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The draft Royal Decree with which the Spanish Government intends to regulate the energy, environmental, resilience and digital sovereignty requirements for data centres has sparked an intense debate in recent weeks. Companies in the sector, business associations and several regional governments have raised concerns about some of the proposed conditions and, in particular, about the potential impact of a more demanding regulatory framework than those applied in other European countries.

The debate is a legitimate one. Data centres are infrastructure-intensive facilities, consuming significant amounts of energy and, depending on their configuration, water as well. Their rapid growth requires Spain to manage access to a limited electricity grid, ensure appropriate efficiency and sustainability standards, and address increasingly important issues around data sovereignty and security. The Government is therefore responding to a genuine need and to a concern shared across Europe.

But perhaps the debate should be broadened. The question is not simply what requirements the next generation of data centres built in Spain should meet. What really matters is understanding that the regulatory decisions we make today could help define the position Spain occupies within Europe’s emerging digital architecture over the next decade. And Spain enters this moment from a particularly interesting position.

An opportunity that already exists

Spain’s attractiveness for this type of investment is not merely theoretical. The Government acknowledges that, since 2021, more than 12 GW of grid access and connection rights associated with data centres have been granted, while the National Artificial Intelligence Strategy targets around 2.5 GW of computing capacity by 2030, equivalent to between 3.5 and 4 GW of electricity demand. The gap between these figures illustrates the extent of the interest in developing computing capacity in Spain, but also suggests that a significant proportion of the projects currently announced will have to compete for scarce resources and will not necessarily be realised.

This is precisely why growth needs to be properly managed. As currently drafted, the regulation establishes energy and water efficiency requirements, digital sovereignty conditions and an initial obligation to support at least 80% of energy consumption with new renewable generation, subject to additionality and hourly correlation criteria. The stated objective is to capture the economic opportunity without undermining other electrification processes or the country’s environmental and energy goals.

The issue, therefore, is not whether regulation is necessary. It is about finding the right balance between requirements that are essential and the ability to compete in a market where investment can move relatively easily between countries.

This is precisely one of the main concerns raised by the sector: that certain national requirements, if they diverge too far from the European framework or affect projects that are already at an advanced stage, could create legal uncertainty or put Spain at a disadvantage compared with other Member States. The debate even extends to Spain’s future Artificial Intelligence (AI) gigafactory, whose current design would need to improve its efficiency parameters to meet the transitional threshold envisaged in the draft regulation.

Despite this, reducing the discussion to a competition to attract data centres would be to look at the issue only from the surface. It is also a major opportunity to broaden the focus and regulate with a strategic, long-term perspective.

Computing capacity as a strategic asset

Digitalisation is entering a new phase. For years, data storage, supercomputing, AI and quantum computing have been discussed as separate areas. Today, it no longer makes sense to approach them in isolation.

AI requires ever-increasing computing capacity. Supercomputing is essential for model training, scientific simulation, industrial research and the processing of vast amounts of information. And quantum computing, although still at an early stage in terms of commercial applications, is already being envisioned through hybrid architectures in which classical and quantum resources can be combined to tackle problems that are currently beyond the reach of classical computing.

These are not substitute technologies, but complementary and cumulative ones. The ability to deploy them, connect them and build research, talent and business applications around them will determine a significant part of technological competitiveness in the years ahead. This is where the strategic value of computing capacity lies.

Europe is increasingly approaching the issue from precisely this perspective. The EU’s supercomputing policy already incorporates AI and quantum technology within a shared architecture, while EuroHPC is deploying infrastructure specifically designed to facilitate integration between high-performance computing and emerging quantum computing systems.

And Spain?

For now, Spain occupies a prominent position in this process. Barcelona is probably the most visible example. MareNostrum 5 places the Barcelona Supercomputing Center (BSC) among Europe’s major supercomputing infrastructures and, since last May, EuroQCS-Spain has added integrated quantum computing capacity to this ecosystem. The European initiative itself presents this infrastructure as part of the effort to develop sovereign quantum computing capabilities connected to Europe’s leading HPC centres.

A complementary development is taking place in the Basque Country. Since 2025, San Sebastián has hosted Europe’s first operational IBM Quantum System Two at the Ikerbasque facilities. Equipped with a 156-qubit Heron processor, it is intended to serve as the core of a broader scientific and industrial ecosystem.

Granada, meanwhile, has been pursuing another complementary approach. Quantum ADA, based at the Andalusian Artificial Intelligence Centre, aims to build an ecosystem around quantum computing that connects public administrations, companies, universities and research centres, with applications ranging from cybersecurity and energy to logistics, healthcare and AI itself. The University of Granada has also participated in Quantum Spain, precisely with the aim of building a national ecosystem for quantum computing applied to AI.

These are three different initiatives, but when viewed together they reveal a distinctive trend: Spain is beginning to concentrate several of the capabilities that are likely to define the next phase of European digitalisation.

The final stretch of the quantum race

This scenario is particularly significant in quantum computing because, although the overwhelming majority of experts believe we are getting close to crossing the quantum threshold, the technology’s real breakthrough is still ahead of us.

Unlike AI, whose adoption by businesses is already becoming widespread, quantum computing remains in a phase of capability building — constrained in part by error management — experimentation and use-case development. Precisely for this reason, governments around the world are seeking to position themselves ahead of the curve, ensuring they are well placed before the technology reaches greater industrial maturity.

Spain is not starting from the margins. In IBM’s infrastructure ecosystem, for example, Germany has hosted the company’s first Quantum Data Center in Europe since 2024, while the Basque Country is home to the continent’s first operational Quantum System Two. These are different types of infrastructure, but both place their respective territories within a very small group of European locations with direct access to quantum systems at this scale.

Ultimately, however, the key will not simply be to have the most advanced quantum computer or system at any given moment. Sustainable advantage will be built around the ecosystem: scientific capacity, talent, universities, industrial applications, companies capable of working with these technologies and integration with other computing infrastructures.

This is where the convergence of Barcelona, the Basque Country and Granada becomes particularly interesting. Spain does not have a single quantum project, but rather a range of initiatives that are beginning to establish a foundation from which much broader capabilities could develop. An advantage that is particularly valuable precisely because the market has not yet been defined.

Regulating with the bigger picture in mind

But let us return to the debate around data centres. Considered in isolation, a regulatory decision on energy efficiency, water consumption or grid access may appear to be a fundamentally technical matter affecting a specific sector. But technology investments do not operate in isolation, and regulatory decisions of this kind should therefore not be designed without a broader perspective.

The location of a major computing infrastructure attracts suppliers, creates demand for specialised professionals, encourages collaboration with universities and technology centres, and can subsequently influence other investment decisions.

This is precisely why it is important to analyse the wider context and the second-order effects that such regulation may have. If a particular regulatory framework makes the installation of new computing capacity in Spain less attractive, the immediate consequence may be the loss of a data centre. But the medium-term consequence could be that certain AI development capabilities, cloud services, applied research or industrial applications fail to emerge around that investment.

This does not mean that appropriate regulation requires lower standards. Spain has clear reasons to pursue data centres that are efficient, sustainable and compatible with the needs of its electricity system and the availability of water resources. It also has strong strategic reasons to introduce digital sovereignty and resilience criteria.

However, intelligent regulation should incorporate other variables at the same time: predictability, legal certainty, technical feasibility, the ability of projects to adapt and competitiveness relative to other countries. The objective should not be to regulate less, but to regulate with a clear understanding of what we want to build.

A European issue, not just a Spanish one

There is another dimension that will probably become increasingly important: European regulatory alignment.

The European Union is developing common policies around AI, semiconductors, supercomputing, cloud infrastructure and quantum technologies because it considers these capabilities fundamental to the EU’s competitiveness and strategic autonomy.

It would be contradictory to move towards a common European technology strategy while simultaneously allowing regulatory differences to become significant enough to distort, within the Single Market, the location decisions surrounding the very infrastructures that underpin that strategy. The risk of investment moving elsewhere is clear.

Not all countries, of course, face the same circumstances. Spain’s energy, geographical and water conditions differ from those of Germany, France or the Nordic countries, and some degree of national flexibility is therefore reasonable. But that flexibility should sit within a sufficiently harmonised framework to prevent competition from ultimately depending more on regulatory divergence than on genuine economic, energy or technological advantages.

Indeed, part of Spain’s future framework already relies on European standards. The efficiency requirements set out in the draft Data Centre Royal Decree refer to the European rating system that will apply from 2027 onwards. Wherever possible, this logic of convergence should extend to the broader set of conditions affecting infrastructure that, by definition, operates within a European market.

Once again, Europe will struggle to achieve genuine digital sovereignty if the infrastructure required to build it develops across 27 regulatory environments that are unable to offer broadly comparable conditions.

Today’s decisions, tomorrow’s position

Spain currently brings together a highly relevant combination of factors: significant renewable energy capacity, strong international connectivity, data centre projects with European significance, an established supercomputing infrastructure, a relevant role in Europe’s AI strategy and several hubs that place Spain at the forefront of quantum computing development.

That does not guarantee that Spain will become one of Europe’s leading digital hubs. What it does mean is that there is a real opportunity to do so — and that the conditions are broadly aligned with that ambition.

It should also be remembered that, in industrial and technology policy, competitive advantages are often built long before the market makes them visible. By the time a technology reaches maturity, many of the decisions determining where its industry, talent and research capabilities will be concentrated have already been made. Those who try to jump on the train once it is already moving will arrive late.

It is from this perspective that the current debate around data centres and their regulation in Spain should be approached. Their growth needs to be managed and their sustainability guaranteed. But it would be a mistake to do so without considering the technology, business and talent ecosystem that can develop around them, and without recognising that other European countries are competing for the same investments — and for the capabilities that will follow them.

The race for AI is already underway, and many voices argue that Europe is arriving late. The quantum race, however, is only just beginning, and the computing capacity that will enable both technologies is set to become increasingly strategic.

Spain has an opportunity to occupy a relevant position in this new European digital geography. The regulatory decisions taken today will not determine the outcome on their own, but they can either help make that position possible or make it considerably harder to achieve.

And that is probably the question worth asking before the framework is finalised: not only how we regulate the digital infrastructure we need today, but what position we want to occupy when the technologies now emerging become tomorrow’s strategic markets.