| SOV-1 Strategic Sovereignty | SEAL-3 | |
| SOV-2 Legal & Jurisdictional Sovereignty | SEAL-2 | |
| SOV-3 Data & AI Sovereignty | SEAL-1 | |
| SOV-4 Operational Sovereignty | SEAL-3 | |
| SOV-5 Supply Chain Sovereignty | SEAL-3 | |
| SOV-6 Technology Sovereignty | SEAL-2 | |
| SOV-7 Security & Compliance Sovereignty | SEAL-1 | |
| SOV-8 Environmental Sustainability | SEAL-2 |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-1.1 | EU/EEA legal entity control | 4. Entirely within the EU | 125/125 | SEAL-4 | high | eu_entity (Hetzner Online GmbH, Gunzenhausen, no non-EU parent) -> entity control entirely within the EU, opt4. (src: https://docs.hetzner.com/general/company-and-policy/information-security-at-hetzner/) |
| SOV-1.2 | Change of control risk | 5. Very unlikely | 125/125 | SEAL-4 | medium | Privately held, founder-rooted German company (founded 1997 by Martin Hetzner), unfunded by external/VC capital and not publicly traded, making a non-EU takeover very unlikely. |
| SOV-1.3 | Control over roadmap | 3. Governance bodies exist with EU actors participation | 83/125 | SEAL-3 | medium | eu_entity with EU-actor feedback channels but informal governance -> governance/EU-actor participation, opt3. |
| SOV-1.4 | Financial independence from non-EU capital | 5. Entirely EU-based funding | 125/125 | SEAL-4 | medium | Self-funded, profitable German company with no external/non-EU investors; financing is entirely EU-based. |
| SOV-1.5 | EU economic contribution | 4. Majority in the EU | 94/125 | SEAL-4 | high | Workforce, HQ, R&D, and owned data centres are in Germany and Finland; the large majority of economic activity is in the EU though some colocation/revenue arises in the US and Singapore. |
| SOV-1.6 | Participation in EU strategic programs | 2. Limited participation | 31/125 | SEAL-4 | low | Positioned as an EU sovereign-cloud alternative and a recognised EU-native provider, but no documented formal participation in Gaia-X or IPCEI-CIS; participation is limited at best. |
| SOV-1.7 | Alignment with EU industrial strategies | 2. Existing action plan | 42/125 | SEAL-4 | low | Markets a 'made in Germany / European cloud' sovereignty proposition consistent with EU industrial goals, amounting to an action plan rather than measured, governed achievement. |
| SOV-1.8 | Resilience to cut-off | 5. Full autonomy and continuity | 125/125 | SEAL-4 | medium | own_stack (EU-owned data centres, EU staff, self-built hypervisor/control plane, can internalise) with residual foreign chips only -> full autonomy & continuity, opt5. |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-2.1 | Primary legal jurisdiction | 3. Exclusively EU law | 167/167 | SEAL-4 | high | German GmbH with EU-only corporate structure and EU/Finland data centres; service governed exclusively under EU/German law, opt3. (src: https://docs.hetzner.com/general/company-and-policy/information-security-at-hetzner/) |
| SOV-2.2 | Extraterritorial laws exposure | 4. Legal structures shielding from foreign law | 125/167 | SEAL-2 | medium | eu_entity German ownership shields the core, but a US subsidiary (Hetzner US LLC) operational nexus and no SecNumCloud/EUCS-High certified immunity -> legal structures shielding (not verified immunity), opt4 (CEIL seal 2). Real differentiator vs. the pure-DE anchors (STACKIT/SysEleven/T-Systems = opt5). |
| SOV-2.3 | Data access pathways for non-EU authorities | 5. Requests always rejected by the provider | 167/167 | SEAL-4 | high | No foreign_parent: purely German/EU-owned, not subject to US CLOUD Act/FISA or PRC law; foreign-authority requests have no legal basis over the parent and would be rejected, opt5. |
| SOV-2.4 | Export control restrictions | 5. Part of offer shielded from restrictions towards EU MSs/intl orgs | 167/167 | SEAL-4 | medium | Consistency with the German cohort: a pure-German EU IaaS provider with EU-based revenue and operations and no export-control restrictions toward EU member states or international orgs -> offer shielded toward EU MSs, opt5. |
| SOV-2.5 | Origin of IP | 4. Mostly within the EU | 125/167 | SEAL-4 | medium | Core software/hypervisor and operational IP are developed in-house in the EU; physical hardware/chip IP (Intel, NVIDIA, Ampere) is foreign, so IP is mostly but not fully EU-origin. |
| SOV-2.6 | IP holder jurisdiction | 5. Fully under EU law | 167/167 | SEAL-4 | high | The IP-holding entity is the German GmbH, fully under EU law, opt5. |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-3.1 | Customer control over encryption keys | 4. Customer primary control but provider can read data | 150/200 | SEAL-3 | low | Customers can encrypt their own volumes/data with their own keys; absent confidential-compute/HSM by default the provider operating the infrastructure could technically read unencrypted data, opt4. |
| SOV-3.2 | Transparent data flows & access logs | 4. Full customer-controlled visibility, not real-time | 150/200 | SEAL-3 | low | Consistency with the German C5 cohort: customer-accessible logging/access records plus annual TUV-audited TOMs under BSI C5 Type 2 give full customer-controlled visibility (real-time independent audit for opt5 not evidenced) -> opt4. |
| SOV-3.3 | Secure deletion & proof of erasure | 4. Deletion technically verified with access logs | 150/200 | SEAL-3 | low | Consistency with the German C5 cohort: under BSI C5 Type 2 / ISO 27001 secure-deletion controls, deletion is technically verified with access logs (no per-request cryptographic proof for opt5) -> opt4. (src: https://www.hetzner.com/news/hetzner-receives-bsi-c5-certification/) |
| SOV-3.4 | Data location strictly in EU/EEA | 4. EU by default, tightly controlled exceptions | 150/200 | SEAL-1 | high | No eu_exclusive guarantee (real differentiator vs. STACKIT/SysEleven/T-Systems): data is EU (Germany/Finland) by default with controlled exceptions, but US/Singapore exist as opt-in locations and there is no contractual no-third-country-fallback term -> EU-by-default, opt4 (CEIL seal 1). |
| SOV-3.5 | AI services sovereignty | 4. EU-led AI, foreign accelerators | 150/200 | SEAL-3 | medium | Consistency with the cohort (SysEleven/IONOS): AI is GPU IaaS (rent NVIDIA/Ampere hardware) on which customers run their own open-source/auditable models hosted in EU DCs; EU-led/customer AI on foreign accelerators -> opt4. |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-4.1 | Portability & interoperability | 4. Formal migration services available | 125/167 | SEAL-4 | medium | Standard documented data export plus REST API/CLI, Terraform/Ansible/Kubernetes integrations and snapshot/image migration with no proprietary lock-in formats, opt4. |
| SOV-4.2 | Ability to operate without foreign dependencies | 4. Ops predominantly EU-based teams | 125/167 | SEAL-3 | medium | eu_ops: infrastructure operated by Hetzner's own German technician teams; staff predominantly EU-based -> ops predominantly EU teams, opt4. |
| SOV-4.3 | Skill availability in the EU | 4. All EU staff | 125/167 | SEAL-3 | medium | Engineering and operations skills are concentrated in Germany; majority of staff EU-based with minor non-EU presence -> all/predominantly EU staff, opt4. |
| SOV-4.4 | Support channels | 4. All support staff in EU | 125/167 | SEAL-3 | medium | Support, including 24/7 cloud tickets, delivered by Hetzner's own technicians based in Germany; no documented security clearances -> all support in EU, opt4. |
| SOV-4.5 | Documentation & knowledge transfer | 4. EU-only primary repositories | 125/167 | SEAL-4 | low | Documentation and knowledge repositories maintained in-house in the EU (Hetzner Docs), primarily EU-only, opt4. |
| SOV-4.6 | Subcontractor & supplier jurisdiction | 4. Ability to source alternatives or internalise | 125/167 | SEAL-3 | low | own_stack: core suppliers/facilities EU-based; US/Singapore colocation non-critical to the EU offering and alternatives can be sourced or internalised, opt4. |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-5.1 | Origin of components (physical parts) | 3. Transparent with exceptions | 72/143 | SEAL-3 | medium | Consistency with the cohort: Hetzner builds its own servers and is transparent about sourcing; underlying foreign chips/parts (Intel, AMD, NVIDIA, Ampere) are disclosed with exceptions -> transparent with exceptions, opt3. |
| SOV-5.2 | Manufacturing location | 4. Built by EU teams on foreign design | 107/143 | SEAL-3 | medium | Hetzner builds/assembles its own servers in-house in Germany, but on foreign chip and component designs -> built by EU teams on foreign design, opt4. |
| SOV-5.3 | Embedded code/firmware provenance | 2. Partial disclosure | 36/143 | SEAL-4 | low | Firmware/microcode in CPUs, GPUs, NICs and BMCs comes from foreign vendors with only partial provenance disclosure, opt2. |
| SOV-5.4 | Origin of software | 4. Large majority maintained by EU teams | 107/143 | SEAL-3 | medium | No foreign_core: cloud control plane/hypervisor and management software developed and maintained in-house by EU teams; large majority of stack EU-maintained, opt4. |
| SOV-5.5 | Software build/release jurisdiction | 4. EU control & execution | 107/143 | SEAL-3 | medium | Software is developed, built and released under EU control and execution from Germany, opt4. |
| SOV-5.6 | Single point of dependency | 4. Few non-EU in non-critical services, documented | 107/143 | SEAL-3 | medium | Consistency with the own-stack German cohort (STACKIT anchor): self-built servers and in-house EU software/hypervisor in owned DCs mean the only non-EU dependency is substitutable commodity silicon as a non-critical hardware input, documented -> opt4 (few non-EU in non-critical, documented). |
| SOV-5.7 | Supply chain transparency | 4. Most suppliers auditable | 107/143 | SEAL-3 | low | Consistency with the German C5 cohort: under ISO 27001:2022 + BSI C5 Type 2 supplier-management scopes in its owned DCs, most suppliers are auditable beyond just the critical ones -> opt4 (most suppliers auditable). (src: https://www.hetzner.com/news/hetzner-receives-bsi-c5-certification/) |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-6.1 | Interoperability & open interfaces | 4. Standards-based and broadly compatible | 150/200 | SEAL-3 | medium | Standards-based, broadly compatible interfaces: REST API, CLI, and integrations for Terraform, Ansible and Kubernetes with portable images, opt4. |
| SOV-6.2 | Open standards compliance | 3. Partial core adoption | 100/200 | SEAL-2 | medium | Adopts common open standards/protocols (KVM virtualization, S3-compatible object storage, standard Linux images) across core services -> partial core adoption, opt3. |
| SOV-6.3 | Open source availability | 2. Source available for review, strict rights | 50/200 | SEAL-2 | medium | No foreign_core but control plane/hypervisor proprietary and closed; Hetzner supports open-source workloads but does not open-source its own platform -> source-available/closed, opt2. Genuine differentiator vs. the OpenStack-based cohort (STACKIT/SysEleven/T-Systems open-source their core). |
| SOV-6.4 | Service architecture transparency | 3. Some public insight | 100/200 | SEAL-3 | low | Some public architecture insight via extensive docs and status pages, but the core hypervisor platform is deliberately kept private, opt3. |
| SOV-6.5 | HPC sovereignty | 2. EU-hosted, foreign stack | 50/200 | SEAL-3 | medium | GPU/HPC offering is EU-hosted (Germany/Finland) but runs an entirely foreign accelerator stack (NVIDIA, Intel) -> EU-hosted, foreign stack, opt2. |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-7.1 | Security certification (EAL) | 4. EAL3 | 107/143 | SEAL-3 | medium | ISO/IEC 27001:2022 + BSI C5:2020 Type 2. Per the answer-key cert->EAL map, BSI C5 is a high-assurance EU/national cloud certification mapping to EAL3 (opt4 'EAL3', seal 3); applied identically to the German cohort (STACKIT anchor scored opt4 on BSI C5) -> opt4. (src: https://www.hetzner.com/news/hetzner-receives-bsi-c5-certification/) |
| SOV-7.2 | EU regulatory compliance (GDPR/NIS2/DORA) | 5. Fully compliant to all, independently audited | 143/143 | SEAL-4 | high | GDPR-compliant with Art. 28 DPA, ISO/IEC 27001:2022 and BSI C5 Type 2, designated KRITIS/NIS-2 operator, with TOMs independently audited annually by TUV Rheinland. |
| SOV-7.3 | EU-based SOC & incident handling | 4. Entire lifecycle by EU teams, EU threat intel | 107/143 | SEAL-3 | medium | Security operations and incident response handled by Hetzner's own EU-based teams in Germany; no documented ENISA/CSIRT real-time sharing -> EU lifecycle, opt4. |
| SOV-7.4 | Control over security monitoring/logging | 4. Full direct access, logs stored in EU | 107/143 | SEAL-3 | low | Customers get direct access to their own monitoring and logs and audit reports, with infrastructure logs stored in EU data centres; no immutable tamper-proof claim -> full access EU-stored, opt4. |
| SOV-7.5 | Disclosure of incidents | 4. Partial compliance, monitored flow, SLAs | 107/143 | SEAL-3 | medium | As an NIS-2/KRITIS operator and GDPR processor it follows monitored breach-disclosure flows with SLAs; not documented as full real-time CSIRT sharing, opt4. |
| SOV-7.6 | Maintenance autonomy | 4. High autonomy (deploy independently, no checks) | 107/143 | SEAL-4 | low | Hetzner controls its own maintenance and can deploy patches independently on its self-built stack without third-party vendor scheduling, opt4. |
| SOV-7.7 | Auditability | 2. Limited independent access | 36/143 | SEAL-1 | medium | No audit_rights (real differentiator vs. the awarded sovereign offers): assurance only via ISO 27001, C5 Type 2 and TUV audits; no contractual full independent audit of the proprietary platform by the contracting authority/any EU body -> limited independent access, opt2 (CEIL seal 1). (src: https://www.hetzner.com/news/hetzner-receives-bsi-c5-certification/) |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-8.1 | Energy efficiency (PUE) | 4. PUE < 1.3 | 188/250 | SEAL-4 | high | Reported average PUE of 1.13 (range ~1.10-1.16), comfortably below 1.3, though not independently EU-verified below 1.2 across all sites, opt4. (src: https://www.hetzner.com/unternehmen/nachhaltigkeit) |
| SOV-8.2 | Hardware reuse & recycling | 3. Documented program | 125/250 | SEAL-3 | low | Documented sustainability practices including hardware reuse and energy efficiency, amounting to a documented program rather than EU-certified circular lifecycle, opt3. |
| SOV-8.3 | Environmental impact reporting | 3. Annual report | 125/250 | SEAL-2 | low | Publishes sustainability information and CO2-reduction figures at roughly annual-report level, not an independently EU-audited methodology, opt3. |
| SOV-8.4 | Energy supplies | 5. Only green EU energy supplies | 250/250 | SEAL-4 | high | Energy is exclusively renewable EU supply: hydropower in Germany since 2008 and hydro/wind in Finland since 2018, with own solar/storage build-out via HT clean Energy GmbH. (src: https://www.hetzner.com/unternehmen/nachhaltigkeit) |