Governance Model

Country Precedents

Lessons learned from countries and organisations that have successfully reduced dependency on US cloud and software platforms. These precedents provide reusable patterns, tooling, and approaches.

Why study precedents? Other governments and organisations have already solved many of the technical and organisational challenges. Learning from their experience accelerates our migration and reduces risk.

1. Denmark: Microsoft Exit & Digital Sovereignty

Denmark Case Study

Background

Following the 2020 Schrems II ruling, Danish authorities determined that Microsoft 365 and other US cloud services could not guarantee compliance with EU data protection law. The Danish Data Protection Agency (Datatilsynet) issued guidance effectively prohibiting certain uses of Microsoft products in schools and public sector.

Key Actions Taken

  • Schools exit from Google/Microsoft: Danish municipalities directed to stop using Google Workspace and Microsoft 365 for pupil data
  • Public sector guidance: Datatilsynet issued binding guidance on US cloud service risks
  • Alternative deployment: Migration to sovereign-hosted and open-source alternatives
  • National digital infrastructure: Investment in Danish/EU-hosted services

Technologies Adopted

Function US Product Replaced Sovereign Alternative
Email & Calendar Microsoft 365, Gmail Open-Xchange, Nextcloud + mail
Document Storage OneDrive, Google Drive Nextcloud
Office Suite Microsoft Office, Google Docs LibreOffice, Collabora Online
Video Conferencing Teams, Zoom, Meet Jitsi, BigBlueButton

Key Lessons

  • Legal driver works: GDPR/Schrems II provided legal basis for action
  • Start with education: Schools are less risk-averse than core government
  • Open source is ready: Nextcloud, LibreOffice viable for government use
  • Resistance is manageable: User complaints decrease after transition period

Reusability

HIGH. Denmark's approach is directly replicable. Their technical architecture, procurement approach, and change management lessons can be adopted with minimal modification.

2. France: SecNumCloud & Sovereign Cloud Strategy

France Case Study

Background

France has the most mature sovereign cloud strategy in Europe. The ANSSI (French cybersecurity agency) created the SecNumCloud certification, and the government requires its use for sensitive workloads. France has explicitly stated that US cloud providers cannot receive SecNumCloud certification due to extraterritorial US law.

Key Actions Taken

  • SecNumCloud certification: Rigorous security certification excluding US control
  • Cloud de Confiance: National trusted cloud strategy
  • OVHcloud + S3NS: French-controlled alternatives (S3NS = Thales + Google partnership with French control)
  • Procurement requirements: SecNumCloud mandatory for sensitive government data
  • Open source policy: French government directive to prefer open source

SecNumCloud Requirements (Key Points)

  • Provider must be headquartered in EU
  • No non-EU entity may have controlling interest
  • Data must remain in France/EU
  • Provider must not be subject to non-EU law that could compel data access
  • Rigorous technical security controls

Key Lessons

  • Certification creates market: SecNumCloud drives supplier investment
  • Explicit US exclusion: France explicitly states US law incompatibility
  • Hybrid models possible: S3NS shows US tech can be used under EU control
  • Political will essential: French government has been consistently assertive

Reusability

HIGH. SecNumCloud certification framework can be adopted or mutually recognised. French procurement language and technical requirements are directly reusable.

3. Germany: Bundescloud & Digital Sovereignty

Germany Case Study

Background

Germany operates the Bundescloud (Federal Cloud) for government workloads and has developed the BSI C5 certification for cloud security. German federal states (Länder) have significant autonomy, leading to varied approaches but consistent sovereignty concerns.

Key Actions Taken

  • Bundescloud: Federal government private cloud infrastructure
  • BSI C5 certification: Cloud security certification framework
  • Open source mandate: Schleswig-Holstein moving entirely to LibreOffice/Linux
  • Phoenix project: German federal open source collaboration suite
  • Gaia-X leadership: Germany co-leads European cloud initiative

Schleswig-Holstein Example

The German state of Schleswig-Holstein announced migration of 25,000 government PCs from Microsoft Windows/Office to Linux and LibreOffice:

  • Complete Microsoft Office → LibreOffice migration
  • Windows → Linux on all workstations
  • Nextcloud for file storage and collaboration
  • Open-Xchange for email
  • Jitsi/BigBlueButton for video

Key Lessons

  • State-level pilots work: Länder can pilot before federal adoption
  • Full desktop migration is feasible: Linux + LibreOffice viable for government
  • BSI C5 is rigorous: Certification framework is well-developed
  • Coordination challenges: Federal/state split creates complexity

Reusability

HIGH. BSI C5 can be mutually recognised. Schleswig-Holstein's desktop migration approach is directly replicable. Bundescloud architecture provides reference model.

4. Munich: LiMux Project (Lessons from Failure)

Munich Case Study (Cautionary)

Background

Munich's LiMux project (2004-2017) migrated 15,000 city workstations to Linux and LibreOffice. It was technically successful but politically reversed in 2017 when a new administration returned to Microsoft. This reversal is now itself being questioned, with Munich considering a return to open source.

What Went Right

  • Technically successful migration of 15,000 desktops
  • Significant cost savings (estimated €10M+)
  • Increased security and local control
  • Reduced vendor lock-in

What Went Wrong

  • Insufficient change management: User complaints amplified by opponents
  • Political vulnerability: New mayor reversed on ideological grounds
  • Legacy application issues: Some specialist apps required Windows
  • Microsoft lobbying: Aggressive vendor response including HQ relocation to Munich

Key Lessons

  • Technical success isn't enough: Political sustainability requires ongoing commitment
  • Change management is critical: User satisfaction determines political support
  • Vendor response will be aggressive: Expect significant pushback
  • Cross-party consensus helps: Single-party projects are vulnerable to reversal
  • Document benefits clearly: Cost savings must be visible and attributed

Reusability

MEDIUM. Technical approach remains valid. Lessons about change management and political sustainability are essential reading. The failure was political, not technical.

5. Switzerland: Federal Administration & Swiss Cloud

Switzerland Case Study

Background

Switzerland, while not EU, has strong data protection traditions and has developed sovereign cloud infrastructure. Swiss neutrality creates additional motivation for digital sovereignty.

Key Actions Taken

  • Swiss Government Cloud: Federal cloud infrastructure for government
  • Swiss hosting providers: Infomaniak, Exoscale, local providers preferred
  • Open source policy: Federal law requiring open source preference (2023)
  • Swiss data protection: Strong legal framework with US adequacy concerns

Swiss Providers

Provider Services Differentiator
Infomaniak Cloud, Mail, Collaboration Full Microsoft alternative suite
Exoscale IaaS, Kubernetes Developer-focused, S3-compatible
Proton Mail, VPN, Drive Privacy-focused, E2E encrypted

Key Lessons

  • Legal mandate helps: 2023 open source law creates obligation
  • Neutrality is motivator: Swiss sovereignty concerns parallel ours
  • Market exists: Swiss providers demonstrate viable alternatives

Reusability

MEDIUM-HIGH. Swiss approach is relevant for smaller jurisdictions. Proton and Infomaniak products could serve UK/EU governments directly.

6. Italy: Polo Strategico Nazionale

Italy Case Study

Background

Italy's Polo Strategico Nazionale (PSN - National Strategic Hub) is a €900M programme to consolidate government data into sovereign cloud infrastructure. Launched in 2022, it's one of the largest active sovereign cloud initiatives.

Key Actions Taken

  • PSN infrastructure: Four datacenters across Italy
  • ACN classification: National Cybersecurity Agency data classification
  • Mandatory migration: Government agencies required to migrate to PSN
  • €900M investment: Significant funding from Recovery and Resilience Plan

Technical Approach

  • Hybrid architecture: Italian infrastructure with some hyperscaler technology under Italian control
  • Data classification driving hosting decisions
  • OpenStack and Kubernetes foundation
  • Italian telecommunications consortium (TIM, Leonardo, etc.)

Key Lessons

  • Scale requires investment: €900M demonstrates required commitment
  • Mandates drive adoption: Compulsory migration overcomes inertia
  • Consortium model works: Multiple Italian companies cooperating

Reusability

MEDIUM-HIGH. PSN is still in implementation but architecture decisions and procurement approach are instructive.

Summary: Reusability Matrix

Precedent Reusability Key Reusable Elements When to Apply
Denmark HIGH Microsoft exit approach, education sector pilot, Nextcloud/LibreOffice stack Immediate: Office/email migration
France (SecNumCloud) HIGH Certification framework, procurement language, legal basis Phase 0-1: Framework establishment
Germany (Bundescloud) HIGH BSI C5 certification, desktop migration approach Phase 1-2: Infrastructure build
Munich (LiMux) MEDIUM Change management lessons, political sustainability Planning: Risk mitigation
Switzerland MEDIUM-HIGH Open source law, Swiss providers, privacy approach Phase 1+: Provider selection
Italy (PSN) MEDIUM-HIGH Consortium model, mandatory migration, investment scale Phase 2+: Scale-up

Engagement Strategy

Recommended approach to leveraging these precedents:

  1. Establish bilateral contacts
    Working-level relationships with Danish Datatilsynet, French ANSSI, German BSI, Swiss NCSC, Italian ACN
  2. Request documentation sharing
    Procurement frameworks, technical specifications, lessons learned documents
  3. Propose mutual recognition
    SecNumCloud, BSI C5, and NCSC Cloud Security Principles alignment
  4. Invite to working groups
    Denmark, Switzerland, and Italy as observer members of relevant working groups
  5. Joint procurement exploration
    Investigate joint procurement with France/Germany for common tooling

Sources & References

The precedent information in this document is based on the following verified sources:

Denmark

France (SecNumCloud)

Germany (Schleswig-Holstein)

European Commission

For complete source documentation, see the References & Sources page.

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