Published by the Luxembourg Bankers’ Association (ABBL) on 11 November 2026, this position paper supports Europe’s ambition to strengthen its cloud and AI capabilities while safeguarding financial-sector resilience and competitiveness. It calls for the deletion of Article 31 of the proposed Cloud and AI Development Act (CADA), or an exemption for DORA-regulated financial entities, to avoid duplicative requirements and preserve proportionate, risk-based regulation, technological flexibility and access to global innovation.