Digital sovereignty: Best practices from strategy to compliance

Overview - Contents of the article:
Best practices for decision-makers | Best practices for IT & security | Best practices for administration | Lectures on the subject

This is not about achieving technological self-sufficiency or eliminating external providers entirely. Digital sovereignty means having the ability to adapt technological decisions in response to changing conditions. Problems arise when data, systems or investments can no longer be controlled.

Digital sovereignty is closely linked to traditional IT security protection goals. If organizations cannot control where their data is processed, which jurisdiction it is subject to or how dependent their operational capability is on individual providers, then confidentiality, integrity and availability are at risk not only technically, but also politically and legally.

Therefore, modern IT security strategies must be expanded beyond firewalls, encryption, and access controls to include issues of jurisdiction, third-party access, and long-term operational capability. Modern IT strategies therefore focus on operational capability. Companies must ensure that data, processes, and dependencies remain controllable in the event of regulatory conflicts, market changes, or problems with providers.

From buzzword to practical implementation strategy

This development is driven by technological, regulatory and geopolitical factors. European organizations are faced with the challenge of combining innovation with the requirements of EU legal frameworks, such as the GDPR and the DORA. At the same time, questions about foreign authorities' access to data, extraterritorial legislation and structural dependencies on non-European platform providers are coming into sharper focus.

Digital sovereignty is defined as the ability to use modern IT and cloud technologies without losing control over security- and regulatory-sensitive aspects. A simple organizing principle can help to achieve this. In practice, it manifests itself on three interrelated levels:

• Strategic: controllability of risks and investments
• Technological: Operational capacity to act
• Regulatory: Trust and compliance.
   

Best practices for strategists and decision-makers: Making sovereignty controllable

At management level, digital sovereignty begins with transparency, not technology. Dependencies rarely arise consciously. They usually grow gradually through budget decisions, architectural specifications and short-term efficiency gains. To ensure sovereignty, these dependencies must be made visible and controllable.

These pose not only a business risk, but also a security risk. If business-critical systems or sensitive data depend entirely on individual providers or jurisdictions, regulatory conflicts, sanctions or political tensions could directly affect the availability of systems and the protection of sensitive information. 

1. Make sovereignty measurable by calculating the proportion of IT expenditure that can be used flexibly.

Technological lock-ins often arise in the budget rather than the architecture. Investments in platforms, licenses and integrations accrue over many years, making a later change increasingly unlikely. 

Therefore, it is helpful to have a simple metric showing what proportion of IT spending goes into solutions that are difficult to change and what proportion goes into systems that are comparatively easy to replace or operate with other providers. This reveals where dependencies are growing and where investments in flexibility are being made consciously.

Effect: Digital sovereignty becomes a controllable management variable rather than a purely technical detail.

2. Geopolitical layering for critical systems

Cloud and platform strategies are usually developed with cost and innovation as the primary considerations. Political and legal risks, however, often play a secondary role until they suddenly become relevant. 

A sustainable approach is to deliberately distribute critical workloads, data sets and backups across different legal and geopolitical areas, as well as at least one environment that can operate independently. This creates an architecture that is not wholly dependent on a single legal area, market or regulatory environment.

In addition to providing regulatory resilience, this approach also enhances security-related availability. Even if a provider, legal jurisdiction, or region fails, business-critical processes will remain operational. At the same time, the risk of sensitive data being subject to a single, potentially foreign jurisdiction is reduced.

Effect: Organizations become more resilient to sanctions, trade conflicts, regulatory interventions and sudden market restrictions.

3. Ensuring AI governance and model sovereignty

Using AI creates new dependencies. Business processes based on external AI models can change quickly due to factors such as new prices, altered terms of use or restricted access.

In the case of sensitive data or security-relevant decision-making processes in particular, questions also arise regarding data leakage, traceability and regulatory control. Compliance and security requirements may also be violated if models are operated in uncontrollable environments or if the training data is unclear.

Digital sovereignty when dealing with AI therefore means that important use cases should not depend entirely on external, proprietary models. Where possible, companies should be able to switch to alternative, openly available or self-operated models, particularly for central processes.

Effect: Companies retain their ability to act, even when market conditions or the rules of the AI ecosystem change.

In conclusion, strategic sovereignty does not mean operating every technology yourself. It means having real choices at all times, rather than only realizing in a crisis that there are no alternatives.

Best practices for IT and security: Ensuring sovereignty through architecture

Strategic guidelines alone are insufficient. The decisive factor is whether systems can be rebuilt or replaced in an emergency. This reveals whether architectural decisions enable long-term action or create new dependencies. Technical sovereignty therefore means one thing above all else: interchangeability as a conscious design principle.

Technical sovereignty is not an alternative to IT security, but rather an extension of it. While traditional security measures protect systems against attacks, digital sovereignty aims to reduce structural dependencies that can themselves pose a security risk in the event of a crisis.

1. Define infrastructure independently of providers

Many cloud environments appear flexible but are, in fact, closely tied to the specifics of individual platforms. Proprietary services, specific configuration logics or manual setups make switching considerably more difficult.

A key best practice is to describe infrastructure based on open or common standards. The goal is to create an environment that can be rebuilt with minimal effort at different providers or in-house. The important thing is not that everything is identical, but that it is possible to rebuild.

Effect: The infrastructure becomes reconfigurable instead of hardwired, providing strategic flexibility.

2. API abstraction for decoupling external services

Business-critical applications are often directly connected to external services for communication, data processing or identity functions, for example. If such a service changes, becomes restricted or is discontinued, it has an immediate impact on the application.

This issue can be resolved by creating proprietary interfaces or abstraction layers between the application and external services. The application only accesses the internal interface, meaning that the underlying service can be replaced or supplemented as needed without affecting the core logic.

Effect: Changing providers or adjusting services becomes an integration project rather than requiring complete redevelopment.

3. Transparency in the software supply chain through automated SBOM checks

Most modern software consists of a large number of third-party components. Without transparency regarding these dependencies, security and compliance risks can arise that often only become apparent in an emergency.

An effective approach is to automate the collection and verification of SBOMs throughout the development and deployment processes. This enables known vulnerabilities, outdated components or undesirable dependencies to be identified at an early stage.

Effect: Organizations can then gain control over their software supply chain and reduce the risk of unnoticed third-party dependencies.

4. Design robust and independent identities

Identity is the key to almost all digital systems. If access to this is completely dependent on a single central service, a critical dependency arises.

This dependency is particularly critical in the context of modern zero-trust architectures: if identity services fail or are restricted by regulations, even functioning specialist applications cannot be used. Sovereign identity architectures not only increase resilience, but also directly ensure operational availability.

Sovereign identity solutions rely on multiple combinable access paths. The goal is to ensure that logging in and assigning rights do not depend on a single external service and continue to function reliably in the event of disruptions, failures or provider issues.

Effect: Access and working capability are maintained even in exceptional situations.

Technical sovereignty is not reflected in how modern a platform is, but rather in whether systems can be replaced. Architecture thus becomes the central lever of digital capability.

Best practices for administration and compliance: Demonstrating sovereignty

Digital sovereignty is not just about strategy and architecture. In regulated areas and the public sector in particular, it must be verifiable. Rather than just claiming to, companies must be able to demonstrate that they actually have control over their data, systems, and dependencies.

European regulations such as NIS2 and DORA, as well as industry-specific security requirements, are increasingly requiring organizations to make their dependencies, supply chains and operating models transparent and controllable, including from a security perspective.

Therefore, regulatory sovereignty means transparency, traceability, and verifiable standards above all else.

1. Open-source and standard-oriented procurement

Public institutions and highly regulated organizations are challenged by the need to avoid long-term reliance on tax revenues or critical budgets. Proprietary solutions that lack transparency regarding their functionality and future development can pose a structural risk.

A proven approach is to consistently consider solutions based on open standards or with accessible source code. This does not necessarily mean operating in-house, but it does ensure that further development, maintenance or changing providers does not depend exclusively on a single manufacturer.

Effect: Long-term control over technological foundations instead of permanent structural dependency.

2. Enforcing the limitation of data use for specific purposes

Many regulatory requirements, particularly in the context of data protection or data ecosystems, demand clear limitations on the use of data. In practice, however, this is often only regulated at an organizational level and rarely secured technically.

Sovereign data architectures address this issue by anchoring purpose limitation directly in the system logic. Data access is linked to clearly defined roles, contexts and purposes. Once the purpose has expired or changed, access can be restricted or revoked technically.

Effect: Not only is compliance documented, it is also implemented systemically, in the sense of true 'compliance by design'.

3. Regular sovereignty and compliance audits

Self-assessments are insufficient for sensitive areas. Trust is created when security and sovereignty measures are reviewed based on recognized criteria.

Regular audits of critical systems help identify risks early on and present your situation to regulatory authorities, partners and the public in a clear manner. These audits cover not only IT security, but also data handling, dependencies on providers and organizational controllability.

These audits support not only compliance, but also the continuous evaluation of security-relevant dependencies, such as those on individual cloud providers, critical service providers, or proprietary security services.

Effect: Digital sovereignty becomes verifiable and thus a reliable factor of trust.

In conclusion, digital sovereignty only becomes a reality when it exists not only technically, but also in a verifiable way. Transparency and verifiable standards form the basis for this.

Digital sovereignty is not a decision, but a capability

It does not arise from a single technological choice or from completely foregoing external providers. In a networked digital world, cooperation is inevitable, but dependence should always have an alternative.

In this sense, digital sovereignty becomes an extended security discipline. It considers threats not only from attackers, but also from structural risks relating to technological, legal and geopolitical dependencies.

Organizations that actively manage this dimension will not only increase their resilience, but also strengthen the confidentiality, integrity and availability of their systems in the long term.

The essence of digital sovereignty is the ability to choose. Organizations can act independently when they are aware of their dependencies, have prepared alternatives and have designed their architecture in such a way that changes are possible. This ability manifests itself on several levels:

• Strategic: investments are consciously managed and risks are made visible.
• Technical: when systems remain flexible, replaceable and rebuildable.
• Regulatory: control, security and compliance are verifiable.

Digital sovereignty is therefore less a target state and more a continuous discipline. It requires the regular reassessment of dependencies, architectural decisions and regulatory requirements. Those who actively shape this process gain resilience and long-term freedom to innovate.

Ultimately, an organization's sovereignty is demonstrated not by which provider it uses, but by its ability to switch providers without losing its ability to act.