Disclaimer: This document is without prejudice to any official call published by the EuroHPC Joint Undertaking for the AI Gigafactories (AIGFs) selection. While every effort is made to ensure that the information provided is accurate and up to date, in the event of any discrepancy between the information provided in this note and the official Call documents, the official published Call documents prevail. The EuroHPC JU reserves the right to update or revise these answers at any time.
See Recital 13 and Article 12b(4) of the EuroHPC amended Regulation:
Recital 13: The selection of AI gigafactories should be based on a joint procurement between the Joint Undertaking and one or more contracting authorities from the countries that are members of the Joint Undertaking (‘Participating States’). The Joint Undertaking and the Participating States should conclude a joint procurement agreement encompassing all the core elements of the subsequent call for expression of interest, including the commitments by Participating States that are Member States to finance their share of any AI gigafactory selected for funding within their respective territory, following the outcome of the selection process conducted by the Joint Undertaking. Member States’ commitments should be submitted to the Joint Undertaking prior to the launch of the call for expression of interest.
Article 12b(4): AI gigafactories shall be selected based on a joint procurement between the Joint Undertaking and one or more contracting authorities from the Participating States. An AI gigafactory Consortium shall benefit from an explicit commitment by the Member State, provided to the Joint Undertaking, to finance its share of the AI gigafactory to be established within the territory of that Member State, following its selection in accordance with paragraph 19. That commitment shall be provided by the Member State before the launch of the call for expression of interest.
In essence, the Member State’s commitment explicitly states the support for establishing an AI Gigafactory in the territory of that Member State.
Again, see Recital 13 and Article 12b(4) of the EuroHPC amended Regulation which provides:
That commitment shall be provided by the Member State before the launch of the call for expression of interest.
The geographical allocation is confirmed by the decision of the EuroHPC Governing Board that approves the evaluation results of the AIGFs selection procedure.
To note that there is an option for provisional commitment for the Member State where adoption of its national budged for 2026 is not completed, with an obligation to provide definitive firm commitment 6 weeks prior to the end of the time-period for the submission of tenders.
If no AIGF is selected in that Member State, the conditions necessary to honour the commitment simply do not materialise and become moot, and no national funds are transferred for that purpose. The Member State, however, might be willing to support other selected AIGFs, just as an option not as an obligation.
The official Call is planned for February 2026 or later - the decision for the date of its publication will be taken by the EuroHPC Governing Board - with the objective to allocate the available budget from this MFF and select fund the AIGFs that are the highest ranked from the selected ones.
It is too early to plan for additional calls for AI Gigafactories under the current MFF. The call may foresee that AIGFs proposals, which meet all the conditions but which are not finally selected may be included in the reserve list which may be funded later on, if funds become available under the current or even the next MFF.
If a multi-site multi-country AIGF is selected, with a physical site in the territory of that Member State, the obligation to support the AIGF is only on the physical site built in the territory of the Member State, not on the other sites in other Member States.
If a MS decides to explicitly limit its commitment to a single-country AIGF, this will be considered as conferring to the Member State some degree of control over the types of consortia to finance, therefore questioning the non-imputability to the State.
Yes, for a multi-country AIGF, each participating host Member State must submit its own commitment letter as part of the joint procurement process.
There is no need to coordinate though such an approach between different MS participating in a multi-country, multi-site AIGF. This coordination is rather for the members of the AIGF consortia.
As stated before, the commitment of a Member State is irrespective of multi-site proposals. If one selected AIGF is multi-site multi-country with a physical location in a Member State that submitted its commitment to the AIGF initiative, that Member State will be supporting the physical site of the multi-site multi-country in its territory.
No discussions between the Commission, or the Member States with specific consortia about the content of their future bids should take place to ensure a level playing field.
Member States can hold general market consultations open to all potential players to understand national capabilities, but they must avoid any actions that could be perceived as providing preferential treatment or inside information to a specific future tenderer.
Crucially, Member States should publicly clarify whether they will commit to the AIGF initiative, including financial support.
Please also note that according to article 12b(4) of the EuroHPC amended Regulation: That commitment shall be provided by the Member State before the launch of the call for expression of interest.
Therefore, once the Call is published, such information about MS commitments will be available and will be published as part of the Call. This would allow all candidate AIGF Consortia to be formally informed of the commitments provided by the concerned MS.
According to article 12b(19) of the EuroHPC amended Regulation:
Following a call for expression of interest, the AI gigafactory Consortium shall be selected by the Governing Board of the Joint Undertaking through a fair and transparent process, with the support of a panel of independent experts and of an accredited financial institution appointed by the Governing Board to carry out an evaluation…
In order to ensure fairness and objectivity in the joint procurement, and underpin the non-imputability of the State, Member States will not have any role in the evaluation and selection process.
The Call for Expression of Interest (call for Tenders) will be a procedure allowing tenderers to bid under either the CAPEX or the Off-take model. The selection process will be irrespective of the model chosen by the Consortia, ensuring that both models are treated equally in terms of evaluation.
A Member State’s contribution should align with the model proposed by the winning consortium supported by that Member State. Therefore, the model is a decision that Consortia will make ex ante based on the needs and specificities of the particular project.
Yes, the AIGF consortium should indicate the public support model in its tender submission.
Yes, the tender offers themselves should be very clear on these points. They should specify, among other information, the phasing and timeline of the proposed investments and the corresponding public support requested for each phase, whether the support is via CAPEX or via Off-taking, and the maximum capacity and financial ceilings for both the overall project and the public contribution.
Regarding the duration of support commitments, in case of the CAPEX model, the financial support will be provided upfront. In case of the Offtake model, payments will spread over the duration of the typical amortization of this type of computing asset, i.e. 5 years. In both cases, and in exchange, the Union and Member States will receive a % of the total compute capacity over 5 years.
Yes, as this is defined in article 12b(3) of the EuroHPC amended Regulation:
Participation in an AI gigafactory Consortium of legal entities from non-Participating States shall be subject to restrictions or exclusion where such participation is considered contrary to the Union’s strategic assets, interests, autonomy or security. In accordance with Regulations (EU) 2021/694, (EU) 2021/695 and (EU) 2021/1153, the call for expression of interest for the selection of an AI gigafactory Consortium shall restrict participation in the AI gigafactory Consortium to legal entities established in Participating States, or to legal entities established in specified associated countries of Horizon Europe, the Digital Europe Programme and any subsequent relevant Union funding programme, or in other third countries in addition to Participating States which do not contravene the security and defence interests of the Union and its Member States. The restrictions and exclusions referred to in this paragraph shall not, in principle, apply to legal entities established in third countries which have signed an AI gigafactory Cooperation Agreement or a similar agreement with the Union. The call for expression of interest for the selection of an AI gigafactory Consortium may provide that legal entities established in other third countries are eligible, provided that such legal entities comply with the requirements applicable to those legal entities to guarantee the protection of the security interests of the Union and the Member States, and to safeguard classified information. Those requirements shall be set out in the work programme.
Yes, but the financial commitment must be submitted and guaranteed at the national level. The internal origin of funds (central vs. regional) is the sole responsibility of the Member State. Please note that the commitment is binding for the Member State: if a project is selected in its territory, the Member State is obliged to provide the funding regardless of the specific location of the AIGF in the Member State.
As regards the commitment, each participating MS submits a commitment letter for their specific financial contribution in their territory (i.e., for the site located in its territory in a multi-country proposal). The internal distribution of costs and responsibilities between the partner countries is governed by their own Consortium Agreement. The JU evaluates the proposal as a single entity, but the Joint Procurement Agreement (JPA) acknowledges the separate public financial streams from each MS. MSs should already now start to work on this commitment and ensure that all their internal processes are cleared in due time.
Member States should match at least the EuroHPC JU contribution and define their commitment individually, also possibly including a “Maximum Ceiling” (e.g., “Up to €X million”), with the cap at 17% of eligible IT CAPEX. The final contribution will be calculated based on the actual price of a selected proposal, and per country in the case of a multi-country project. As the national commitments will be known in advance (i.e., before the opening of the formal call), there will be a possibility for MS to come to an agreement in advance in case more than one MS would decide to invest in an AIGF located in a given MS.
Member States’ roles in the Joint Procurement are directly linked to their financial commitments under the Joint Procurement Agreement.
Member States not providing any financial commitment via the JPA will not participate in the joint procurement.
Some Member States may also decide to invest in an antenna of a full-scale AIGF that is located in their territory by providing a limited (small) commitment. The EU may decide to support financially or not such antennas (Article 12b-paragraph 5 à “In the case of multi-site multi-country AI gigafactories, the Union contribution may be allocated to AI gigafactories that meet the required scale and to one AI gigafactory per participating Member State.”
Importantly, all Member States committing funds initially, but not hosting a selected AIGF, will still have the option to procure compute capacity from the selected AI Gigafactories under the terms and conditions established by the joint procurement, should they wish to do so.
In any case, financial support from all MS will be clear, public and transparent, so that potential bidders know ex ante what to expect when submitting proposals.
The JPA manages and regulates the purchase process. The Hosting Agreement (signed after selection) governs the operations. It is up to the MS to manage, allocate and use the compute capacity that they will receive. It is also important to note that there will be some time of margin for planning in the MS before the compute capacity is operational.
These points will be fully detailed in the official Call for Tenders.
Phased Implementation: A phased approach to construction and deployment is absolutely acceptable and, for projects of this scale, often expected. The call text will provide guidance on how to present a phased work plan and how the ambition and scale of each phase will be assessed.
Alignment of Contributions: For each publicly supported phase, the financial contributions from the Union and the host Member State will be provided in alignment with the project’s milestones, maintaining the matching principle between the Union and the Member State at all times.
Commitment and Go/No-Go Decisions: The proposal, including all its publicly supported phases, will be evaluated holistically as a single, unified project. The Hosting Agreement will create a legally binding commitment for the consortium to complete all approved and funded phases. Therefore, a “no-go” decision point between these funded phases is not foreseen. Failure to execute the full, agreed-upon project would likely trigger penalty clauses or even a termination of the contract, as defined in the Hosting Agreement.
CAPEX: This is an upfront public contribution towards the IT compute infrastructure, which includes GPUs, CPUs, memory, storage, high-performance networking, racks, dedicated cooling and rack power systems, and software. It does not cover the physical data centre building or general site utilities. The call text will clarify eligible costs.
Offtake: This involves periodic payments for a guaranteed purchase of access time over a set period (e.g., 5 years or more) – unless prefinancing option is taken, in which case a bank guarantee should be provided. The total nominal value will be financially equivalent to the corresponding CAPEX contribution, calculated by including a factor for the project’s cost of capital (WACC).
The Joint Procurement Agreement (JPA) is a prerequisite for launching the official Call for Tenders. We are currently drafting the JPA that will be formally submitted to the EuroHPC GB for its agreement. The realistic timeframe for signature is February 2026, just ahead of the planned launch of the call.
We understand the challenge for Member States to organize funding. The JPA requires a firm commitment, but the actual financial amount will only be fixed at the award decision stage, once a specific project and its costs are known. The provided guidance on RRF and Cohesion funds is also designed to help facilitate this process. In any case, MS should already start working on this commitment given the tight schedule.
The timelines are tight but designed to be compatible. Member States wishing to use RRF funds should initiate their national RRP amendment process as soon as possible, in parallel with the JPA and commitment preparations.
The RRP amendment should define a milestone for the contribution of a specific amount to the EuroHPC JU for an “AI Gigafactory or other strategic digital infrastructure”.
The JPA commitment can be made based on the intention to use RRF funds. Commission services (RECOVER, ECFIN) are prepared to assist Member States in this process, and we already shared a guidance note on RRF.
The above have been fully described in the respective guidance notes the Commission provided to the MS some time ago.