RFP Template: Procuring a European Sovereign Cloud Provider (AWS EU Case)

Stop guessing—get a procurement-ready RFP for a European sovereign cloud (AWS EU case)

Procurement and security teams in European businesses face hard trade-offs: meet strict data sovereignty rules, avoid hidden legal exposure, and still move quickly to modern cloud platforms. The 2026 wave of sovereign cloud offerings—most notably AWS’s Independent European Sovereign Cloud—changes vendor expectations. This RFP template and playbook tells you exactly what to ask, how to score responses, and what contractual assurances to demand.

Why this RFP matters in 2026

Two immediate pressures shape cloud procurement today:

• Regulatory tightening: NIS2, DORA, and evolving EU data governance rules (and ongoing EDPB guidance) mean buyers must prove technical and contractual controls, not just intent.
• Product evolution: Major clouds now offer independent EU regions with separate control planes and new legal assurances (AWS announced an independent European Sovereign Cloud in Jan 2026). Procurement must translate those features into binding contract language and verification steps.

“AWS launched the AWS European Sovereign Cloud in 2026 to meet EU sovereignty requirements—physically and logically separate from other regions with sovereign assurances.” — industry reporting, Jan 2026

How to use this document

This is a practical, ready-to-use RFP template with:

• Sections and sample language tailored to European data sovereignty
• Specific questions mapped to legal assurances and technical controls
• Scoring matrix and minimal acceptance criteria
• Proof-of-concept (POC) and contract clause recommendations

Executive summary (RFP intro)

Use this text block at the top of your RFP to set expectations:

Objective: Select a cloud provider that can host regulated EU data with demonstrable technical separation, contractual sovereign assurances, and verifiable auditability to meet EU regulatory, privacy, and security requirements.

Scope: Infrastructure-as-a-Service (IaaS), managed platform services, identity and key management, and optional managed security services. Initial scope includes customer production and backup data for EU operations, excluding public test data.

Minimum mandatory requirements (must-have checklist)

Vendors must answer YES/NO and provide evidence. Non-compliance with any must-have disqualifies the bid.

1. Data residency: All customer data (at rest and in backups), metadata, and logs stored within EU sovereign cloud regions. Evidence: region identifiers, account mappings.
2. Control plane separation: Logical and operational separation of control plane from non-EU regions. Evidence: architecture diagrams; third-party assessment.
3. Legal entity and governing law: An EU-based legal entity as the data controller/processor with contracts subject to EU law. Evidence: signed commitment, entity registration.
4. Access controls: Human access to customer data limited to EU-based personnel under EU contractual terms. Evidence: HR policies, access logs, role maps.
5. Audit rights: Right to audit, request logs, and receive independent third-party SOC/ISO and EU-specific certifications. Evidence: sample audit report sections, certificates.
6. Breach notification: Contractual breach notification within 72 hours and a dedicated EU escalation path. Evidence: SLA section in draft contract.
7. Encryption & keys: Customer-controlled encryption keys (BYOK or CCKMS) with keys stored in EU-only HSMs. Evidence: key management diagram and KMS location.

Detailed RFP sections and sample questions

1. Compliance & legal assurances

What to request and why.

• Provide the full list of applicable EU regulations and certifications you meet (GDPR, NIS2, DORA applicability, ISO 27001, ISO 27701, ISO 27018, SOC 2, EUCS/EUCC compliance status).
• Confirm the legal entity that will sign customer contracts and your willingness to accept EU jurisdiction for disputes.
• State your approach to international legal process (e.g., handling of third-country law requests). Provide template language you will accept committing to challenge extraterritorial requests and to deny access unless compelled under EU law.

Expected response (acceptance criteria): Vendor provides EU entity commitment, an explicit clause limiting non-EU access except under narrow, documented circumstances, and audit evidence of enforcement.

2. Technical architecture & separation

Key questions:

• Provide an architecture diagram showing physical locations, network segmentation, and control plane boundaries for the EU sovereign cloud.
• Explain how control plane and management systems are logically and operationally isolated from non-EU regions.
• Detail cross-region replication controls and options to keep backups within EU-only regions.

Expected response: Clear diagrams, proof of logical separation, and controls to enforce EU-only replication.

3. Data access, personnel controls & human access

• List all personnel roles with potential access to customer data. For each role, describe nationality/location restrictions and background checks.
• Detail privileged access management (PAM), just-in-time access, session recording, and approval workflows.
• Explain use of bifurcated admin models (EU-only support rotation) and how non-EU support can be blocked.

Expected: Role-by-role mapping, enforced EU staffing for critical functions, and recorded approvals for any exception with customer notification.

4. Encryption & key governance

• Confirm support for Customer-Managed Keys (BYOK) stored in EU HSMs and the process for key revocation/destruction.
• Describe envelope encryption, in-transit and at-rest encryption, and TLS configurations.
• State whether the provider can perform cryptographic escrow for compliance or eDiscovery scenarios and under what legal conditions.

Expected: BYOK, EU HSMs, and contractual commitment that provider cannot access plaintext without authorized EU legal request and customer approval.

5. Monitoring, logging & auditability

• Provide log retention controls, log export options, and locations for logs and telemetry.
• Detail audit APIs, frequency of independent audits, and how customers receive audit artifacts.
• Confirm access to raw logs for regulators and your standard incident response playbook aligned to GDPR/NIS2 timelines.

Expected: APIs for logs, EU storage of logs, and pre-approved audit artifacts delivered within contractual timelines.

6. SLA, availability & resilience

• Define SLAs for availability, data durability, and RTO/RPO targets within EU regions.
• Describe cross-Availability Zone and cross-Region resilience patterns that remain within EU jurisdictions.
• State financial remedies for SLA violations and processes for emergency failover.

7. Pricing, TCO & migration support

• Provide detailed pricing models including data egress costs, inter-region replication, KMS charges, and audit fees.
• Itemize migration support offerings, professional services rates, and a 90-day migration plan with milestones and acceptance criteria.

8. Proof-of-Concept & acceptance criteria

• Define a 30–90 day POC scope: host sample workloads, demonstrate control-plane separation, execute a simulated cross-border access request, and perform a customer-led audit.
• List deliverables: architecture review, SOC/ISO artifacts, KMS demo, access log exports, and incident simulation report.

Contract clauses to request (sample language)

Include these clauses or strong equivalents in your procurement contract.

• Data Residency & Processing Clause: "Provider shall process and store Customer Data solely within the EU sovereign cloud regions identified in Exhibit A. Any transfer outside the EU requires prior written consent and documented legal basis."
• Control Plane & Access Limitations: "Provider shall maintain logical separation of control plane infrastructure for EU sovereign regions and limit human operator access to personnel employed by the Provider's EU legal entity, subject to Customer's prior written consent for exceptions."
• Challenge & Notification of Third‑Country Requests: "Provider will challenge extraterritorial government access requests to Customer Data and will notify Customer within 48 hours of any request to access Customer Data by a non‑EU authority, unless legally prohibited. Provider will provide the legal basis for any compelled disclosure."
• Audit & Certification Rights: "Customer shall have the right to receive independent third‑party audit reports and, upon reasonable notice, perform audits of Provider's controls relevant to Customer Data."
• Key Management: "Customer retains full control over encryption keys used to protect Customer Data. Provider shall not access or use Customer keys except at Customer's explicit instruction."

Scoring matrix (sample weights & thresholds)

Use this scoring grid to evaluate vendors quantitatively.

• Compliance & Legal Assurances — 30% (pass threshold: 24/30)
• Security & Controls (technical) — 25% (pass: 20/25)
• Operational Resilience & SLA — 15% (pass: 12/15)
• Pricing & TCO — 10% (pass: 8/10)
• POC Results & Migration Support — 10% (pass: 8/10)
• Roadmap & Vendor Stability — 10% (pass: 8/10)

Minimum overall score to progress to contracting: 80/100.

Red flags that should stop procurement

• No EU legal entity to accept contract and liability for data processing.
• Inability to demonstrably isolate control plane and key management within the EU region.
• Refusal to grant reasonable audit rights or deliver independent verification artifacts.
• No BYOK or customer key control options.
• Unclear or unlimited cross-border replication by default.

2026 trends that affect your RFP

Procurement teams should be aware of these market shifts:

• Sovereign cloud mainstreaming: By 2026 multiple hyperscalers and specialized vendors launched independent EU offerings. Expect providers to compete on legal assurances and EU control-plane separation—not just latency or pricing.
• Tighter regulator scrutiny: Regulators are now requesting technical proof during supervisory audits. Your RFP must require artifacts, not just statements of compliance.
• Contractual certainty demand: Buyers no longer accept public marketing claims; they insist on binding contractual commitments with penalties for non‑compliance.
• Cryptographic sovereignty: Demand for customer-controlled keys and in-region HSMs is now a procurement baseline for regulated sectors.

Practical procurement playbook — step by step

1. Issue RFP with a 3–4 week response window. Require mandatory evidence in initial submission to reduce review time.
2. Shortlist 3 vendors and run a 30–90 day POC focused on control-plane separation, KMS, and a simulated regulator request scenario.
3. Perform an independent legal review of proposed contract language and escalate red-line issues early.
4. Use the scoring matrix, but weight contractual/legal assurances higher for regulated workloads.
5. Require a signed SOC/ISO attestation and a clause committing to give customers audit artifacts on demand for supervisory checks.

Example evaluation scenario (finance sector)

For a mid‑sized financial firm subject to DORA and GDPR:

• Compliance & legal assurances carry 40% weight.
• Provider must agree to EU courts as dispute forum and accept fining exposure under contract.
• POC must include a simulated access request and demonstration that keys and logs remained in EU limits.

Actionable takeaways

• Do not rely on vendor marketing—require artifacts and include binding legal commitments enforceable in EU courts.
• Make control-plane separation and key sovereignty mandatory requirements, not optional features.
• Build POCs that test real-world legal scenarios (e.g., external access request) and verify provider behaviour under pressure.
• Score vendors with legal/compliance highest for regulated workloads—price savings do not offset legal exposure.

Closing: how to move from RFP to contract

Use this template as the baseline for immediate RFP issuance. After vendor selection, follow with a focused negotiation that locks in the legal assurances and audit artifacts you relied on in scoring. Expect negotiation cycles around access to data, key control, and dispute resolution—these are non‑technical but mission‑critical.

Need assistance? If you want an editable version of this RFP, a custom scoring matrix for your sector (DORA, healthcare, public sector), or help running the POC and legal review, contact an expert procurement advisor with EU cloud experience.

Call to action

Download the editable RFP template and sample contract clauses, or schedule a 30‑minute consultation to tailor this template to your risk profile and regulatory obligations. Move procurement from risky assumptions to contractual certainty—start now.

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