An Overview to the EU Cloud Code of Conduct

As data privacy expectations continue to rise, organizations operating in the cloud are facing growing pressure to prove compliance with the EU’s General Data Protection Regulation (GDPR). For cloud service providers (CSPs), one of the most relevant and practical ways to demonstrate that compliance is through the EU Cloud Code of Conduct—a voluntary, sector-specific framework designed specifically for the cloud industry.

What Is the EU Cloud Code of Conduct?

The EU Cloud Code of Conduct (EU Cloud CoC) is a GDPR-backed framework established under Article 40 of the GDPR. It allows organizations to be assessed against a standardized set of rules that translate GDPR obligations into clear, operational requirements for cloud providers.

The framework is overseen by Scope Europe, an independent body that manages and verifies adherence. Once approved, organizations are listed on the public EU Cloud CoC registry, signaling compliance and transparency to customers and regulators alike.

The Code is designed exclusively for data processors in the cloud ecosystem, covering IaaS, PaaS, and SaaS providers.

EU Cloud Code of Conduct: Key Requirements and Structure

The EU Cloud Code of Conduct is divided into two main sections:

1. Section 5: Administrative Controls: Focuses on governance and management aspects, such as defining privacy roles and responsibilities, staff training, and oversight practices.

2. Section 6: Technical and Security Controls: Covers the privacy and security measures cloud providers must implement, many of which align closely with existing frameworks like ISO 27001, ISO 27701, and SOC 2.

This structure makes it straightforward for organizations already following established standards to align with the EU Cloud CoC without reinventing their compliance approach.

Why the EU Cloud Code of Conduct Matters

Since GDPR took effect in 2018, CSPs worldwide have faced ongoing inquiries about their compliance posture. The EU Cloud CoC provides one of the few approved, recognized mechanisms to formally demonstrate GDPR compliance, reducing the administrative burden of repeated assessments and inquiries.

• Reduced GDPR-related follow-ups and data protection inquiries
• Improved readiness for new privacy and regulatory requirements
• Enhanced data integrity, confidentiality, and availability
• Cost savings from streamlined compliance processes and reduced risk of penalties
• Public recognition via listing on Scope Europe’s registry

Who Should Consider Certification?

Cloud service providers that operate globally, or plan to expand internationally, stand to gain the most. The EU Cloud CoC provides a strong privacy foundation aligned with GDPR’s core principles, helping providers build trust with customers and regulators across jurisdictions.

While other sector codes exist, the EU Cloud Code of Conduct is tailored specifically for CSPs acting as data processors, making it the most directly applicable framework for IaaS, PaaS, and SaaS organizations.

Alignment with Other Frameworks

The EU Cloud CoC was designed with cross-framework compatibility in mind. Many of its technical and administrative controls directly map to:

• ISO 27001 / 27017 / 27018 (information security and cloud-specific privacy)
• ISO 27701 (privacy information management)
• SOC 2 (trust services criteria)
• C5 (Cloud Computing Compliance Controls Catalogue)
• NIST SP 800-53 and the Cybersecurity Framework

This means most CSPs pursuing the Code will find significant overlap with controls they’ve already implemented, minimizing duplication and effort.

Getting Started with the EU Cloud Code of Conduct

For cloud providers, the EU Cloud Code of Conduct offers a credible, scalable path to demonstrate GDPR compliance, improve privacy posture, and gain a competitive edge in the global market.

To learn more or explore how your organization can align with the EU Cloud CoC, contact Schellman’s privacy team for guidance and next steps.