True data sovereignty isn’t where it’s kept, but who has access to it

Regulated industries have been dealing with the equivalent of sovereign data for a long time. And as the geopolitical situation makes it more broadly relevant, it doesn’t make it any easier to deal with.

From concerns about the reach of the US CLOUD Act and what telemetry or sensitive business data gen AI models might collect, to implications of the US government taking part ownership of a range of technology companies and the impact of EU regulations, the state of the world means more organizations need to think about where data is located.

The result is a flood of announcements from hyperscalers about new EU cloud regions, as well as pitches from regional and private cloud providers. The promised sovereignty may be anything from a local availability zone to more sophisticated approaches to ownership structure, compliance frameworks, where logs are stored, or where support staff work.

Actual data sovereignty involves legal, technical, contractual, governance, and infrastructure questions, but all too often, what’s on offer is what IDC research director Rahiel Nasir calls sovereignty washing. “When you look under the lid, all they’re really offering is a solution for data residency and data localization, keeping data in country,” he says. “That’s part of sovereignty, but not all of sovereignty.”

In his experience, in-country data centers are the first thing organizations ask for to support data localization and data residency, but they also require enhanced controls over identity and access management. That’s critical because data sovereignty is as much about who has access to the data and why, as where it lives.

“It’s really important the only people who touch my data in what is supposedly a sovereign cloud environment are those I give permission to,” he adds. “Because it’s my data, and I’m the only one who can give the authority to grant access to it. That also applies to support and admin staff.”

Companies want control through where they store data but also to restrict how users can interact with it that might expose that information outside an approved environment or jurisdiction, adds Acceldata SVP Ali Afsar.

Access and control

Don’t confuse the regulatory requirements of data residency with data sovereignty, Scality CMO Paul Speciale warns. “Residency is about geography,” he says. “Sovereignty is about control, jurisdiction, and who ultimately has the legal authority to access data.”

For CIOs, the question is no longer simply where the data is but who can access it, who controls the encryption keys, under which legal framework it operates, and can that control be proven. That includes being able to show who accesses data, from where, and for what purpose, which requires verifiable controls like jurisdiction-aware data placement, immutable backups, tightly governed admin access, and clear audit trails.

The UK government’s recent call for evidence on the impact of international data flows on sovereignty makes this explicit, referring to transfer by access where personal data remains in the UK but is accessed from overseas, including by a user located in another country. Access transfers include administrative access, backups, disaster recovery, support incidents and sometimes — depending on the specific regulations — processing the data.

GDPR doesn’t mean data has to stay in the EU but it does require data to be protected to EU standards wherever it goes. Data transfer obligations for other jurisdictions can be far more restrictive, so multinational organizations may need access controls limiting who can see what regulated data from different locations.

RBI-regulated payment-system data, for instance, must be stored in India, but can be processed outside India, Afsar explains, as long as it’s deleted from overseas systems within 24 hours. And with limited exceptions, personal data in Saudi Arabia must be processed within the Kingdom, and China treats overseas access to some categories of data stored in China as a cross-border data activity. Russian laws require similar strict data localization, and personal data of Russian citizens has to be stored, processed, and kept within the country’s borders at all times, which is why LinkedIn was blocked there.

Elsewhere, regulations are most restrictive for specific markets like healthcare, financial, and public services. Not everything needs to be transferred to a sovereign cloud, Nasir points out, as use of that data is subject to regulatory compliance, and the increasing need for AI training.

“This is the data that’s going to have catastrophic business impacts if leaked,” he says. “To give enhanced controls and security for that data, you’d consider wrapping sovereign controls around it. Everything else not subject to compliance nor sensitive data can be accessed by whomever you want and from wherever.”

Sovereignty and safety

Organizations typically know data sovereignty rules well but still experience incidents like data breaches, government data access requests, and unauthorized cross-border transfers caused by, for example, traveling employees or excessive admin access, according to Kiteworks’ 2026 Data Security and Compliance Risk report.

“Location only tells a regulator where the data rests, not who can still reach it,” says Kiteworks’ EMEA GM Dario Perfettibile. “Every real exposure we’ve seen so far happens through access not geography.”

Thinking data needs to stay in region because then it’s safe gives a false sense of security if practiced as a substitute for proper data management. Access, data labelling, and retention polices take more work but are what can prevent incidents. “If you have a data policy in place, it can force a reapproval of the access,” he adds. “It can restrict access to you only, or it can block you out immediately.”

Location isn’t everything

Using a service closer to home doesn’t automatically make any of that easier. “Many organizations still assume sovereignty can be achieved by moving data from one cloud provider to another, or by replacing one hyperscaler with another,” says Keepit Group CISO Kim Larsen. “That misses the bigger picture.” CIOs should treat sovereignty as an operational capability not a compliance exercise, he adds, since sovereignty isn’t about scale or ownership of infrastructure for its own sake, but maintaining control.

“If an organization doesn’t know who can access its data, which legal frameworks govern that access, or whether it can recover its data independently, simply changing where the servers are located does little to reduce risk,” he says.

Just because something is based in your region doesn’t automatically make it a good choice. The EC, for instance, has set up accounts on W Social, an independent social media platform based on the AT protocol designed for data mobility and user migration, which Bluesky uses but is hosted in Europe.

The Commission’s own open source strategy suggests open source promises more control over digital infrastructure by avoiding vendor lock in, and a recent policy brief positions digital sovereignty as a form of digital independence. But having servers in the EU isn’t the same as freedom of digital movement since unlike Eurosky, based in Europe and using the same protocol, W limits interoperability so it can require identity verification, and has closed its source code after security researchers pointed out vulnerabilities.

Most organizations will continue to use both global and local providers, though they might prioritize what Nasir called glocal options built on partnerships between the two. “Organizations want to use a mixture of local and global providers,” he says. “They want all the innovation capabilities that the Microsofts, AWSs, and Googles of the world give us, that they consider local providers can’t match.”

IDC figures suggest only 4% of European organizations plan to switch to purely local options. “We can’t live without US technology today and there’s no appetite to do that,” says Nasir. Availability matters and local providers may not have the same level of infrastructure as global options. They can offer low hanging fruit like video conferencing solutions, but not more complicated directory and database services, or productivity software that’s intertwined with those US-provided services.

Choices about where to store data, and the technical controls to enforce that, have their own operational implications.

“Redundancy and resiliency are key tenets of sovereignty,” he adds. “You want to make sure your operations are always available. In order to enable that, you want to spread the risk.”