| SOV-1 Strategic Sovereignty | SEAL-2 | |
| SOV-2 Legal & Jurisdictional Sovereignty | SEAL-2 | |
| SOV-3 Data & AI Sovereignty | SEAL-0 | |
| SOV-4 Operational Sovereignty | SEAL-3 | |
| SOV-5 Supply Chain Sovereignty | SEAL-1 | |
| SOV-6 Technology Sovereignty | SEAL-3 | |
| SOV-7 Security & Compliance Sovereignty | SEAL-1 | |
| SOV-8 Environmental Sustainability | SEAL-0 |
| 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 (French SAS, registered Nanterre/Boulogne-Billancourt; since Feb 2026 a wholly-owned subsidiary of Mistral AI, French) -> entity control entirely within the EU -> opt4 (src: https://www.koyeb.com/blog/koyeb-is-joining-mistral-ai-to-build-the-future-of-ai-infrastructure). |
| SOV-1.2 | Change of control risk | 5. Very unlikely | 125/125 | SEAL-4 | medium | Owned by Mistral AI, France's flagship sovereign-AI champion building a European AI cloud; transfer to a non-EU sovereign entity is very unlikely -> opt5 (all-seal-4 factor, existing choice kept). |
| SOV-1.3 | Control over roadmap | 2. Through 'voice of the customer' public channels | 42/125 | SEAL-2 | low | Commercial PaaS/Mistral subsidiary; roadmap influence is via product feedback / voice-of-customer, no formal EU multi-stakeholder governance body over the roadmap -> opt2 (seal 2). |
| SOV-1.4 | Financial independence from non-EU capital | 4. Majority of funding is EU-based | 94/125 | SEAL-4 | medium | Pre-acquisition funding from French VCs (Serena, ISAI); now backed by Mistral AI, majority EU-funded though with some non-EU investors -> majority EU funding -> opt4 (all-seal-4 factor, existing choice kept). |
| SOV-1.5 | EU economic contribution | 4. Majority in the EU | 94/125 | SEAL-4 | medium | Engineering team and HQ in France, joining Mistral's EU engineering division; economic contribution majority in the EU with some global revenue -> opt4 (all-seal-4 factor, existing choice kept). |
| SOV-1.6 | Participation in EU strategic programs | 3. Active participant in strategic projects | 63/125 | SEAL-4 | medium | Through Mistral AI, part of an explicitly European sovereign AI-cloud initiative; active participant rather than named lead of formal programs -> opt3 (all-seal-4 factor, existing choice kept). |
| SOV-1.7 | Alignment with EU industrial strategies | 3. Measured achievement and dedicated governance | 83/125 | SEAL-4 | medium | Mistral/Koyeb position the combined offering around Europe's sovereign full-stack AI cloud with dedicated investment and stated governance -> opt3 (all-seal-4 factor, existing choice kept). |
| SOV-1.8 | Resilience to cut-off | 4. Ability to source alternatives or internalise key functions | 94/125 | SEAL-2 | low | No own_stack: PaaS runs on bare-metal/colo incl. US partner Vultr (32 global regions), a real non-EU operational dependency, but stack is open source (Nomad/Firecracker/Kuma) and EU-built and could be re-sourced/internalised -> 'ability to source alternatives' opt4 (seal 2), not full autonomy (src: https://www.koyeb.com/blog/partnering-with-vultr-for-serverless-and-global-ai-deployments). |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-2.1 | Primary legal jurisdiction | 3. Exclusively EU law | 167/167 | SEAL-4 | high | ToS/MSA governed by French law with French jurisdiction; contracting entity is a French SAS -> contract exclusively under EU law -> opt3 (seal 4) (src: https://www.koyeb.com/blog/koyeb-is-joining-mistral-ai-to-build-the-future-of-ai-infrastructure). |
| SOV-2.2 | Extraterritorial laws exposure | 4. Legal structures shielding from foreign law | 125/167 | SEAL-2 | medium | Pure-FR entity under a French parent (no US/foreign parent) gives legal structures shielding from foreign law, but immunity is not certified (no SecNumCloud/EUCS-High) -> opt4 'legal structures shielding' (seal 2), not opt5 verified immunity. |
| SOV-2.3 | Data access pathways for non-EU authorities | 5. Requests always rejected by the provider | 167/167 | SEAL-4 | medium | No foreign_parent: French SAS with French parent is not subject to US CLOUD Act/FISA/PRC law and has no legal basis to comply with non-EU compelled-access orders, so such requests would be rejected -> opt5 (seal 4). |
| SOV-2.4 | Export control restrictions | 3. Share of revenues >50% in the EU | 84/167 | SEAL-2 | low | No EU-facing export restrictions on a French provider; global customer base means the relevant tier is EU revenue share rather than a formally shielded offer -> opt3 (seal 2). |
| SOV-2.5 | Origin of IP | 4. Mostly within the EU | 125/167 | SEAL-4 | medium | Core orchestration/platform IP (serverless engine integrating Nomad/Firecracker/Kuma) developed by the French team; underlying OSS components and chips originate partly outside the EU -> IP mostly within the EU -> opt4 (all-seal-4 factor, existing choice kept). |
| SOV-2.6 | IP holder jurisdiction | 5. Fully under EU law | 167/167 | SEAL-4 | medium | Proprietary platform IP held by the French SAS (now Mistral, French) -> IP holder fully under EU law -> opt5 (seal 4). |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-3.1 | Customer control over encryption keys | 2. Primarily provider, not exclusively | 50/200 | SEAL-1 | low | Managed PaaS with platform-managed encryption at rest; customer-managed/BYOK key control is not the default -> keys primarily provider-controlled -> opt2 (seal 1). |
| SOV-3.2 | Transparent data flows & access logs | 3. Logs exist but not real-time / vendor-controlled | 100/200 | SEAL-2 | low | Logging/observability exists but data-flow and access logs are vendor-controlled and not independently real-time auditable by the customer -> opt3 (seal 2). |
| SOV-3.3 | Secure deletion & proof of erasure | 3. Internal validation per policy, no proof | 100/200 | SEAL-1 | low | GDPR/DPA commits to deletion of customer data per policy on termination, but no published independently-verified proof-of-erasure -> internal validation per policy -> opt3 (seal 1). |
| SOV-3.4 | Data location strictly in EU/EEA | 2. Partly EU, significant third-country reliance | 50/200 | SEAL-0 | high | NOT eu_exclusive: operates US (Washington DC, San Francisco), Singapore and Tokyo regions and partners with US provider Vultr (32 global regions); EU regions exist but the offer has significant third-country reliance -> opt2 'partly EU, significant third-country reliance' (seal 0). Genuine SEAL-0 gate, not shared with the EU-exclusive members; not inflated per directive (src: https://www.koyeb.com/blog/partnering-with-vultr-for-serverless-and-global-ai-deployments). |
| SOV-3.5 | AI services sovereignty | 4. EU-led AI, foreign accelerators | 150/200 | SEAL-3 | medium | AI offering centres on deploying EU-origin/open-source models (notably Mistral's) on the platform -> EU-led AI, but inference runs on foreign accelerators (Nvidia/AMD) -> opt4 (seal 3). |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-4.1 | Portability & interoperability | 3. Standard documented data export methods | 84/167 | SEAL-4 | medium | Supports OCI/container images, Git- and Docker-based deploys and standard data export -> documented portability -> opt3 (seal 4). |
| SOV-4.2 | Ability to operate without foreign dependencies | 4. Ops predominantly EU-based teams | 125/167 | SEAL-3 | medium | eu_ops: engineering team is France-based and joining Mistral's EU engineering org -> operations predominantly EU-based teams -> opt4 (seal 3). |
| SOV-4.3 | Skill availability in the EU | 4. All EU staff | 125/167 | SEAL-3 | medium | Core engineering staff EU-based (France); no evidence of security clearances -> all-EU staff -> opt4 (seal 3). |
| SOV-4.4 | Support channels | 3. Majority in EU, non-EU escalations | 84/167 | SEAL-3 | low | Support by a small EU-based team with some community/global support -> majority-EU support with possible non-EU escalation -> opt3 (seal 3). |
| SOV-4.5 | Documentation & knowledge transfer | 3. EU primary with non-EU fallback | 84/167 | SEAL-4 | low | Documentation served via global CDN, authored by the EU team -> EU-primary with non-EU/global fallback -> opt3 (seal 4). |
| SOV-4.6 | Subcontractor & supplier jurisdiction | 3. Continue temporarily per contractual agreement | 84/167 | SEAL-3 | low | Reliance on some non-EU bare-metal/colo partners (e.g. Vultr); a supplier cut-off allows temporary continuation while re-sourcing rather than full autonomy -> opt3 (seal 3). |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-5.1 | Origin of components (physical parts) | 2. Partial disclosure | 36/143 | SEAL-1 | low | Hardware uses AMD/Intel/Nvidia/Tenstorrent components; provenance disclosed only partially via vendor names, no full bill-of-materials -> opt2 (seal 1). |
| SOV-5.2 | Manufacturing location | 2. Foreign origin, partial disclosure | 36/143 | SEAL-1 | medium | Servers and chips manufactured outside the EU (US/Asia fabs) with only partial disclosure; no EU manufacturing -> opt2 (seal 1). |
| SOV-5.3 | Embedded code/firmware provenance | 2. Partial disclosure | 36/143 | SEAL-4 | low | Server firmware/BIOS from foreign hardware vendors; provenance at best partially disclosed -> opt2 (all-seal-4 factor, existing choice kept). |
| SOV-5.4 | Origin of software | 4. Large majority maintained by EU teams | 107/143 | SEAL-3 | medium | No foreign_core: platform software (serverless engine, orchestration) is built and maintained by Koyeb's EU team atop open-source components -> large majority EU-maintained -> opt4 (seal 3). |
| SOV-5.5 | Software build/release jurisdiction | 4. EU control & execution | 107/143 | SEAL-3 | low | Build/release controlled and executed by the EU-based engineering team; no documented certified policy gates -> EU control and execution -> opt4 (seal 3). |
| SOV-5.6 | Single point of dependency | 3. Few non-EU in critical services / documented | 72/143 | SEAL-2 | medium | Dependence on non-EU vendors for critical compute (US partner Vultr, foreign chips), documented via partnerships but affecting critical infrastructure -> few non-EU in critical services -> opt3 (seal 2). |
| SOV-5.7 | Supply chain transparency | 2. Some suppliers auditable | 36/143 | SEAL-1 | low | Supply chain (chip vendors, colo/bare-metal partners) only partially auditable; some suppliers named, no comprehensive supplier-audit program -> opt2 (seal 1). |
| 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: OCI containers, HTTP/gRPC, Git/Docker workflows and documented APIs -> broadly portable -> opt4 (seal 3). |
| SOV-6.2 | Open standards compliance | 4. Policy for most core services | 150/200 | SEAL-3 | medium | Core services rely on open standards (OCI, HTTP, TLS, standard networking) across most core services -> opt4 (seal 3). |
| SOV-6.3 | Open source availability | 3. Open source, centralised governance | 100/200 | SEAL-3 | medium | Heavy use of open-source (Firecracker, Nomad, Kuma) and deploys open-source models, but the Koyeb control-plane/orchestration code is proprietary with centralised governance -> open source, centralised governance -> opt3 (seal 3). |
| SOV-6.4 | Service architecture transparency | 4. Large corpus of public insight | 150/200 | SEAL-3 | medium | Publishes a large corpus of detailed engineering blog posts/docs on the serverless architecture (Nomad/Firecracker/Kuma) -> large corpus of public insight -> opt4 (seal 3). |
| SOV-6.5 | HPC sovereignty | 2. EU-hosted, foreign stack | 50/200 | SEAL-3 | low | GPU/HPC capacity uses foreign accelerators (Nvidia/AMD) on a foreign hardware/software stack, hosted and operated in EU (and other) regions -> EU-hosted, foreign stack -> opt2 (seal 3). |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-7.1 | Security certification (EAL) | 1. EAL0 / none | 0/143 | SEAL-1 | medium | No SecNumCloud and no Common Criteria EAL certification documented; ISO 27001/SOC 2 not evidenced as held -> effectively EAL0/none -> opt1 (seal 1). No SecNumCloud-IaaS basis, so not inflated per directive. |
| SOV-7.2 | EU regulatory compliance (GDPR/NIS2/DORA) | 4. Partial compliance to most | 107/143 | SEAL-4 | medium | GDPR-compliant processor with a DPA; partial compliance to most relevant EU regimes, no evidence of full DORA/NIS2 audited compliance -> opt4 (all-seal-4 factor, existing choice kept). |
| SOV-7.3 | EU-based SOC & incident handling | 2. Hybrid EU/non-EU | 36/143 | SEAL-1 | low | Small EU company with global regions and a US infrastructure partner; security operations/incident response likely a hybrid EU/non-EU function -> opt2 (seal 1). |
| SOV-7.4 | Control over security monitoring/logging | 3. Basic monitoring portal | 72/143 | SEAL-1 | low | Customers get a monitoring/observability portal with logs/metrics, but not full direct access to immutable EU-stored security logs by default -> opt3 (seal 1). |
| SOV-7.5 | Disclosure of incidents | 3. Moderate (GDPR/NIS2-aligned) | 72/143 | SEAL-2 | low | GDPR-bound EU processor; incident disclosure is GDPR/NIS2-aligned (moderate) without documented real-time CSIRT sharing -> opt3 (seal 2). |
| SOV-7.6 | Maintenance autonomy | 3. Moderate autonomy (notice + testing, except zero-day) | 72/143 | SEAL-4 | low | Koyeb controls its own platform maintenance with notice/testing windows; emergency/zero-day patches may apply without prior notice -> moderate autonomy -> opt3 (seal 4). |
| SOV-7.7 | Auditability | 2. Limited independent access | 36/143 | SEAL-1 | low | No audit_rights: independent auditability limited to certification-body audits; customers cannot freely conduct independent audits -> limited independent access -> opt2 (seal 1). |
| ID | Factor | Value | Score | SEAL | Conf. | Justification |
|---|---|---|---|---|---|---|
| SOV-8.1 | Energy efficiency (PUE) | 2. PUE < 3 | 63/250 | SEAL-1 | low | Koyeb does not publish its own PUE; runs on third-party/colo data centres of varying efficiency -> conservative PUE<3 tier -> opt2 (seal 1). |
| SOV-8.2 | Hardware reuse & recycling | 2. Basic circular practices | 63/250 | SEAL-0 | low | No published hardware reuse/recycling program; basic circular practices inherited from colo/hardware providers at most -> opt2 (seal 0). |
| SOV-8.3 | Environmental impact reporting | 2. Basic reporting | 63/250 | SEAL-1 | low | No detailed environmental-impact reporting published; only basic/indirect reporting via underlying providers -> opt2 (seal 1). |
| SOV-8.4 | Energy supplies | 3. Mix of EU and non-EU supplies | 125/250 | SEAL-4 | low | EU and non-EU (US, APAC) regions on third-party data centres; energy supply is a mix of EU and non-EU sources without a published renewable-only guarantee -> opt3 (all-seal-4 factor, existing choice kept). |