The European Commission's release of the AI Continent Action Plan on 9 April 2025 marks a transformative shift in the European Union's ambition for technological leadership.
This is not merely a roadmap but a €200 billion strategy to create a sovereign, pan-European AI ecosystem grounded in safety, trust, and innovation. At its heart is the recognition that computing infrastructure has become the geopolitical substrate of power in the age of AI.
The Action Plan offers unprecedented opportunities and challenges for European businesses, particularly those navigating regulatory compliance, data governance, and AI adoption. With a staggering €200 billion investment initiative called "InvestAI" at its core, the plan aspires to position Europe as a competitive force in the global AI landscape while maintaining its distinctive regulatory approach that emphasises trustworthiness, safety, and alignment with European values.
"The European Union is committed and determined to become a global leader in Artificial Intelligence, a leading AI continent," the Commission declares in its communication. "AI has just begun to be adopted in the key sectors of our economy, helping to tackle some of the most pressing challenges of our times."
Strategic Foundations: The Five Pillars of Europe's AI Plan
The EU's strategy for AI advancement centres on five interconnected domains:
- Compute Infrastructure: AI Factories and forthcoming Gigafactories aim to triple the EU's AI compute capacity by 2027.
- High-Quality Data Access: A new Data Union Strategy and associated Data Labs will unlock sector-specific data.
- Algorithm Development and Adoption: A forthcoming Apply AI Strategy will accelerate uptake across strategic sectors.
- Skills and Talent: The AI Skills Academy will address talent shortages and support workforce reskilling.
- Regulatory Clarity: The AI Act is backed by support mechanisms to simplify compliance.
This holistic programme is designed to support AI research and industrialise AI deployment at scale across the European economy.
Compute Power as Strategic Infrastructure
At the plan's core is a provocative proposition: that Europe must build and control its own computational destiny. The Action Plan makes the case that computing infrastructure is the geopolitical substrate of AI, just as fossil fuel pipelines once were for global energy. The United States has OpenAI, Anthropic and NVIDIA. China has Baidu, Alibaba, and government-aligned semiconductor giants. To date, the EU has lacked both foundational models and the computing infrastructure required to support them.
AI Factories: Building Europe's Computational Backbone
Thirteen AI Factories have already been selected, spanning 17 Member States. These dynamic ecosystems integrate AI-optimised supercomputers, data resources, programming facilities, and human capital. Following a highly successful first call for proposals, nine new AI-optimised supercomputers will be procured and deployed across the EU in 2025-2026, with one existing supercomputer being upgraded with AI capabilities. This investment will more than triple the current European High-Performance Computing Joint Undertaking's (EuroHPC) AI computing capacity.
Each AI Factory brings specialised focus areas to the network. Finland's LUMI AI Factory concentrates on manufacturing, health, life science, and communication technologies. Italy's IT4LIA focuses on agri-tech, cybersecurity, healthcare, and education sectors. Spain's BSC AI Factory, built around the Mare Nostrum 5 supercomputer, emphasises health, climate, agriculture, and energy applications.
While Ireland is not yet among the host countries, Irish companies will be able to access compute power and services via the EuroHPC access framework. SMEs, startups, and public bodies will be prioritised for access, creating immediate opportunities for Irish businesses developing AI solutions.
AI Gigafactories: Europe's Moonshot Computing Initiative
While the AI Factories represent a significant computational advancement, the Commission recognises that developing and training frontier AI models requires even more substantial resources. Enter the "AI Gigafactories" initiative, which aims to create large-scale facilities capable of training complex AI models with hundreds of trillions of parameters.
On a scale equivalent to CERN, these gigafactories are designed to train the next generation of frontier AI models – those approaching artificial general intelligence (AGI). They will integrate massive computing power – exceeding 100,000 advanced AI processors per installation – while accounting for energy, water efficiency, and circularity considerations.
To finance these ventures, the Commission has announced the InvestAI Facility, which aims to mobilise €20 billion specifically for AI infrastructure, targeting up to five AI Gigafactories across the Union. This facility will blend private investment with grants and guarantees from the Union budget and Member States.
The broader €200 billion InvestAI programme will also promote a "European preference" in public procurement for critical technologies, including AI chips and cloud infrastructure. Clients involved in public tenders should anticipate increased compliance requirements with this localisation principle.
A New Regulatory Infrastructure: The AI Act and Beyond
The fifth pillar of the Action Plan addresses regulatory compliance and simplification. The EU's AI Act, which entered into force on 1 August 2024 and will be phased in gradually until full application by 2 August 2027, creates harmonised conditions for AI market access across the EU while ensuring safety and fundamental rights protection.
To facilitate compliance, particularly for smaller AI solution providers, the Commission is launching an AI Act Service Desk as a central information hub in July 2025. This service will offer practical advice, technical tools, and guidance on navigating the regulatory landscape.
"The AI Act's success will primarily depend on how workable its rules are in practice," the Commission acknowledges. "The current preparatory phase is crucial to achieving a successful implementation."
Crucially, the Action Plan does not propose new legislation. Instead, it focuses on implementing the AI Act in a usable and business-friendly way. The Commission aims to avoid regulatory overreach while strengthening market trust. This is a critical window for regulated entities and product developers to engage with regulators and shape interpretation.
The progressive implementation of the AI Act creates a complex compliance timeline that businesses must navigate:
- 2 August 2025: Rules related to governance and general-purpose AI models
- 2 February 2026: General provisions and prohibitions
- 2 August 2026: General application covering high-risk AI systems, transparency measures, and innovation support
- 2 August 2027: Rules for high-risk AI systems covered by existing product legislation
Data Sovereignty: From Fragmentation to a Federated System
Computational power alone cannot drive AI advancement – high-quality data is equally critical. Recognising this, the Commission plans to introduce a new "Data Union Strategy" in the second half of 2025 to enhance interoperability and data availability across sectors.
To be established as part of the AI Factories, the Data Labs initiative will bring together and federate data from different factories covering the same sectors and link to Common European Data Spaces. They will offer services including data cleaning, enrichment, standardisation, and interoperability tools.
"Data Labs will not only ensure access to Common European Data Spaces but could also offer a range of other services," the Commission explains. "These could include cleaning and enriching datasets, providing technical tools and fostering interoperability across sectors and borders."
The Alliance for Language Technologies (ALT-EDIC), launched in March 2025, exemplifies this approach by pooling language data from 17 Member States to support multilingual AI models – a critical advantage for the linguistically diverse European market. Language data availability is essential for breaking down language barriers in the single market, potentially boosting intra-EU trade by up to €360 billion.
Irish companies should assess the potential to contribute to or benefit from European Common Data Spaces. This is especially relevant in health, where the European Health Data Space will become an enabling layer for AI in diagnostics and public health.
From Research to Market: Accelerating AI Adoption
A crucial element of the Action Plan focuses on stimulating the development and adoption of AI algorithms in strategic European sectors. The forthcoming "Apply AI Strategy" will target key European industrial sectors where the EU already demonstrates leadership, including advanced manufacturing, aerospace, defence, agri-food, energy, mobility, pharmaceuticals, and cultural and creative industries.
The Apply AI Strategy will be complemented by the network of European Digital Innovation Hubs, which will evolve in their second phase (beginning December 2025) to become "Experience Centres for AI." These hubs aim to ensure the digital transformation of SMEs, mid-caps, and public sector organisations across all regions of Europe.
Building on the GenAI4EU initiative, which has already allocated nearly €700 million for AI research and innovation, the Commission plans continued support for European AI R&I and solution development through 2026 and 2027. Within the public sector, up to four pilot projects will aim to accelerate the deployment of European generative AI solutions in public administrations, enhance decision-making, and improve citizen interactions.
For foundational research, the plan proposes establishing a European AI Research Council, called the Resource for AI Science in Europe (RAISE), which will support both "Science for AI" (advancing next-generation AI technologies) and "AI in Science" (using AI across scientific disciplines).
AI Literacy and Workforce Development
Recognising that technology without talent is ineffectual, the Action Plan outlines comprehensive measures to strengthen AI skills throughout the EU. The Commission aims to enlarge the EU's pool of AI specialists while simultaneously upskilling and reskilling the broader workforce.
Central to this effort is the AI Skills Academy, a one-stop shop for education and training on AI development and deployment skills. The Academy will support AI fellowship schemes, pilot AI-focused degree programmes, and create apprenticeship opportunities – including specific returnship schemes for female professionals.
To attract and retain international talent, the Commission will improve implementation of the Students and Researchers Directive and the BlueCard Directive while piloting the Marie Skłodowska-Curie action "MSCA Choose Europe" scheme. By 2026, the Commission will also launch Multipurpose Legal Gateway Offices in key partner countries to boost international labour mobility in ICT and other AI-relevant sectors.
For employers, this opens new avenues for talent acquisition and training partnerships. It also implies a growing expectation for AI literacy across the workforce – including legal, compliance, HR, and operations functions.
Key Business and Legal Implications
Assessing AI Act Compliance Requirements
Businesses developing or deploying AI systems should assess whether their applications fall within the high-risk categories defined by the AI Act. This includes AI systems incorporated into products covered by EU product safety legislation and standalone AI systems used in specific sectors like biometric identification, critical infrastructure, education, employment, essential services, law enforcement, migration, and administration of justice.
High-risk AI system providers must establish risk management systems, ensure data governance, maintain technical documentation, enable logging capabilities, ensure human oversight, and meet accuracy, robustness, and cybersecurity requirements. They must also register in the EU database before placing their systems on the market.
Even for non-high-risk systems, transparency obligations may apply, particularly for systems interacting with humans, emotion recognition systems, biometric categorisation systems, and AI-generated content ("deepfakes").
Exploring Funding and Support Opportunities
The €200 billion InvestAI initiative presents significant funding opportunities for businesses involved in AI development and deployment. Companies should:
- Monitor calls for expressions of interest related to AI Factories and Gigafactories
- Engage with European Digital Innovation Hubs in their region to access training, testing facilities, and funding advice
- Explore participation in GenAI4EU initiatives and other research programs
- Consider how to leverage the upcoming Data Labs for access to high-quality training dat
Preparing for Data Union Strategy Implementation
Organisations should be preparing for the forthcoming Data Union Strategy by:
- Auditing their data assets and identifying those with potential for federated sharing
- Reviewing data governance frameworks to ensure compliance with evolving regulations
- Exploring opportunities to participate in sectoral data spaces
- Monitoring developments in interoperability standards that may impact data architecture decisions
Strategic Talent Planning
Given the emphasis on AI skills development, businesses should:
- Develop strategies for upskilling existing staff through the AI Skills Academy and other initiatives
- Consider how to leverage new visa pathways for international AI talent
- Explore apprenticeship and returnship schemes being developed at EU level
- Engage with educational institutions developing AI-focused qualifications
Implications for Irish Business and Regulation
Ireland has a unique opportunity to play a strategic role in Europe's AI vision:
- As a Gateway: With its deep tech ecosystem and transatlantic links, Ireland can serve as a bridge for US firms seeking to align with the AI Act.
- As a Contributor: Irish participation in AI Factory Antennas or sectoral Data Labs could enhance regional competitiveness.
- As a Regulator: Ireland's Data Protection Commission and sectoral regulators will be instrumental in aligning AI governance with existing legal frameworks, including GDPR.
For law firms, in-house counsel, and compliance teams, this presents immediate priorities:
- Reviewing existing and planned AI deployments against the AI Act's high-risk categorisations
- Assessing data governance frameworks in preparation for the Data Union Strategy
- Monitoring funding opportunities through InvestAI and sectoral initiatives
- Preparing for new skills requirements and international talent mobility options
Conclusion: A Defining Moment for European AI
The AI Continent Action Plan marks Europe's most assertive bid yet to shape the future of AI – not just as a consumer of models and chips developed elsewhere but as a global developer, deployer, and regulator of AI technologies.
The EU's approach – combining substantial investments in infrastructure, data, skills, and innovation with its distinctive regulatory framework – creates a unique environment for AI development. While compliance requirements may initially appear burdensome, they create a stable, predictable environment for long-term investment in AI capabilities.
Now is the time for businesses to engage with these initiatives, assess compliance requirements, and position themselves to leverage the substantial resources being mobilised across the EU. Those who engage early – through governance reform, data partnerships, and infrastructure collaboration – will shape not only compliance but competitiveness in the AI-powered future.
As the Commission concludes, "This is a unique opportunity for Europe to act swiftly to shape the future of AI and create a better tomorrow for all Europeans, ultimately becoming a leading AI Continent."
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