The European Commission's Directorate-General for Digital Services published the Cloud Sovereignty Framework (Version 1.2.1, October 2025) to define a structured set of sovereignty objectives for the procurement and assessment of cloud services. The framework establishes eight Sovereignty Objectives (SOV-1 through SOV-8) and a five-level assurance scale — the Sovereignty Effectiveness Assurance Level (SEAL) — ranging from SEAL-0 (no sovereignty) to SEAL-4 (full digital sovereignty). It draws on European initiatives including CIGREF's Trusted Cloud Referential, Gaia-X, ENISA/NIS2/DORA, and national cloud strategies such as France's "Cloud de Confiance" and Germany's "Souveräner Cloud".
As a Swiss company, linkyard ag and Phonemos are not EU members, but operate within the EU/EEA/EFTA regulatory space and maintain close alignment with EU digital and data protection standards. The assessment below applies the framework's objectives to Phonemos Cloud in that broader European context.
Scope note: References to "EU" in this assessment are interpreted as EU/EEA/EFTA throughout, reflecting Switzerland's bilateral agreements with the EU, its adoption of data protection standards equivalent to GDPR (nDSG/revFADP), and its participation in European digital infrastructure initiatives.
Objective | Description | Phonemos Position | SEAL |
|---|---|---|---|
SOV-1 Strategic Sovereignty | Ownership, governance, and financing anchored in the European ecosystem; ability to sustain operations independently. | linkyard ag is a 100% Swiss-owned, owner-managed company headquartered in Bern, Switzerland. No non-European ownership, no external investor dependencies. Phonemos is developed, operated, and governed entirely within Switzerland. linkyard is an active participant in the Swiss and European technology ecosystem. | SEAL-4 |
SOV-2 Legal & Jurisdictional Sovereignty | Governed by European law; insulated from non-European extraterritorial reach (e.g. US CLOUD Act, Chinese Cybersecurity Law); IP under European jurisdiction. | Phonemos operates exclusively under Swiss law (Federal Data Protection Act / nDSG, equivalent to GDPR). linkyard ag has no US parent, no US-listed entities, and no legal exposure to the US CLOUD Act or equivalent non-European extraterritorial instruments. All intellectual property is created and registered in Switzerland. Contracts are governed by Swiss law with jurisdiction in Bern. | SEAL-4 |
SOV-3 Data & AI Sovereignty | Customer control over data and cryptographic access; strict confinement of storage and processing to Europe; AI services developed and governed under European control. | All Phonemos Cloud data is stored and processed exclusively in Switzerland (Exoscale/cloudscale.ch infrastructure, Swiss data centres). Customer data is never transferred to non-European jurisdictions. Customers retain full control over their content. Audit logs provide visibility into data access. No AI training on customer data. AI features, where offered, are opt-in and scoped to European-hosted models. | SEAL-4 |
SOV-4 Operational Sovereignty | Ability to run, support, and migrate workloads independently; European-based operations and talent; no non-European vendor lock-in; full technical documentation available. | All engineering, operations, and support are performed by linkyard staff in Switzerland. Phonemos is available as both a managed cloud service and a self-hosted on-premises deployment, enabling customers to migrate or operate independently at any time. Full technical documentation is maintained in the Phonemos User Guide. No dependency on non-European operational resources or vendor access. In case of government customers, there is a special government license agreement under which source code is opened for non-commercial use including the possibility to create derivates of the product. | SEAL-4 |
SOV-5 Supply Chain Sovereignty | Geographic origin and transparency of hardware, firmware, and software supply chain; degree of reliance on non-European vendors. | Phonemos Cloud is hosted on cloudscale.ch and Exoscale (Swiss-European cloud infrastructure) operated by linkyard. The application stack is built primarily on selected open source components with European or globally distributed origins. Sub-processors are documented in the Sub-processor Policy. Hardware dependencies on non-European suppliers (e.g. commodity server hardware) represent the main residual supply chain exposure, consistent with the broader European cloud market. | SEAL-3 |
SOV-6 Technology Sovereignty | Open standards and APIs; open-source licensing; architectural transparency; no lock-in to foreign proprietary systems. | Phonemos exposes well-documented REST, GraphQL and MCP APIs enabling integration without proprietary lock-in. The platform is built on open web standards, open document formats and open source components. Phonemos is available under a dual-licensing model including a special noncommercial licence for public-sector use. Architectural documentation and data flow descriptions are published in this User Guide. Customers can export their complete data at any time in standard formats. | SEAL-4 |
SOV-7 Security & Compliance Sovereignty | European-recognised certifications; adherence to GDPR/NIS2/DORA; security operations under European jurisdiction; independent audit capability. | linkyard ag holds ISO 27001 (information security) and ISO 9001 (quality management) certifications. Phonemos is designed for compliance with nDSG (Swiss GDPR-equivalent), and aligns with NIS2 and DORA requirements relevant to its critical infrastructure customer base (banking, public administration, energy). Security operations, incident response, and vulnerability management are conducted exclusively by Swiss-based staff under Swiss law. Customers can commission independent audits. | SEAL-4 |
SOV-8 Environmental Sustainability | Energy-efficient infrastructure; circular economy practices; transparent carbon and sustainability reporting; renewable energy sourcing. | linkyard ag holds an ISO 14001 (environmental management) certification. Phonemos Cloud runs on cloudscale.ch and Exoscale infrastructure in Swiss data centres, which benefit from Switzerland's high share of hydropower and renewable energy in the national grid. linkyard does publish a formal sustainability report. We depend on a stable energy network. | SEAL-3 |
Summary
Phonemos achieves SEAL-4 (Full Digital Sovereignty) across six of the eight objectives, reflecting its Swiss-only ownership, jurisdiction, data residency, and operations. A SEAL-3 (Digital Resilience) rating applies to SOV-5 (Supply Chain) due to residual hardware dependencies on non-European suppliers, which is consistent with the broader European cloud market, and to SOV-8 (Environmental Sustainability) where linkyard's ISO 14001 certification and formal sustainability report provide a solid foundation, but detailed infrastructure-level disclosures such as PUE metrics and circular economy practices remain governed by the underlying cloud infrastructure providers rather than linkyard directly.
This assessment is a self-declaration by linkyard ag and has not been independently verified against the EU Cloud Sovereignty Framework tender specifications. It is intended to help customers and procurement teams understand Phonemos's sovereignty profile in the context of the framework. For formal procurement use, please contact info@phonemos.cloud to discuss supporting evidence and documentation.