Evaluating AWS European Sovereign Cloud: A Checklist for Security Architects

Hook: Why security architects can’t treat "sovereign" as a checkbox

Security architects planning a migration to the AWS European Sovereign Cloud face a common, urgent problem: cloud marketing uses the word sovereignty liberally, but compliance teams and auditors want concrete controls, evidence, and mappings to GDPR, NIS2, DORA, and internal audit frameworks. If you’re evaluating a move to an EU-only AWS environment in 2026, this checklist maps technical controls to enterprise security requirements and audit controls so you can make a programmatic decision—not a guess.

Executive summary (most important first)

In early 2026 AWS announced the AWS European Sovereign Cloud: a physically and logically separate cloud region intended to address EU sovereignty concerns. For security architects, the evaluation is not just about data residency: it’s about legal protections, personnel access controls, cryptographic key ownership, service availability, and verifiable audit evidence for regulators and internal stakeholders.

Use the checklist below to map the new AWS sovereign controls to your security requirements and the audit controls your organization must produce. The checklist is organized by policy areas (data residency, access, cryptography, monitoring, legal/contractual, operations) and for each item provides: the control, how AWS typically implements it, what the enterprise must verify, and the audit evidence to collect.

Context: 2025–2026 trends that make this evaluation critical

• European digital sovereignty push: EU institutions and member states accelerated requirements around data localization, personnel access, and supply-chain transparency in late 2025—creating more demand for dedicated sovereign cloud environments in 2026.
• Regulatory consolidation: NIS2 and DORA enforcement is maturing; auditors expect demonstrable isolation controls and resilience plans for critical services.
• Legal scrutiny of cross-border access: After Schrems II-era rulings, organizations are more sensitive to foreign government access to cloud-hosted data, with auditors asking for contractual and technical mitigations.
• Operational expectations: Enterprises now expect turnkey integrations (IAM, logging, KMS, monitoring) in sovereign offerings; gaps create friction for migration and auditability.

How to use this checklist

Run this as a tabletop exercise with your cloud, security, legal, and compliance teams. For each checklist item decide: Accept / Mitigate / Reject. If you accept with mitigations, record the compensating controls and an evidence owner (tooling or person). Use the “Audit Evidence” column to collect artifacts before migration.

Checklist: Mapping AWS sovereign technical controls to enterprise requirements and audit controls

1. Data residency and physical/logical isolation

1. Control: Ensure data at rest and backups remain within the EU sovereign region and AZs cannot be replicated outside the sovereign domain.
   • AWS implementation: AWS describes the European Sovereign Cloud as physically and logically separate from other AWS regions and provides

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