academic/research institution Business association Company/business Consumer organisation EU citizen Environmental organisation Non-EU citizen Non-governmental organisation (NGO) Public authority Trade union Other Please choose the type of stakeholder you represent [multiple options possible] Minimum 1 selection(s) a) data centre operator, including co-location providers (i.e. the entities involved in the building and operation of data centre facilities) b) cloud/ Telco / Edge provider, including cloud service providers offering cloud services, irrespective of whether such services are operated on self- owned or leased data centres c) AI developers or AI deployers irrespective of the delivered AI service (training, fine-tuning, inference) and whether these services are delivered on owned or leased data centres and cloud infrastructure. d) cloud/ Edge / AI users, organisations that use any cloud and edge service offering or use any AI application e) Financial institution, investor, fund, etc., that finance any type respondents described under a. b. c. * Organisation name 255 character(s) maximum 3 * Organisation size Micro (1 to 9 employees) Small (10 to 49 employees) Medium (50 to 249 employees) Large (250 or more) Transparency register number Check if your organisation is on the transparency register. It's a voluntary database for organisations seeking to influence EU decision-making. * Country of origin Please add your country of origin, or that of your organisation. This list does not represent the official position of the European institutions with regard to the legal status or policy of the entities mentioned. It is a harmonisation of often divergent lists and practices. Afghanistan Djibouti Libya Saint Martin Åland Islands Dominica Liechtenstein Saint Pierre and Miquelon Albania Dominican Lithuania Saint Vincent Republic and the Grenadines Algeria Ecuador Luxembourg Samoa American Samoa Egypt Macau San Marino Andorra El Salvador Madagascar São Tomé and Príncipe Angola Equatorial Guinea Malawi Saudi Arabia Anguilla Eritrea Malaysia Senegal Antarctica Estonia Maldives Serbia Antigua and Eswatini Mali Seychelles Barbuda Argentina Ethiopia Malta Sierra Leone Armenia Falkland Islands Marshall Islands Singapore Aruba Faroe Islands Martinique Sint Maarten Australia Fiji Mauritania Slovakia Austria Finland Mauritius Slovenia Azerbaijan France Mayotte Solomon Islands 4 Bahamas French Guiana Mexico Somalia Bahrain French Polynesia Micronesia South Africa Bangladesh French Southern Moldova South Georgia and Antarctic and the South Lands Sandwich Islands Barbados Gabon Monaco South Korea Belarus Georgia Mongolia South Sudan Belgium Germany Montenegro Spain Belize Ghana Montserrat Sri Lanka Benin Gibraltar Morocco Sudan Bermuda Greece Mozambique Suriname Bhutan Greenland Myanmar/Burma Svalbard and Jan Mayen Bolivia Grenada Namibia Sweden Bonaire Saint Guadeloupe Nauru Switzerland Eustatius and Saba Bosnia and Guam Nepal Syria Herzegovina Botswana Guatemala Netherlands Taiwan Bouvet Island Guernsey New Caledonia Tajikistan Brazil Guinea New Zealand Tanzania British Indian Guinea-Bissau Nicaragua Thailand Ocean Territory British Virgin Guyana Niger The Gambia Islands Brunei Haiti Nigeria Timor-Leste Bulgaria Heard Island and Niue Togo McDonald Islands Burkina Faso Honduras Norfolk Island Tokelau Burundi Hong Kong Northern Tonga Mariana Islands Cambodia Hungary North Korea Trinidad and Tobago 5  Cameroon Iceland North Macedonia Tunisia Canada India Norway Türkiye Cape Verde Indonesia Oman Turkmenistan Cayman Islands Iran Pakistan Turks and Caicos Islands Central African Iraq Palau Tuvalu Republic Chad Ireland Palestine Uganda Chile Isle of Man Panama Ukraine China Israel Papua New United Arab Guinea Emirates Christmas Island Italy Paraguay United Kingdom Clipperton Jamaica Peru United States Cocos (Keeling) Japan Philippines United States Islands Minor Outlying Islands Colombia Jersey Pitcairn Islands Uruguay Comoros Jordan Poland US Virgin Islands Congo Kazakhstan Portugal Uzbekistan Cook Islands Kenya Puerto Rico Vanuatu Costa Rica Kiribati Qatar Vatican City Côte d’Ivoire Kosovo Réunion Venezuela Croatia Kuwait Romania Vietnam Cuba Kyrgyzstan Russia Wallis and Futuna Curaçao Laos Rwanda Western Sahara Cyprus Latvia Saint Barthélemy Yemen Czechia Lebanon Saint Helena Zambia Ascension and Tristan da Cunha Democratic Lesotho Saint Kitts and Zimbabwe Republic of the Nevis Congo Denmark Liberia Saint Lucia * In which sector(s) is your organisation active? Please specify 6  Text of 1 to 500 characters will be accepted * Type of organization private company (SME) private company (start-up) private company (other) research organization other * Is your organization headquartered in the EU? Yes No Other (e.g. multiple organizations) * Is your parent company headquartered in the EU? Yes No * Do you have an office or other kind of representation in the EU? Yes, we have a subsidiary, branch office or similar in the EU Yes, other No * Do you have a research and development department? Yes No * What is the amount (in EUR) that you invest in R&D on cloud / edge in a yearly basis? EUR * How many employees does your R&D department have? * Scope International 7  Local National Regional * Level of governance Local Authority Local Agency * Level of governance Parliament Authority Agency * Availability for a follow-up conversation - We may wish to contact you for clarification or further discussion if your submission prompts additional interest. Do you agree to be contacted by the Commission for clarification or discussion further to your submission? Yes No The Commission will publish all contributions to this public consultation. You can choose whether you would prefer to have your details published or to remain anonymous when your contribution is published. Fo r the purpose of transparency, the type of respondent (for example, ‘business association, ‘consumer association’, ‘EU citizen’) country of origin, organisation name and size, and its transparency register number, are always published. Your e-mail address will never be published. Opt in to select the privacy option that best suits you. Privacy options default based on the type of respondent selected * Contribution publication privacy settings The Commission will publish the responses to this public consultation. You can choose whether you would like your details to be made public or to remain anonymous. Anonymous The type of respondent that you responded to this consultation as, your country of origin and your contribution will be published as received. Your name will not be published. Please do not include any personal data in the contribution itself. 8  Public Your name, the type of respondent that you responded to this consultation as, your country of origin and your contribution will be published. * Contribution publication privacy settings The Commission will publish the responses to this public consultation. You can choose whether you would like your details to be made public or to remain anonymous. Anonymous Only organisation details are published: The type of respondent that you responded to this consultation as, the name of the organisation on whose behalf you reply as well as its transparency number, its size, its country of origin and your contribution will be published as received. Your name will not be published. Please do not include any personal data in the contribution itself if you want to remain anonymous. Public Organisation details and respondent details are published: The type of respondent that you responded to this consultation as, the name of the organisation on whose behalf you reply as well as its transparency number, its size, its country of origin and your contribution will be published. Your name will also be published. I agree with the personal data protection provisions Section 2: Questions for specific target groups The EU's digital competitiveness in AI and cloud computing is significantly hindered by the gap between the computing resources available in the EU and the needs to satisfy the growing demand for AI-driven services and applications. Current projections indicate that the EU needs to triple its capacity of AI- optimised data and computing infrastructures designed to accommodate data processing and storage needs across the AI value chain (training, inference, fine-tuning). Your response to this section of the survey will help the Commission to assess the scale of this problem as well as to qualitatively analyse its drivers. Section 2.1 Questions for data centre operators 2.1.1 Data centre operators: Current situation * What type of data centre operator is your organisation? Minimum 1 selection(s) Co-location data centre 9  Edge data centre Enterprise data centre Hyperscale data centre Other * Please specify Text of 1 to 1000 characters will be accepted * What is the geographic scope of your operations? regional national EU level global * How many data centres do you operate and what percentage of your capacity is physically located in the EU? 4000 character(s) maximum * What is your overall data centre capacity? Less than 1 MW 1 MW - 30 MW 30 MW - 50 MW 50 MW - 200 MW 200 MW - 1 GW More than 1 GW * What is the average capacity of the data centres that you operate? Less than 1 MW 1 MW - 10 MW 11 MW - 30 MW 10  31 MW - 50 MW More than 50 MW * What is the approximate composition of your total installed compute capacity? Please indicate the distribution which best resembles your installed capacity (CPU: central processing unit. GPU: graphics processing unit). 100% CPUs 75% CPUs - 25% GPUs 50% CPUs - 50% GPUs 25% GPUs - 75% CPUs 100% GPUs I don't know Please specify the models of the GPUs that you are using Text of 1 to 4000 characters will be accepted * If a colocation data centre, what percentage of your business is leased to hyperscale cloud providers? Less than 25% 26% - 50% 51% - 75% More than 75% * How long do you currently need on average to build a data centre from the moment the real estate is identified to the entry in operation? 1 - 2 years 3 - 5 years 5 - 7 years More than 7 years 2.1.2 Specific needs and challenges 11 * Is your organisation planning to build new facilities or expanding existing ones in the EU? Yes No I don't know * Will these facilities be for (you may select more than one option): Minimum 1 selection(s) general purpose computation general purpose edge computation Edge AI AI computation for training models AI computation for the inference of models Other * Please, specify Text of 1 to 1000 characters will be accepted * What will be the approximate planned capacity? Amount of MW I don't know * Amount of MW Only values of at least 1 are allowed When expanding or building your infrastructure in the EU, what are the main problems your organisation has encountered? Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important Not applicable / I Problem 1 2 3 4 5 don't know * Access to land * Access to energy resources 12  * Access to water resources * Access to state-of-the-art location facilities * Difficulty navigating applicable planning regulations * Permitting procedures (too complex or too long) * Access to capital * High operational costs * Access to connectivity * Access to skilled workforce * Other * Please specify 4000 character(s) maximum On the selection of the facility’s location in the EU: which are the main factors that drive or have driven your decision to select a location? Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important. Not Factor 1 2 3 4 5 applicable / I don't know * Saturation of the market * Access to transport networks (e.g. airport, or, high- speed railway) * Availability of a utility provider’s infrastructure nearby * Distance from an electrical substation * Availability and affordability of energy * Availability and affordability of low carbon energy * Possibility to conclude long term energy contracts * Access to long term guaranteed water supply and/or fixed water rates 13  * Possibility for waste heat re-use * Environmental regulations (e.g. air quality or noise levels) * Local climate conditions * Network connectivity and capacity * Availability of incentives (e.g. tax incentives) * Geopolitical stability * Other * Please specify 4000 character(s) maximum How relevant were the following factors for your organisation for the buildout of a new data centre or expansion of existing infrastructure in the EU? This question covers all the steps from the inception of the project until the data centre comes into operation. (Rank each answer on a scale from 1 to 5, where 1 = not very relevant and 5 = very relevant) Not applicable Bottleneck 1 2 3 4 5 / I don't know * Land use / availability * Compliance with environmental or zoning requirements * Energy availability * Energy cost * Water-stress and poor water governance in the areas of operations * Construction * Long approval times * Complexity of regulation * Permitting / Approval procedures 14  * Access to finance * Digital skills * Other * Please specify 4000 character(s) maximum On access to finance/incentives: what are the most significant factors that your organisation is encountering from the financial point of view when expanding capacity or building new capacity in the EU? Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important. Not applicable Factor 1 2 3 4 5 / I don't know * High interest rates charged by banks and other financial institutions * Financial institutions are low risk averse to fund long term data centre projects * Limited upside (e.g. due to high upfront costs and long payback periods, market uncertainty, high operating costs, etc) * High taxes * Other * Please specify 4000 character(s) maximum * How significant is energy efficiency in your expansion plans in the EU? Critical Important, but not a priority 15  Important, but energy efficiency is already a mature design feature Not significant I don't know * What are the main problems that you face in becoming more energy efficient? 4000 character(s) maximum What are your main energy efficiency challenges? (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not applicable / I Challenge 1 2 3 4 5 don't know * Cooling efficiency * Server utilisation * Inefficient hardware * Energy losses * Integration of renewable energy * Compliance with existing regulation * Lack of real time monitoring tools for energy usage * Other * Please specify 4000 character(s) maximum What are the main factors preventing you from building new facilities or expanding existing facilities? (Rank each answer on a scale from 1 to 5, where 1 = not very relevant and 5 = very relevant) 16  Factor 1 2 3 4 5 Not applicable / I don't know * Not a business priority * Land use / availability * Compliance with environmental or zoning requirement * Energy availability * Energy cost * Water-stress and poor water governance in the areas of operations * Construction * Long approval times * Complexity of regulation * Permitting / approval procedures * Access to finance * Digital skills * Other * Please specify 4000 character(s) maximum Please upload your file(s), if you would like to provide additional information Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 2.2 Questions for cloud / Telco / Edge providers 2.2.1 Current situation in the provisioning of cloud / Telco / Edge services for general purpose and AI services * What are your customers using your service offer for? (multiple choice) Minimum 1 selection(s) general purpose computation storage 17  general purpose edge computation Edge AI AI computation for training models AI computation for the inference of models AI Computation for fine tuning Other * Please specify 1000 character(s) maximum * What percentage of your compute capacity is currently dedicated to AI workloads (including AI model training, AI model inference and AI fine tuning)? Less than 10% 10 - 25% 26 - 50% 51 - 75% 76 - 100% I don't know * What is the approximate composition of your total installed compute capacity? (please indicate the distribution which best resembles your installed capacity) 100% CPUs 75% CPUs and 25% GPUs 50% CPUs and 50% GPUs 25% CPUs and 75% GPUs 100% GPUs I don’t know Please specify the models of the GPUs that you are using 4000 character(s) maximum 18 * Do you have difficulties in getting funding to develop your capacities? Yes No * Please give details 4000 character(s) maximum * Do you have problems in accessing non-hardware technologies to develop your capacities and propose new services to your customers? Yes No * Please give details 4000 character(s) maximum * Do you have difficulties in hiring/attracting talents to develop your capacities? Yes No * Which talents' profiles? 4000 character(s) maximum * Do you have difficulties in developing your activities within other EU Member States? Yes 19  No * Which main barriers are you facing? 4000 character(s) maximum * What progress have you made in expanding to markets beyond the European Union? 4000 character(s) maximum 2.2.2 Specific needs and challenges in the provisioning of cloud / Telco / Edge services for general purpose and AI services * Have you experienced any limitation to the access to GPUs that is slowing down your expansion in computation capacity? Yes No I don't know Is this limitation due to (rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not applicable Factor 1 2 3 4 5 / I don't know * Restrictive market practices applied by GPUs providers when selling to customers in specific countries or relating to the volume of pucharses * bargaining power of GPU providers (e.g. setting prices based on their dominant position, exclusive deals, etc.) * access to finance and/or high interest rates when procuring next generation GPUs * scarcity of supply of GPUs 20  * supply chain disruptions * export control restrictions applied by third countries that prohibit you from purchasing GPUs * export control procedures applied by third countries that slow down your access to GPUs, due to the procedures’ complexity * Other * Please specify 4000 character(s) maximum * How are you solving the issues that affect you? 4000 character(s) maximum * Is your organisation planning to expand its computing capacity? Yes No I don't know * Will this capacity be for (you may select more than one option): general purpose computation storage general purpose edge computation Edge AI AI computation for training models AI computation for the inference of models AI computation for fine tuning Other * To what extent do you rely on colocation data centres? To a large extent 21  To some extent To a small extent To no extent * Are you planning to expand the space that you rent in colocation data centres? Yes No I don't know * What is the decisive factor when choosing a colocation facility in the EU? Minimum 1 selection(s) cost of the co-location facility location accessibility of connected services downstream and upstream (connectivity) cybersecurity measures in place physical infrastructure security latency innovation of the facility technical support of the facility sustainability of the facility geopolitical stability of the location of the facility Other * Please specify 4000 character(s) maximum What are your main energy-efficiency challenges? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable / I Challenge 1 2 3 4 5 don't know * Cooling efficiency * Server utilisation 22  * Inefficient hardware * Energy losses * Integration of renewable energy * Compliance with existing regulations * Lack of real time monitoring tools for energy usage * Other * Please specify 4000 character(s) maximum On access to finance/incentives: what are the main challenges that your organisation is encountering from the financial point of view when expanding operations? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Factor 1 2 3 4 5 / I don’t know * High interest rates by the banks and other financial institutions * Financial institutions are too risk averse to fund long term data centre projects * Limited upside (e.g. due to high upfront costs and long payback periods, market uncertainty, high operating costs, …) * High taxes * Difficulty in accessing capital, such as loans or equity * Other * Please specify 4000 character(s) maximum 23  Please include any additional information you would like to share Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 2.3 Questions for AI developers and providers 2.3.1 Current situation * As an AI deployer, on which type of infrastructure is your organisation deploying your AI systems? on-premise on the cloud hybrid model combining local and cloud-based solutions multi-cloud, combining the services from multiple vendors Edge AI not applicable * If chosen on the cloud, select: Using a hyperscaler cloud provider Using a non-hyperscale cloud provider What main factors have impacted your organisation’s choice at the moment of deploying your AI services? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Factor 1 2 3 4 5 / I don't know * Price of computational resources (e.g. virtual machines, infrastructure, storage) * Clarity of price structure depending on the activity (e.g. inference/fine tuning/training) * Sufficient capacity during peak times * Access to specialised hardware on Edge devices * Location of the computational resource (EU, non-EU) * Cloud credits (i.e. an offer of free compute capacity) 24  * Cybersecurity measures in place * High capacity, reliable and affordable connectivity * Managing latency and performance requirements * Integration with other (cloud) services from the same provider * Integration with other services from other providers * Availability of software tools to assist the deployment of your AI service in the cloud * Other * Please specify 4000 character(s) maximum * When selecting cloud providers, how concerned are you that your organisation’s [sensitive] data are being accessed by authorities [of a third country] in circumvention of applicable EU laws and regulations (e.g. the GDPR and the Data Act)? Very concerned Somewhat concerned Neutral Not very concerned Not concerned at all I don’t know Not applicable * When selecting cloud providers, are you concerned that the cloud provider is headquartered in a third country that poses specific cybersecurity threats to the EU? Very concerned Somewhat concerned Neutral Not very concerned Not concerned at all 25  Not applicable * When selecting cloud providers, how concerned are you by risks such as undue influence by a third country on suppliers and service providers (particularly in the case of alternative models of governance); concealed vulnerabilities or backdoors; and potential systemic supply disruptions (particularly in the case of technological lock-in or provider dependency)? Very concerned Somewhat concerned Neutral Not very concerned Not concerned at all Not applicable What performance challenges do you face in the inferencing of AI models on cloud and edge platforms? (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not applicable / I don't 1 2 3 4 5 know * High latency for real time applications * Inconsistent performance across cloud regions * Limited processing power on edge devices * Other * Please specify 4000 character(s) maximum * Do bundling practices (e.g. infrastructure service offerings, such as computation or storage offered with AI / machine learning (ML) tools) by cloud providers impact your AI workload (ability to deploy and manage AI applications)? Bundling is a commercial strategy where several software packages are sold together for distribution, deployment or use. 26  Significantly To a certain extent No I don't know * Please specify 4000 character(s) maximum 2.3.2 Specific needs and challenges What is the most significant challenge from the infrastructure and infrastructure provider point of view that your organisation is facing when deploying and managing your AI services? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Challenge 1 2 3 4 5 / I don't know * Limited access to computational capacity in general * Limited access to computational capacity in the EU * Insufficient features of the current capacity offerings (pricing, sustainability, security) * Fear of vendor lock in * Cybersecurity concerns * Limited availability of high capacity, reliable and affordable connectivity * Limited availability of software tools covering the whole development and operations lifecycle, including open source software * Other * Please specify 4000 character(s) maximum 27  For which part of the AI service development lifecycle is the problem of limited capacity most acute? Rank each answer on a scale from 1 to 5 where 1 = not very acute and 5 = very acute. 1 2 3 4 5 Not applicable / I don't know * Training * Fine-Tuning * Inference * All of the above * Other * Please specify 4000 character(s) maximum Please include any additional information you would like to share Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 2.4 Questions for cloud / Telco / Edge / AI users 2.4.1 Current situation * What type of infrastructure is your organisation using to fulfil your cloud /Telco/Edge/AI needs? On-premise On the cloud Hybrid model combining local and cloud-based solutions Multi-cloud, combining the services from multiple vendors Edge AI What are the main factors that impact your organisation’s choice of Cloud /Edge/AI provider to service your needs? 28  (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not applicable 1 2 3 4 5 / I don't know * Price of the service offers * Location of the data * Cybersecurity measures in place * High capacity, reliable and affordable connectivity * Latency * Innovation of the solution * Breadth of service offer / Possibility of integration with other services from the same provider (e.g. software tools) * Integration with other services from other providers * Interoperability with other providers * Availability of additional software tools * Integrated offering (bundle) * Availability of additional software tools * Cloud credits * Other * Please specify 4000 character(s) maximum * What type of AI offers do you usually need? Training on the cloud Training on high performance computing Training on premise Fine-tuning on the cloud Inference on the edge 29  Inference on the cloud I don’t know Other please specify * Please specify 4000 character(s) maximum * Who is currently capable of offering these services to you? Hyperscale cloud providers Providers of High-Performance Computing (EuroHPC or national HPC) EU cloud service providers Smaller non-EU cloud service providers Other * Please specify 4000 character(s) maximum 2.4.2 Specific needs and challenges * When selecting a cloud service, what are the most significant factors that affect your decision? Pricing Data location Limited choice of infrastructure provider (through bundling, restrictive licensing) Financial incentives (cloud credits, committed spend discounts) Data protection, privacy and security vulnerabilities Not enough processing power for training either in the EU or offered by an EU provider Not enough processing power for inference either in the EU or offered by an EU provider 30  Fear of vendor lock-in Cybersecurity protection High-capacity, reliable and affordable connectivity infrastructure Limited open-source software and / or AI models Other * Please specify 4000 character(s) maximum * Are there any gaps in the current service offers of cloud computing providers that impact your operations? 4000 character(s) maximum * Are there any gaps in the current offers of AI providers that impact your operations? 4000 character(s) maximum Please include any additional information you would like to share. Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 2.5 Questions of Public Administrations * On behalf of what type of public administration are you answering? Local Regional National/Federal European 31  2.5.1 Current situation * Does your public administration currently use cloud computing and AI services? Yes No I don't know * What types of cloud services do you use? Infrastructure as a Service - IaaS (e.g. virtual machines, storage, infrastructure) Platform as a Service - PaaS Software as a Service - SaaS Other I don't know * Please specify 1000 character(s) maximum * Do you store data on the cloud? Yes No, only on-premises I don't know * What type of data do you store in the cloud? Sensitive information, such as data related to public security or public safety Special categories of sensitive data such as health records or financial data Other data that my organisation considers sensitive (if so, please specify) Commercially sensitive data, including data subject to intellectual property rights as well as trade secrets Operational data related to functioning of digital public services Public data Open data Trained AI models 32  Other * Please specify 1000 character(s) maximum * How do you store this data on the cloud? All encrypted All non-encrypted It depends on the data classification and sensitivity I do not know * Please specify the data classification and sensitivity 4000 character(s) maximum When selecting cloud providers for your organisation how concerned are you with respect to the following: (Rank each answer on a scale from 1 to 5, where 1 = not concerned at all and 5 = very concerned) Not applicable 1 2 3 4 5 / I don't know * Sensitive data of your organisation is accessed by authorities of a third country in circumvention of applicable EU laws and regulations (e.g. GDRP, Data Act) * Cloud provider is headquartered in a third country that poses specific cyber-security threats to the Union * Risks such as undue influence by a third country on suppliers and service providers, in particular in the case of alternative models of governance; concealed vulnerabilities or backdoors; and potential systemic supply disruptions, in particular in the case of technological lock-in or provider dependency 33  * Other * Please specify 4000 character(s) maximum * Which cloud deployment model(s) does your public administration rely on? Government private cloud Public cloud Hybrid cloud Other I don’t know * Please specify 1000 character(s) maximum * Are any of your procured providers subject to non-EU jurisdictions including laws with extraterritorial effect (e.g. US or Chinese providers)? Yes No I don't know What are the main factors driving the decision of which cloud service will be procured in your administration? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Factor 1 2 3 4 5 / I don't know * Level of assurance and protection (i.e. the security mechanisms put in place depending on the sensitivity of the data) 34  * Price * Made in the EU * Provenance of the provider * Integration with other services from the same provider (e. g. software tools) * Integration with other services from other providers * Interoperability with other providers * Integrated offerings (bundle) * Sustainability * Latency * Reliability * Scalability * Other * Please specify 4000 character(s) maximum What are the main reasons for your administration not using cloud computing? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Reason 1 2 3 4 5 / I don't know * Total Cost of Ownership * Not enough knowledge to select the most appropriate service for different data sensitivities * Cybersecurity * Data protection concerns * Limited knowledge or lack of expertise in operation and management of cloud services (e.g. in terms of technical and administrative capabilities) 35  * Limited offering from EU providers * Compliance with EU regulations (e.g. the GDPR and Data Act) * Risk of unlawful access to data from third countries legislation with extra territorial reach * Fear of vendor lock in * Fear of interoperability issues * High operational cost of migration from on-premise solutions * Sustainability concerns * Preference/ no need * Other * Please specify 4000 character(s) maximum * Is the software developed in your public administrations released as open source software? Yes No I don't know * Is there an established public repository where the code can be accessed and contributed to? Yes No I don't know * Is there a community governance mechanism put in place for the code released as open source? Yes No I don't know 36  2.5.2 Specific needs and challenges What are your administration’s top priorities when using cloud computing? (Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important) Not applicable Priority 1 2 3 4 5 / I don't know * Scalability * Cost efficiency * Risk of unlawful access to data from actors subject to non-EU legislation with extraterritorial reach * Security mechanisms in place * Data protection measures * Availability / uptime * Performance * Integration with other services from the same provider, for instance, software tools * Integration with other services from other providers * Interoperability with other providers * Integrated offering (bundle) * Made in Europe * Environmental sustainability * Protection from cybersecurity risks posed by certain countries * Other * Please specify 37  What challenges have you encountered with the adoption of cloud by your administration? (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not applicable Challenge 1 2 3 4 5 / I don't know * Limited knowledge on how to technically evaluate, assess and procure the existing cloud service offerings * Security risks * Vendor lock in * Limited technical expertise * Limited or lack of interoperability * Regulatory, including public procurement requirements * Other * Please specify 4000 character(s) maximum * Are there any gaps in the current offerings of cloud computing providers that impact your operations? 4000 character(s) maximum How can the EU support public administrations in increasing their use of cloud computing? (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) 38  Factor 1 2 3 4 5 Not applicable / I don't know * Funding * EU-wide uniform guidance on how to procure * Mechanisms to allow federation of cloud services across public administrations within and across Member States * Standards, open specifications and mechanisms to ensure interoperability of cloud solutions * Cybersecurity guidelines * Technical support, training and capacity building support * Other * Please specify 4000 character(s) maximum * Does your administration release the code procured for the delivery of digital services as open source? Always In some cases Never I don't know Not applicable * Is any licensing schema preferred? 4000 character(s) maximum * What is preventing you from this? Licenses Cybersecurity vulnerabilities 39  Maintenance Sustainability Accountability Other * Please specify 1000 character(s) maximum * Are there any specific policy measures you would recommend to improve public administrations’ access to and use of cloud services? 4000 character(s) maximum * Are there any specific policy measures you would recommend for the provision of the security of cloud services for public administrations? 4000 character(s) maximum Please include any additional information you would like to share Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 2.6. Questions for financial institutions 2.6.1 Current situation * What are the main activities that your financing institution is investing in related to AI / cloud computation? Computing infrastructure development, mainly real estate (e.g. data centres) Computation processors such as GPUs (Graphic Processing Unit) AI services 40  Other I don’t know * Please specify 4000 character(s) maximum * How would you describe your current level of investment in computing infrastructure development? significant – computing infrastructures are a key part of our portfolio moderate – we have some investments in the sector minimal – we are still exploring opportunities none – we currently have no investments in this area If any, what are the main reasons for your interest in investing in computing infrastructures? (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not applicable / I Reason 1 2 3 4 5 don't know * the sector’s high growth potential (return on investment) * Diversification of the investment portfolio * Alignment with existing policies * Strategic interest (resilient infrastructure for critical services) * Other * Please specify 4000 character(s) maximum 41  Which are the main factors preventing your organisation from investing in new computing infrastructures capacity? (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not Factor 1 2 3 4 5 applicable / I don’t know * High upfront capital requirements * High risk aversion to funding long-term computing infrastructure projects * Lack of access to tax incentives * Lack of access to tax breaks * Lack of access to additional funds * Uncertainty about long term demand * Lack of technical expertise to evaluate projects * Insufficient market data or performance benchmarks * Low liquidity or exit options for data centre investments * Competing resources * Regulatory obstacles * Environmental or social impact concerns * Other * Please specify 4000 character(s) maximum * What expectations do you have for computing infrastructure projects in terms of return on investment (ROI)? Above 15% annually Between 10% and 15% annually Below 10% annually but stable Other 42 * Please specify 4000 character(s) maximum What factors limit the ROI of your computing infrastructure investments? (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not applicable / I Factor 1 2 3 4 5 don’t know * High initial capital expenditure delaying the return * High operational costs (e.g. energy and maintenance) * Limited scalability * Future proofing of the technology and the facility * Competition driving down margins * Cybersecurity risks * Other * Please specify 4000 character(s) maximum * When you expect to break even the investment realized in computing infrastructure projects? 1-3 years 4 -7 years 8 – 10 years More than 10 years I don't know 2.6.2 Specific needs and challenges 43  What is the biggest challenge for investors in the computing infrastructures market? (Rank each answer on a scale from 1 to 5, where 1 = not very important and 5 = very important) Not applicable / I don't Challenge 1 2 3 4 5 know * Lack of market transparency or data * Insufficient policy support or incentives * Only a few available firms able to build facilities * Other * Please specify 4000 character(s) maximum What policy measures could help mitigate investment risks in this sector? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Policy measure 1 2 3 4 5 / I don’t know * EU- or Member-State-backed guarantees or risk sharing mechanisms * Clearer regulatory frameworks * Tax incentives for computing infrastructures investments * Establish standardised metrics and benchmarks for computing infrastructures performance * Simplify regulatory procedures (e.g. for permitting) * Create liquidity mechanisms for long term investors * Reduced energy costs for data centres through subsidies * Streamlined regulatory approval processes * Other, please specify 44 * Please specify 4000 character(s) maximum What policy measures could make computing infrastructures investments more attractive for investment? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Policy measure 1 2 3 4 5 / I don’t know * Co-investment opportunities with public or private partners * Development of specialized funds or instruments for data centres * Enhanced transparency on sector performance metrics. * Other * Please specify 4000 character(s) maximum Please include any additional information you would like to share Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 2.7 Questions for organisations other than the ones above 2.7.1 Current situation * What is your profile? Business organization Consumers organization NGO 45  Academia Other What is your main reason for participating in this survey? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Interest 1 2 3 4 5 / I don't know * I am concerned about how secure my personal or professional data are when stored in the cloud * I am concerned that non-EU tech companies have too much influence over our data and digital infrastructure * I want fair competition and support for EU businesses and start-ups in the digital space * I would like the EU to invest in and prioritise EU cloud infrastructure and services * I believe there should be stronger rules and enforcement for how cloud and AI services operate in the EU * I am concerned about the environmental impact of building large-scale data centres and digital technologies * I am concerned that some people or communities may be left behind in the shift to digital and cloud-based services (e.g. due to the lack of access to digital tools, poor internet, lack of training, etc.) * I want to know how governments and public institutions use cloud services and how they protect our data * I work in tech, policy, education or a related field and want to contribute with my perspective * I believe citizens should have a voice in digital governance aspects * Other * Please specify 4000 character(s) maximum 46 2.7.2 Specific needs and challenges * Are there any specific needs to be addressed for building new computational resources? 4000 character(s) maximum * Are there any specific factors affecting your access to cloud services? 4000 character(s) maximum * Are there any specific obstacles to the consumption of secure cloud services? 4000 character(s) maximum * Have you identified any gaps in the current offerings of cloud computing providers that impact your day-to-day activities? 4000 character(s) maximum Please include any additional information you would like to share 4000 character(s) maximum Please upload your file(s) Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 47  2.8 Questions for individual citizens 2.8.1 Specific interests and concerns What are your main reasons for participating in this consultation? Rank each answer on a scale from 1 to 5 where 1 = not very important and 5 = very important. Not applicable Interest 1 2 3 4 5 / I don't know * I am concerned that my personal or professional data may not be secure when stored in the cloud * I am concerned that non-EU tech companies have too much influence over our data and digital infrastructure * I want fair competition and support for EU businesses and start-ups in the digital space * I would like the EU to invest in and prioritise EU cloud infrastructure and services * I believe there should be stronger rules and enforcement for how cloud and AI services operate in the EU * I am concerned by the environmental impact of building large-scale data centres and digital technologies * I am worried that some people or communities may be left behind in the shift to digital and cloud-based services (e.g. due to the lack of access to digital tools, poor internet, lack of training) * I want to know how governments and public institutions use cloud services and how they protect our data * I work in tech, policy, education or a related field and want to contribute with my perspective * I believe citizens should have a voice in digital governance aspects * Other * Please specify 4000 character(s) maximum 48 * How familiar are you with the current state of cloud computing services available in the EU? Very familiar Somewhat familiar Not very familiar Not familiar at all How much do you trust the following types of cloud providers to keep your personal or business data private and protected — even when it is stored in the EU? (Note: some non-EU providers may still be required to share data with their home country’s government under foreign laws, even if the data are stored in the EU) Very low Low Moderate High Very high Provider trust trust trust trust trust * EU-based providers * US-based providers (e.g. AWS and Microsoft) * Providers based outside the EU and US * If possible, please explain your answer above and provide examples 4000 character(s) maximum * How well do you think the EU is equipped in terms of cloud computing resources for both basic and AI-related services? Very well equipped (i.e. the EU is fully prepared and competitive on a global level) Well equipped (i.e. the EU is mostly keeping up with cloud and AI infrastructure demands) Moderately equipped (i.e. the EU has some capacity but there is room for improvement) Poorly equipped (i.e. some infrastructure exists, but it is not enough to meet current needs) 49  Very poorly equipped (i.e. the EU lacks sufficient infrastructure and is falling behind) I don’t know * Do you believe cloud service providers based in the EU can compete fairly with global tech giants? Yes, definitely Yes, but only with strong EU support Not really No, the market is already dominated and hard to disrupt I don’t know Other * Please specify 4000 character(s) maximum * How important is it for you for the EU to reduce its dependency on non-EU cloud providers? Very important Somewhat important Not important I don’t know Do you believe citizens should have the right to know which cloud services are used by public institutions (e.g. governments, hospitals and schools)? Yes, always Yes, but only for highly critical services No, this information does not need to be public I don’t know Other * Please specify 4000 character(s) maximum 50 * If possible, please explain your answer above and provide examples 4000 character(s) maximum * Do you think public services in the EU (e.g. healthcare or education) should be allowed to store citizen data with non-EU cloud providers (e.g. US-based companies)? Yes, without restrictions Yes, but only if strong safeguards are in place No, citizen data from public services should only be stored with EU-based providers It depends on the type of data or service I don’t know Other * Please specify 4000 character(s) maximum * If possible, please explain your answer above and provide examples 4000 character(s) maximum * Who do you think are most at risk of being excluded from the cloud and AI transition? People in rural or remote areas Older adults 51  Low-income individuals Small businesses Students without digital access No one – I believe access is fair I don’t know * Do you believe investing in EU cloud infrastructure could help create jobs and economic opportunities in the EU? Yes, definitely Possibly, especially in digital or tech sectors Not really No I don’t know * What benefits do you expect from stronger EU cloud infrastructure? Better protection of personal data and privacy More reliable and secure public digital services Job creation in tech, infrastructure or support roles Increased trust in public institutions More fairness and transparency in cloud and AI use I don’t know Other * Please specify 4000 character(s) maximum * What role should the EU play in shaping the future of cloud services? 4000 character(s) maximum Please include any additional information you would like to share 4000 character(s) maximum 52  Please upload your file(s) Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 3. EU Policies Faced with the current gap in the EU’s cloud and AI computing capacity, preliminary policy levers and possible areas of action have been identified to drive the development and deployment of the required computing resources and to stimulate their uptake in line with the EU’s rules and broader policy objectives. Your response to this section of the consultation will help the Commission to design the most impactful and efficient policy options as well as identify possible missing elements. 3.1 Computing Capacities This section collects input on the prioritisation of the activities in order to foster different types of computation facilities in the EU, while taking environmental aspects into consideration. What type of EU action should be prioritised for boosting the availability of sufficient and adequate cloud capacity for AI workloads? (Rank each answer on a scale from 1 to 5, where 1 = not very relevant and 5 = very relevant). Facilitation of investment Not Policy action 1 2 3 4 5 applicable / I don't know * Increasing public investment in private-public infrastructures * Creating public-private partnerships for large-scale data centres * Incentives for building computing infrastructure in underserved regions * Other * Please specify 53  Simplification of infrastructure permitting procedures Not applicable Policy action 1 2 3 4 5 / I don't know * Have a one stop shop service or a similar mechanism where the different permits at the different administrative levels can be requested and managed * Reduce the amount of time needed to obtain the different permits and environmental authorisations * Create expedited approval mechanisms and clear conditions for critical / strategic projects * Other * Other, please specify 4000 character(s) maximum Simplification of regulations for the building of computing infrastructure with energy efficiency Not applicable Policy action 1 2 3 4 5 / I don't know * Unified guidelines at national level for all aspects including energy efficiency * Unified guidelines at EU level * Other * Please specify Environmental aspects 54  Not applicable / I don't Policy action 1 2 3 4 5 know * Clear environmental compliance requirements * Addressing energy availability for data centres * Addressing land availability for data centres * Other * Please specify Energy efficiency Not applicable Policy action 1 2 3 4 5 / I don't know * Tax incentives for using sustainable technologies * Funding for research and development of energy- efficient technologies. * Standardised energy efficiency benchmarks * Investments in the development of more efficient software to manage and monitor the energy efficiency and metrics of the data centre * Other * Other, please specify 4000 character(s) maximum Cross-cutting issues Not applicable / I Policy action 1 2 3 4 5 don't know * 55  Supporting an open source software ecosystem * Collaborative programmes for R&D and innovation * Other * Please specify * At EU policy level, is it appropriate to distinguish between capacity for training, for fine-tuning, and for inference of AI models and solutions? Yes No I don't know * Why not? 3.2 Public Sector actions The following set of questions aim at gathering information mainly on the procurement rules of public administrations, and on policy actions to address the challenges faced by the public sector on procuring cloud services. * Which EU policy actions would best address the current issues faced by public administrations when procuring cloud and AI services? (multiple options possible) Guidelines with standard criteria to procure cloud services Guidelines with standard award criteria Standardized tender vocabulary and requirements I don't know Other * Please specify 56  1000 character(s) maximum * Which EU policy actions would address the issues currently faced by public administrations as regards cloud and AI services? (multiple options possible) Include a criterion ensuring sovereignty, autonomy, resilience and availability in the procurement of narrowly defined highly critical and strategic use cases Include a criterion for highly innovative solutions Include a criterion for solutions with added value and innovation Improvement of skills and capabilities, including training and certifications Marketplace of cloud services, AI services, and other software applications for the Public sector. Other I don't know * Please specify 4000 character(s) maximum 3.3. Open source in the public sector The following set of questions are intended to gain input to help address policy options on the release of code developed with public money as open-source code. * What EU policies would alleviate the challenges of releasing the code funded by public money as open-source* code? (*released under a license in which the copyright holder grants users the rights to use, study, change, and distribute the software and its source code to anyone and for any purpose) A common open-source licensing schema across the EU Guidelines to set up the governance mechanisms of the open-source community 57  Guidelines to select relevant open-source communities/foundations where the code can be released The setting up of a public-private foundation dedicated to such communities An obligation to release the source code developed with public money onto open-source repositories, except in duly justified cases Other I don't know * Other, please specify 4000 character(s) maximum 3.4 Cross – cutting topics The following questions are intended to provide the Commission with your input on cross-cutting topics such as market practices, security and research. * What EU policy actions would address bundling? Bundling is a commercial strategy where several software packages are sold together for distributon, deployment or use. Regulation of bundling practices to ensure fair competition Promoting open licensing models for AI tools and platforms Transparency requirements for cloud provider pricing and licensing I don't know Other * Other, please specify 4000 character(s) maximum * What EU policy actions would best protect against unlawful access to [sensitive] data [by third-country legislation with extraterritorial reach] and risks associated with supply chain dependencies (and possible disruptions) of cloud and AI services? 58  Pursue international cooperation (including international agreement) with third countries that address such risks Develop criteria that could be used to differentiate between third countries depending on whether they pose specific threats to the Union. Develop criteria to narrowly identify highly critical use cases for cloud and AI services Define criteria to narrowly identify highly critical use cases for which public procurers could address specific risks related to third countries’ legislation with extraterritorial reach, aligned with international agreements. Other I don't know * Other, please specify 4000 character(s) maximum * The EU pursues and has concluded with third countries agreements that facilitate trusted cross-border data flows and prohibit unjustified data localisation restrictions (including with Japan, Korea, Singapore and the UK). How important is it in your view that the EU promotes such partnerships with like-minded countries? Very important Somewhat important Neutral Not very important Not important at all In order to meet the future demand for AI services and applications while catering for the EU’s environmental policy objectives and technological autonomy, the EU needs to advance its research and innovation in the area of sustainable and resource-efficient AI computing continuum technologies (IoT, Telco, Edge, the cloud and HPC). Your response to this section of the survey will complement a targeted consultation addressing stakeholders involved in research and innovation projects in these fields and will help the Commission to identify priority fields for future support. If you are a researcher, are there any specific research priorities that you would like to recommend on: Data centre components (e.g. highly efficient chips, graphene battery walls)? 59  4000 character(s) maximum Optimal data centre operation and use of resources (e.g. AI solutions, optimisation of computing architecture and virtualisation, improved adaptation to user demand)? 4000 character(s) maximum Cooling innovations (e.g. direct on-chip, liquid & immersive)? 4000 character(s) maximum Integration of data centres into energy systems? 4000 character(s) maximum Advanced pilot lines to demonstrate the green data centres of the future? 4000 character(s) maximum Any other ideas? 4000 character(s) maximum 60 Please upload your file(s), if you have any additional information Only files of the type pdf,txt,doc,docx,odt,rtf are allowed 61 Saatja: "Kristiina Krause - JUSTDIGI" <[email protected]> Saaja: [email protected], "info - RIT" <[email protected]>, [email protected], [email protected] Teema: FW: Huvigruppide kaasamine: avalik konsultatsioon EL AI & pilveandmetöötluse määrus (tähtaeg 16.05) Kuupäev: 2025-05-05 07:20 Tere! Euroopa Komisjon avaldas uue tehisaru kontinendi tegevuskava <https://digital-strategy.ec.europa.eu/et/library/ai-continent-action-plan > raames avaliku konsultatsiooni EL tehisaru ja pilveandmetöötluse arendamise määruse ettevalmistamiseks (link <https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives /14628-Cloud-and-AI-Development-Act/addFeedback_en?p_id=50088950> ). Uues õigusaktis käsitletakse Euroopa pilve- ja tehisaru taristu suutlikkuses olevat lünka, mille kõrvaldamiseks tuleks: * edendada teadusuuringuid ja innovatsiooni, mis kiirendavad pilvandmetöötluse ja tehisintellekti vallas andmetöötlustaristute ja andmekeskuste kestlikuks muutmist; * hõlbustada erainvesteeringute tegemist pilvandmetöötluse ja tehisintellekti võimsuse kestlikku suurendamisse, et kolmekordistada järgmise 5–7 aasta jooksul ELi andmetöötlusvõimsus; * võtta meetmeid, millega suurendatakse ELis asuvate pilvandmetöötlusteenuste osutajate turvalise andmetöötluse võimsust. Seadusakti ettepaneku plaanib Euroopa Komisjon avaldada 2025. aasta lõpus. Konsultatsioonile saavad vastata kõik huvilised Have Your Say portaali kaudu. Justiits- ja Digiministeerium koostab konsultatsioonile vastust ning ootame selleks huvigruppidelt tagasisidet ja ettepanekuid, millele konsultatsioonile vastamisel tähelepanu pöörata. Manuses on lisatud ka Komisjoni küsimustik, millele võib tagasiside andmisel toetuda. Kirjaliku sisendi andmise tähtajaks on 16. mai (aadressile <mailto:[email protected]> [email protected]). Tänades Kristiina Krause EL ja rahvusvahelise digipoliitika juht Kommunikatsiooni- ja väliskoostöö talitus Justiits- ja Digiministeerium <mailto:%7BE-mail%7D> [email protected] <https://www.justdigi.ee/> www.justdigi.ee | Suur-Ameerika 1, Tallinn