Noerr advises Schwarz Digits on market entry in the Netherlands

A Noerr team led by Thomas Thalhofer and Lennart Laude has advised Schwarz Digits, the IT and digital division of the Schwarz Group, on signing a framework agreement with the Strategic Vendor Management for Microsoft, Google Cloud and AWS (SLM Rijk), which forms part of the Dutch Ministry of Justice and Security. In this way, the parties to the agreement are paving the way for greater digital sovereignty in Europe.

Following a successful review process, this framework agreement provides a solid base for using the STACKIT Public Cloud in a compliant manner. The Dutch SLM Rijk has thus confirmed STACKIT as a sovereign alternative to non-European cloud providers. The partnership is based on a comprehensive data protection impact assessment (DPIA) conducted by Privacy Company, an independent consulting firm.

The approval covers both Infrastructure-as-a-Service (IaaS) and Platform-as-a-Service (PaaS). A thorough data protection impact assessment (DPIA) conducted in 2025 confirmed that STACKIT meets the strict Dutch and European data protection requirements for protection of government data. A key component of the agreement is flexibility in procurement. The negotiated terms of use allow Dutch government agencies to procure STACKIT services either directly or through local resellers.

The framework agreement with SLM Rijk is a major milestone in Schwarz Digits’ international expansion strategy, aimed at making Europe more digitally independent. While companies and government agencies are subject to strict regulatory requirements, the cloud provider STACKIT offers a turnkey, legally compliant solution with physical data storage within the EU.

The Noerr team advised Schwarz Digits on drafting and negotiating the complex contracts underlying the transaction, especially on challenging legal and regulatory issues relating to the Data Act and data privacy law. This also included advising on and successfully negotiating a data processing agreement.

Advisors to Schwarz Digits: Noerr

Team lead: Thomas Thalhofer (partner, Digital Business), Lennart Laude (senior associate, both Munich)

Digital Business: Andreas Daum (associated partner), Konstantin Richter (senior associate, both Munich)

Data Privacy: Daniel Rücker (partner), Alexander Brandt (senior associate, both Munich)

Advisors on Dutch law: Houthoff (lead: Thomas de Weerd, partner)

Schwarz Digits inhouse team: Philipp Müller Günthert (Legal), Philipp Hartmann (Data Privacy), Tom Goll (Country Manager for the Netherlands), Simon Mildner (Customer Success Management)