87% of German companies say the “sovereign” offerings of international providers do not give them enough transparency about how data is processed and who can access it. That is not a vendor problem. It is a proof problem — and about ten questions fix it.
The figure comes from the Bitkom Cloud Report 2026, published on 17 June 2026, based on a representative survey of 603 German companies with twenty or more employees. It sits next to a better-known number from the same report: 85% consider Germany too dependent on providers from the United States. The second one got the headlines. The first one is more useful, because it points at something a buyer can actually act on.
The word stopped carrying information
Every large vendor now has a sovereign product line. The offerings are real, in the sense that work went into them. What almost none of them provide is a way for the person buying to check the claim themselves.
Read the three figures above together and a pattern appears that is worth stating carefully. There is large, self-declared, unmet demand — 91% want something 53% have. And a substantial minority, 43%, have concluded that no equivalent European alternative exists at all. Some of that is a genuine supply gap. Some of it is that the alternatives are hard to evaluate, so they do not register as alternatives.
One more figure from the same report sharpens the point: 87% want protection against unauthorised access by the cloud provider itself. No contract can deliver that. A commitment not to look is a commitment; an architecture in which looking is not possible is a property. The gap between those two is where this whole discussion lives.
The ten questions
Group them the way a review actually runs: jurisdiction, then the data path, then access, then exit. Every one of them should be answerable with an artefact — a document, a capture, a completed run — rather than a reassurance.
Jurisdiction
Who is legally in charge
- 1. Which legal entity operates the service, and under which country's law? Follow the ownership chain to the top. A local subsidiary does not always change the answer.
- 2. Which foreign authority could compel disclosure, under which statute? Ask the vendor to name the mechanism rather than deny the possibility.
- 3. What is the vendor's policy and history on government data requests? A transparency report, or an explanation of why there isn't one.
The data path
Where things actually go
- 4. What outbound network connections does the software make? Ask for a packet capture from a running instance, not a datasheet claim. For software you run yourself, you can do this without the vendor's help.
- 5. Where is data at rest, and who holds the encryption keys? If the vendor holds the keys, encryption at rest protects you from a stolen disk, not from the vendor.
- 6. What components does the software ship, and can you see that inventory? A machine-readable list of the third-party libraries included in a release. Reviewers use it to check for known vulnerabilities without waiting for a bulletin.
Access and integrity
Who can touch it, and is it what they published
- 7. Can you verify a release is the one the vendor published? Signed releases let you check that what you installed is what they shipped, unaltered in transit.
- 8. Who at the vendor can technically access customer data, and what prevents it? Distinguish “we have a policy” from “there is no path.”
- 9. What are the log retention periods, and who set them? If nobody can say, the answer is “indefinitely,” and someone will eventually have to explain that.
Exit
The question nobody tests
- 10. What happens on the day you cancel? Export format, how long a full export takes, what is not included, and how long the vendor retains your data afterwards. Ask them to run the export during the evaluation.
What a good answer looks like
Good answers are boring, specific, and often qualified. “Our web tier makes no outbound connections; the model connector makes one, to the endpoint you configure, and here is a capture showing it” is a good answer. So is “we can’t demonstrate that in our hosted service, but here is what we can show instead” — because it is honest about the limit.
Evasive answers have a texture too. They restate the certification when asked a technical question. They answer a different, easier question — residency when you asked about jurisdiction. They promise a document after signature. And they treat the request as unusual, which after this survey it plainly is not.
Where self-hosting is not the answer
It would be convenient to end by saying that running the software yourself resolves all ten. It resolves several — questions 4, 5, 8 and 10 change character entirely when nobody else has an account on the system — but it is genuinely the wrong choice in some situations, and pretending otherwise would fail the same honesty test this article is asking of vendors.
If your organisation has no one who owns infrastructure, self-hosting converts a vendor risk into an operational one, and an unpatched system you control is worse than a maintained system you do not. If the workload is bursty and enormous, someone else’s elasticity is a real advantage. And if the content genuinely carries no confidentiality weight — public documentation, marketing material — the sovereignty question is close to moot, and spending a review cycle on it is effort better spent elsewhere.
The point of the checklist is not to arrive at a predetermined answer. It is that after ten questions you know what you are choosing, which is more than 87% of the market currently gets.
Frequently asked questions
What exactly did the Bitkom Cloud Report 2026 find?
It surveyed 603 German companies with 20 or more employees and was published on 17 June 2026. Headline findings: 85% consider Germany too dependent on US cloud providers (up from 78%); 37% would use a Germany-only cloud even at the cost of features or price; 64% of cloud users feel US government policy is forcing them to rethink their cloud strategy; 98% say the provider's country of origin matters; and 87% say the sovereign offerings of international providers lack sufficient transparency about data processing and access rights.
Isn't a compliance certificate enough?
A certificate tells you an auditor checked a set of controls at a point in time, which is genuinely useful. It does not tell you what the software does on your network this afternoon. The two are complementary: certificates for the organisational picture, artefacts for the technical one. Problems arise when a certificate is offered as an answer to a technical question.
Our vendor says they can't show a network capture for security reasons. Is that reasonable?
For a hosted service, partly — you cannot capture traffic inside infrastructure you do not control, and that limitation is itself informative. For software you run yourself there is no such obstacle: you can capture the traffic without the vendor's cooperation at all. If a vendor of installable software refuses to discuss its outbound connections, that is a finding rather than a policy.
Does this checklist only apply to AI systems?
No. It applies to any system that holds your documents or data. AI tools raise the stakes because they typically touch a broader slice of internal content than a single line-of-business application, and because they often introduce a new outbound connection to a model provider that did not exist before.
What if we're too small to run a technical review like this?
Then run the four that need no specialist: which entity operates it and under whose law, what happens to your data the day you cancel, how long a full export takes, and who at the vendor can see your data. Those four are answerable in plain language by any vendor acting in good faith, and they surface most of the risk.
Sources & further reading
- Bitkom — Cloud Report 2026 (press release, 17 June 2026) — 603 German companies, 20+ employees; the 85%, 87%, 91/53 and 43% figures
- Bitkom — Cloud Report 2026 (full study) — methodology and the full question set
- Bitkom — Kriterien für Cloud-Souveränität in Europa — industry criteria for what sovereignty should mean in practice