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Rising US–EU tensions highlight the urgent need for clear exit plans to reduce dependency on dominant cloud providers.
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Published
6 June 2025
Considering the growing risks tied to heavy reliance on US-based cloud providers in both public and private sectors, now is the perfect time to focus on the importance of cloud exit strategies. This article examines today’s risk landscape across legal, organisational, contractual, and geopolitical dimensions, illustrating how we at Implement help organisations accelerate their cloud exit readiness.
Cloud exit strategy and plan – more relevant than ever
Over the last two decades, organisations have increasingly adopted cloud services and implemented them across all critical business areas and processes. Anywhere from finance, operations, procurement, HR, and customer service, cloud technology permeates the core of modern private and public service delivery.Â
But as our reliance on the cloud deepens, rising geopolitical tension and tighter regulation complicate the risk landscape. Public authorities face stricter compliance and political scrutiny, while private firms enjoy more latitude but risk long-term vendor lock-in. Yet across both sectors, customers and citizens still expect continuous delivery and improvement in services and capabilities.
The public sector’s cloud conundrum
Public organisations face increased regulatory pressure and are generally bound by much stricter legal mandates and sector-specific regulations than those in the private sector. In many EU member states, laws or national policies require data localisation, prohibit the storage of sensitive data outside the EU/EEA, or restrict reliance on non-EU vendors for critical infrastructure. Furthermore, public institutions are held to a higher transparency and accountability standard, meaning that even the choice of cloud service provider (CSP) may be subject to political, media, or audit scrutiny.
But even when cloud service platforms can technically meet GDPR requirements, public authorities are often constrained by broader legal obligations, strict internal risk policies, or extensive external oversight – such as from national data protection agencies or public auditors.
Private organisations have more flexibilityÂ
Private organisations, particularly those not operating in highly regulated industries, often enjoy greater freedom in selecting CSPs, data centre regions, and contractual terms. While businesses that operate in EU markets must still comply with GDPR, enforcement mechanisms tend to be reactive, and the threshold for public scrutiny is higher.Â
As a result, many private organisations adopt a more pragmatic or commercially driven approach to cloud strategy, prioritising flexibility and time-to-market over sovereign data control. However, this flexibility increases the risk of vendor lock-in if cloud exit strategies are overlooked.
The risk landscape is changing
In recent years, cloud adoption has become near universal across public and private organisations, driven by a need for scalability, flexibility, and new services. However, the geopolitical and regulatory context is changing dramatically, exposing organisations to new types of risks. This is especially true of those relying on US-based cloud service providers such as Microsoft, AWS, and Google Cloud. Four risk dimensions are especially important to watch:
Legal risks
Transatlantic data transfers remain under scrutiny. Despite the EU-US Data Privacy Framework, the underlying legal uncertainty stemming from the Schrems-II ruling and the US CLOUD Act has yet to be clarified. Handling sensitive or regulated data, in compliance with GDPR and national legislation, therefore remains a moving target.
Organisational and process-related risks
Many organisations lack defined ownership, processes, and capabilities to continuously monitor, classify, and re-evaluate cloud data and services. Inadequate governance leaves organisations exposed to unidentified and sometimes unmanageable risk, should a change in legal status or vendor availability occur.
Contractual and vendor management risks
Contracts with global tech providers offer limited negotiation flexibility, and exit clauses tend to be vague or biased toward the provider’s operating model. Many have faced de facto vendor lock-in when entering long-term deals focusing on minimal operating costs. The resources required to migrate to other cloud service providers or on-premises alternatives are often seen as prohibitive.
External and geopolitical risks
Geopolitical developments including trade war, cyber threats, and changes in international policy have made it clear that access to core technologies such as cloud services can be weaponised. For most EU-based organisations, dependency on US cloud infrastructure creates systemic vulnerabilities.
These four risk dimensions all serve to highlight a new and critical truth: organisations can no longer afford to treat dependency on CSPs as a static condition. Even with robust architecture and vendor relations, it is no longer sufficient to assume continuity of these services under all circumstances.
That is why a cloud exit strategy and exit plan are essential – not as a sign of distrust, but as part of the professional discipline of thoughtful operational resilience, where the CIO and COO reassure the C-suite of the stability and continuity of daily operations.
A well-defined cloud exit strategy ensures an organisation with an approach, logic, and integrated decision-making on how to relocate data, migrate workloads, or switch vendors if required without suffering undue disruption to operations, compliance, or security. Meanwhile exit planning is not just about switching hardware and software but about making sure your organisation has the clarity, control, and tested procedures to act decisively and in a timely manner when the circumstances demand it.
Own your exit
A robust cloud exit strategy ensures an organisation can reduce or eliminate its dependence on a given CSP and transition when needed without disrupting critical services. Many tech providers offer “exit plans” or data retrieval tools, but these are often designed around their platform limitations rather than your specific business needs. That is why, at Implement, we distinguish between three maturity levels:
In our experience, most companies will find themselves between maturity level 1 and 2, and very few are able to say they are actively testing their cloud exit plan(s). Depending on specific regulatory and business requirements, we also see an intentional mix of maturity across the five dimensions.
No clouds on the horizon
In today's technology landscape, an actionable cloud exit strategy is vital. Rising geopolitical tensions and stricter regulations highlight the risks of relying too heavily on dominant cloud providers, especially those based in the US. Organisations must craft independent exit plans based on their unique operational needs and strengths, free from provider-imposed limitations.
While navigating legal, contractual, and geopolitical risks presents challenges, it also offers opportunities to enhance IT control, boost operational resilience, and ensure compliance with evolving regulations. A proactive approach enables organisations to establish processes for decisive, smooth transitions that safeguard service continuity and data protection.
Owning your exit strategy empowers your organisation to manage transitions away from any cloud service provider effectively. By aligning your exit plans with your strategic goals, you build a foundation for adaptability and competitive agility in an unpredictable digital world.
