- within Tax, Privacy and Intellectual Property topic(s)
In Circular No. 6519/SG 1 dated 5 February 2026, Prime Minister Sébastien Lecornu sets out the framework for the State's digital public procurement and reiterates the requirement to rely on the SecNumCloud qualification for hosting data of particular sensitivity, including health data.
The circular establishes digital sovereignty as the second priority objective guiding digital procurement decisions, after operational performance. It defines digital sovereignty as resting on immunity from extra-European laws with extraterritorial reach, the ability to substitute a digital component, and control over key technologies by French or European actors.
The SecNumCloud qualification specifically allows certification that a cloud offering provides a level of security appropriate for data of particular sensitivity within the meaning of Article 31 of the Loi SREN, notably including data whose breach could endanger the health or life of individuals. A practical guide, published on numerique.gouv.fr, is intended to assist administrations in identifying the relevant data and selecting the appropriate cloud offering.
This requirement goes beyond HDS (Health Data Hosting, hereafter "HDS") certification. While the HDS certification, in its updated version introduced by the ministerial order of 26 April 2024, requires hosting within the European Economic Area and the documentation of appropriate safeguards in the event of access from a third country, it does not cover the extraterritorial immunity requirements specific to SecNumCloud, which also imposes strict constraints relating to shareholding and governance. An HDS-certified hosting provider is therefore not automatically compliant with SecNumCloud standards.
In the healthcare sector, this circular directly echoes the expected migration of the Health Data Hub to a SecNumCloud-qualified hosting provider, as required by the SREN Law (France) by the end of 2026.
Footnote
1. https://www.legifrance.gouv.fr/download/file/pdf/cir_45649/CIRC
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