Severability of Non-EU Network Connections (BSI C3A test)
Why important?
Full severability of third-country connections is hard, verifiable evidence of sovereignty (BSI C3A).
How measured?
Scale 0–5 + N/A:
- 0 = Operation not possible without ongoing non-EU connections (telemetry/control plane/updates necessarily non-EU).
- 1 = High dependency on non-EU connections; cutting them would severely impair operations.
- 2 = Partial severability; relevant non-EU dependencies remain.
- 3 = Non-EU connections largely severable; operations remain essentially functional.
- 4 = All non-EU connections severable without significant impact on operations.
- 5 = Full severability without impact on operations, demonstrated by an annual test (analogous to BSI C3A).
- N/A = no reliable evidence
Sources / Evidence
Validation questions (RFP)
- Which network connections exist to sites or services outside the EU (control plane, updates, support, telemetry, licence servers)? Can operations continue if all of these connections are cut, and for how long? Has severability been tested, for example as part of a BSI C3A test, and can the result be inspected?
Scores comparison
| Provider | Score | |
|---|---|---|
| AWS European Sovereign Cloud | 3.0 | ESC explicitly designed for independent, indefinite operation; critical non-EU infrastructure dependencies are to be avoided. Annual C3A separation test pending. (stated) |
| IONOS Cloud | 3.0 | Operated in DE (United Internet), data centres in DE; no documented non-EU control plane. C3A test pending. (stated) |
| STACKIT | 3.0 | 100% Schwarz ownership, own DE/AT data centres; no non-EU control plane documented. C3A test pending. (stated) |
| OVHcloud Public Cloud (inkl. SecNumCloud) | 3.0 | EU company, own data centres and own backbone; SecNumCloud scope. C3A test pending. (stated) |
| Oracle EU Sovereign Cloud | 3.0 | EU sovereign realm without explicit/implicit connections to other realms (stated). C3A test pending. (stated) |
| pluscloud open | 3.0 | Self-operated core services, OSS; EU/DE. C3A test pending. (stated) |
| Exoscale | 3.0 | Operated in EU/CH (A1); no documented non-EU control plane. C3A test pending. (stated) |
| Hetzner Cloud | 3.0 | Fully operated in the EU (DE/FI), no non-EU control plane; structurally high separability. C3A test pending. (stated) |
| Scaleway | 3.0 | Operated in FR, SecNumCloud in progress; no non-EU control plane documented. C3A test pending. (stated) |
| noris Sovereign Cloud | 3.0 | SCS/OSS, independent of hyperscalers, operated in DE. C3A test pending. (stated) |
| SysEleven OpenStack Cloud | 3.0 | SCS/OpenStack, operated in DE; no non-EU control plane. C3A test pending. (stated) |
| Cloud Temple Trusted Cloud | 3.0 | SecNumCloud requires immunity from non-EU law/access; operated in EU/FR. C3A test pending. (stated) |
| Infomaniak Public Cloud | 3.0 | Operated in CH, OpenStack; no documented non-EU dependencies. C3A test pending. (stated) |
| T Cloud Public | 2.0 | EU-only operations targeted, but Huawei hardware dependency (firmware/lifecycle) limits full separability. (partial) |
| UpCloud | 2.0 | Global footprint (non-EU sites exist); EU DCs can in principle be operated independently. (partial) |
| Delos Cloud | 2.0 | Dependency on Azure software/licensing/updates (non-EU); continuation agreement claimed, but not evidenced. (mixed) |
| Microsoft Sovereign Cloud | 1.0 | US hyperscaler with global control plane/telemetry; the EU Data Boundary does not sever non-EU connections. (high risk) |