Overview
France has decided to stop treating “digital sovereignty” like a slogan and start treating it like a risk register.
At the first Rencontres de la souveraineté numérique on 26 January 2026, Minister for Digital and AI Anne Le Hénanff launched two practical instruments: the Observatoire de la souveraineté numérique (entrusted to the Haut-commissariat à la Stratégie et au Plan) and the Indice de résilience numérique (IRN), a private-sector initiative chaired by Olivier Sichel of the Caisse des Dépôts.
The Minister’s framing was unusually direct: “La souveraineté commence par la lucidité… Nous devons savoir d’où et de quoi nous dépendons” (Sovereignty begins with clear-sightedness… We must know where and on what we depend).
Reference: French Government Press Release, 26 January 2026; Haut-commissariat à la Stratégie et au Plan announcement
What France Is Actually Building
1. A National Dependency Map
The Observatory’s mandate is to produce the first comprehensive diagnostic of France’s digital dependencies—across cloud, AI, data infrastructure, and software—by surveying both public and private sector organisations. A national questionnaire launched in late January 2026, with initial findings expected by spring 2026.
Clément Beaune, President of the Haut-commissariat, outlined a triple mission: diagnose critical dependencies, provide decision-support tools for public and private procurement, and inform policy direction on digital sovereignty.
Reference: Haut-commissariat à la Stratégie et au Plan, January 2026
2. A Board-Level Resilience Dashboard
The IRN is designed to measure dependencies “à 360°” across eight dimensions, as presented at the Bercy launch event. These encompass:
- Software (logiciels)
- Data (données)
- Infrastructure (infrastructures)
- Technological assets (actifs technologiques)
- Internal capabilities (compétences internes)
- Governance (gouvernance)
- Shock resistance (résilience aux chocs)
- Supply chain and subcontracting exposure (chaîne de sous-traitance and exposition extraterritoriale)
As IT for Business reported from the event: presenters discussed eight dimensions but worked to translate them into blocks understandable by an executive committee—making this explicitly a “Comex-compatible” tool rather than a technical audit.
The methodology combines four quantitative criteria measuring information system independence at three scales (national, European, extra-European) with qualitative assessments covering contracts, suppliers, data localisation, migration capability, open technologies adoption, and vendor diversification.
The explicit link to business continuity makes this a governance tool, not just a technical assessment. The initiative will also enable organisations to benchmark against NIS2 obligations, creating a compliance pathway that doubles as a strategic planning exercise.
Reference: IT for Business, “Indice de résilience numérique (IRN): le thermomètre pour gouverner ses dépendances,” January 2026; Banque des Territoires; Caisse des Dépôts announcement; RTE press release, July 2025
3. Procurement as the Enforcement Mechanism
Once dependencies can be measured and scored, embedding those criteria into procurement becomes inevitable. France is already signalling this direction—Senator Dany Wattebled noted that €600 million in public procurement currently flows to US hyperscalers, and a Senate proposal (passed unanimously in December 2025) would require all public contracts to be protected from extraterritorial laws via SecNumCloud-certified solutions.
Reference: Banque des Territoires; French Senate records, December 2025
The Economic Catalyst: €264-265 Billion Annually
France’s initiative is politically powered by a stark economic finding. The Asterès study commissioned by Cigref (April 2025) quantified European digital dependency:
- 80-83% of European spending on professional cloud software and services flows to US companies
- This represents approximately €264-265 billion annually—comparable to Europe’s energy import bill
- The outflow supports an estimated 2 million jobs in the United States
The study’s methodology combined CIO interviews from major French companies with market data, finding that large enterprises allocate roughly 2.2% of turnover to cloud software services, with 83% going to US providers.
Reference: Asterès, “Technological Dependence on American Software and Cloud Services: An Assessment of the Economic Consequences in Europe,” April 2025 (commissioned by Cigref and Numeum)
Why This Is a Cyber Resilience Story
Cyber resilience in 2026 means more than detect-respond-recover. The strategic question is now:
Can you maintain operations when a critical supplier becomes unavailable, constrained, or economically punitive—even without an attacker in sight?
France’s approach aligns precisely with the EU’s regulatory trajectory, which is systematically embedding resilience requirements across supply chains, products, and critical infrastructure.
The Regulatory Convergence
NIS2 Directive: Member States were required to transpose by 17 October 2024. As of late 2025, only 14 Member States had fully completed transposition, with the European Commission issuing reasoned opinions to 19 Member States (including Germany, France, Ireland, and Spain) in May 2025 for non-compliance. The Directive drives risk management and supply-chain security expectations across 18 critical sectors.
Reference: European Commission NIS2 Directive page; Goodwin Law analysis, October 2025
Cyber Resilience Act (CRA): The timeline is now concrete:
- Entered into force: 10 December 2024
- Vulnerability reporting obligations: 11 September 2026
- Full application: 11 December 2027
From September 2026, manufacturers of “products with digital elements” must report actively exploited vulnerabilities within 24 hours and severe incidents within 72 hours. This applies to products already on the market—legacy products are not exempt from reporting requirements.
Reference: European Commission Digital Strategy, CRA Reporting page; CRA Summary, January 2026
AI Act: Entered into force 1 August 2024, with phased implementation:
- Prohibited practices and AI literacy: 2 February 2025
- GPAI model obligations: 2 August 2025
- Full application for most obligations: 2 August 2026
- High-risk AI in regulated products: 2 August 2027
AI deployment intensifies dependency on compute infrastructure, platforms, and model supply chains—making exit options and multi-sourcing increasingly valuable.
Reference: European Commission AI Act page; European Parliament implementation timeline
The European Parliament’s Assessment
A 2025 study from the ITRE Committee (Committee on Industry, Research and Energy) explicitly connects software dependence to strategic vulnerability:
“US firms dominate all major software layers, exposing Europe to strategic vulnerabilities.”
Key findings include:
- Cloud: Three US hyperscalers (AWS, Microsoft Azure, Google Cloud) control approximately 70% of the European market
- Enterprise software: Around 80% of EU corporate spending flows to US vendors (Microsoft, Oracle, Salesforce, IBM); SAP is the only major European player
- Consumer platforms: Android/iOS command virtually 100% of mobile OS; Windows holds 73% of desktop OS; Google exceeds 89% of web search
- Government IT: Public administrations remain heavily dependent on Microsoft ecosystems
Reference: European Parliament ITRE Committee, “European Software and Cyber Dependencies,” Study PE 778576, 2025
Geopolitical Acceleration: Why France Won’t Stay Alone
The macro environment is pushing toward bloc logic: more industrial policy, more trade instruments, more localisation pressure. Two recent developments make it rational to expect other European states to follow France’s direction.
1. Digital Services Enter the Retaliation Toolkit
The EU’s Anti-Coercion Instrument (ACI), adopted in November 2023 but never yet deployed, explicitly covers services, investments, and public procurement access. In the context of escalating US tariff tensions through 2025, the ACI has been characterised as a “nuclear option” that could target US digital giants including Amazon, Microsoft, Netflix, and Uber.
The ACI allows the EU to:
- Impose restrictions on trade in services (including through EU subsidiaries)
- Limit access to public procurement
- Restrict intellectual property protections
- Block foreign direct investment
While deployment remains politically sensitive (and would likely trigger US retaliation), the fact that digital services are now explicitly part of retaliation modelling transforms dependency into leverage.
Reference: CNBC, “How Europe’s ‘trade bazooka’ could be a last resort against Trump’s tariffs,” July 2025; PIIE analysis, April 2025; Euronews explainer, January 2026
2. The Revised Cybersecurity Act Targets “High-Risk Suppliers”
On 20 January 2026—just days before France’s sovereignty summit—the European Commission proposed a revised Cybersecurity Act that would:
- Create a horizontal framework for trusted ICT supply chain security across 18 critical sectors
- Enable the EU and Member States to jointly identify and restrict “high-risk” third-country suppliers
- Make the voluntary 5G Security Toolbox measures binding, enabling mandatory phase-out of high-risk equipment
- Extend restrictions beyond telecoms to energy systems, transport, data centres, connected vehicles, and security equipment
The proposal does not name specific companies, but builds on longstanding concerns over Chinese technology firms (particularly Huawei and ZTE) and signals that dependency is now treated as a security variable, not merely a market choice.
Reference: European Commission Cybersecurity Package, 20 January 2026; EEAS announcement; Euronews coverage
Forward Predictions for 2026-2030
1. Sovereignty Metrics Become Procurement Requirements
Once scoring mechanisms exist, procurement naturally becomes the enforcement layer. Expect tender requirements to increasingly request:
- Dependency mapping documentation
- Data portability guarantees
- Subprocessor transparency
- Jurisdictional exposure assessments
- Realistic exit support commitments
2. “Exit Readiness” Becomes a Board KPI
Vendor lock-in transitions from a finance complaint to a resilience metric. Boards will ask not just “what does this cost?” but “how long until we can operate without this vendor?”
3. Cyber Resilience and Tech Sovereignty Merge
CRA and NIS2 compliance pressure will pull dependency management into auditable, evidence-based governance processes. The distinction between “cybersecurity compliance” and “digital sovereignty” will blur as both require the same underlying capabilities: supply chain visibility, incident reporting, and supplier governance.
4. Other Member States Will Follow
Germany is already accelerating its own digital sovereignty initiatives. The playbook France is establishing—measure, score, shift procurement, harden supply chains—is the path of least political resistance for any European government seeking a defensible stance on critical infrastructure protection.
What Organisations Should Consider
This is not a call to rip-and-replace existing technology stacks. Abrupt changes based on policy headlines create more risk than they mitigate.
However, France’s move should be treated as an early indicator of a hardening European direction. Prudent risk management includes asking:
- Concentration risk: Which suppliers, if disrupted by outage, cyber incident, legal constraint, or commercial shock, would materially affect operations?
- Jurisdictional exposure: Which dependencies could be affected by foreign legal or political changes—including extraterritorial laws like the US CLOUD Act?
- Switching realism: If a provider change became necessary, could it be accomplished within business-relevant timeframes? Or is the dependency effectively permanent?
- Regulatory trajectory: For organisations in regulated sectors, could CRA/NIS2-style requirements make “dependency evidence” a hard compliance requirement rather than a best practice?
Assess Your Own Position
For organisations looking to understand where they currently stand, CyberSolace has developed a Digital Resilience Self-Assessment directly based on the IRN model. This tool allows leaders to quickly identify where their strategic digital dependencies lie and where they may need attention—without waiting for formal regulatory requirements to arrive.
Taking a structured self-assessment now serves two purposes: it builds internal awareness of dependency risks before they become urgent, and it positions the organisation to respond more quickly as European procurement and compliance expectations evolve.
The goal is not immediate action. The goal is avoiding surprise—because in cyber and geopolitics, surprises are expensive and usually public.
Bottom Line
France is operationalising a straightforward idea: dependency should be measured, priced, and reduced where it creates unacceptable risk. The French government’s framing is explicit—reduce dependence to strengthen “resilience.”
Given the direction of geopolitics (more coercion instruments, more regulatory requirements, more supplier-risk policy), more European states will adopt this approach. Not because they’ve all become economic nationalists overnight, but because concentrated single-vendor dependence is now recognised as an avoidable strategic vulnerability.
In 2026, the organisations that thrive will be those that can demonstrate resilience—not just in their incident response capabilities, but in their structural independence from suppliers who might become unavailable, unaffordable, or unacceptable.
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