Masked inference now — Copperway, no campus dependency.
§ 01 Energy · EU · Overview
Generation, transmission, and trading operators are essential entities under NIS2, and AI in the safety chain of critical infrastructure is high-risk under the AI Act. Both point at the same question: who operates the compute.
§ 02 Answer · Direct
The honest version first, before the regulation table.
European energy operators face two binding instruments at once — NIS2 as an essential entity and the EU AI Act where a model sits in the safety chain of critical infrastructure. AGICY's live answer today is Copperway for masked inference; EU-owned capacity at the planned Cyprus campus is pre-construction and reserved through SRA rather than sold as a live service. We are also an energy buyer ourselves, which is why the cost model on this page publishes a tariff spine rather than a marketing number.
| Instrument | Reference | What it obliges |
|---|---|---|
| NIS2 | Directive (EU) 2022/2555, Annex I, sector 1 | Electricity, district heating, oil, gas, and hydrogen undertakings are essential entities subject to Art. 21 risk-management measures and Art. 23 incident reporting. |
| EU AI Act | Regulation (EU) 2024/1689, Art. 6(2) and Annex III(2) | AI intended as a safety component in the management and operation of critical infrastructure, including electricity supply, is high-risk and carries deployer obligations. |
| CER Directive | Directive (EU) 2022/2557, Art. 13 | Critical entities must take resilience measures covering physical and dependency risk, not only cyber risk. |
| REMIT | Regulation (EU) No 1227/2011, Art. 3–4 | Prohibits insider dealing and market manipulation in wholesale energy markets and obliges disclosure of inside information. |
§ 03 Response · Per instrument
An architecture answer, not a legal determination. Your classification stays yours.
Art. 21(2)(d) supply-chain security reaches your compute provider. Our posture, certifications we hold, and the ones we do not, are published in the Trust Center — treat them as an input to your assessment, not a substitute for it.
High-risk deployment needs logging, human oversight, and traceability you can actually produce. That is easier when weights and traces are exportable and the inference path is not a third-party black box.
Dependency risk includes the jurisdiction of your compute supplier. Our own resilience design — storage for diesel replacement and spike absorption — is published with its limits rather than as an availability promise.
Trading-desk prompts and positions are inside information. A gateway that logs prompts to a third-country provider is a disclosure surface. Copperway masks before egress and does not train on customer content.
§ 04 Paths · Status
Same status rubric as the Trust Center. Nothing is upgraded without evidence.
| Status | Surface | What it means for you |
|---|---|---|
| Live | Copperway gateway | OpenAI-compatible EU-oriented gateway with a PII vault. Usable today, on someone else's silicon — it is a routing and masking layer, not sovereign capacity. |
| In design | Sovereign Resource Allocation | Reservation instrument for capacity at the planned Cyprus campus. An Allocation is not an executed offtake agreement. |
| Target | Cyprus GPU leasing | Planned post-COD. Published megawatt and unit figures are plan-of-record, not connected capacity. |
| Not held | Operating EU campus | Vasilikos is pre-construction. Nobody is running a production workload on AGICY-owned silicon today. |
§ 05 Evidence · Computed
Every figure below is read from the same calculators that feed the business plan, and carries the status it earned.
| Figure | Value | Basis | What it does and does not say |
|---|---|---|---|
| Energy tariff spine | €178 → €150 /MWh | plan-of-record | Early-year and later-year Cyprus tariff basis carried in the model. Not a PPA and not a hedged price.computed/energy_bess_16mw.json |
| Phase 1 facility load (planned) | 16.2 MW IT · ~19.5 MW wall | plan-of-record | Planned Phase 1 draw at PUE 1.2. A planned figure, not a connected load.computed/energy_bess_16mw.json |
| Phase 1 storage (planned) | 16 MW / 64 MWh | plan-of-record | 4-hour LFP pack in the CapEx line for diesel replacement, peak shaving, and spike absorption. Multi-day off-grid operation is not claimed.computed/energy_bess_16mw.json |
| Marginal energy cost / M tokens | €1.78 | modelled | Energy only, at the €178/MWh early-tariff spine. The remainder is allocated facility and fixed cost.computed/unit_economics.json |
§ 06 Analysis · 1 of 3
An energy operator rarely gets to treat AI as a productivity tool. NIS2 makes you an essential entity with supply-chain security duties that reach your suppliers, and the AI Act treats a model in the safety chain of electricity supply as high-risk with deployer obligations attached. Both push the same way: you need to know who operates the compute, what they log, and what you can produce on audit.
The uncomfortable part is that most of the answer is contractual and jurisdictional rather than technical. A model running in an EU region operated by a third-country parent satisfies residency and leaves the compulsion question open. For a trading desk under REMIT, where the prompt itself can be inside information, that gap is the whole problem.
§ 07 Analysis · 2 of 3
Today: Copperway. It is an OpenAI-compatible EU-oriented gateway with a PII vault, which is a real answer for masked inference and a poor answer for anything needing an EU-owned boundary. It runs on other people's silicon and we say so.
Post-COD: reserved capacity at the planned Vasilikos campus, through SRA today and leasing after commercial operation. Those are planning instruments. The campus is pre-construction, so an energy operator that needs a high-risk deployment boundary this year should be talking to us about reservation, not migration.
Masked inference now — Copperway, no campus dependency.
Reserved EU-sited capacity — SRA, pre-COD instrument.
Operating EU-owned cluster — not available, and not claimed.
§ 08 Analysis · 3 of 3
A 19.5 MW planned wall load makes us a counterparty in the same market as our customers, and the energy assumptions behind our cost model are published rather than implied. The tariff spine carried in the model is €178/MWh in early years and €150/MWh later, with a 16 MW / 64 MWh storage pack in the CapEx line for diesel replacement, peak shaving, and absorbing sub-second AI power spikes.
What we do not claim is multi-day off-grid operation. The 24-hour case exists in the model as an energy-park scenario and is explicitly not the Phase 1 base. Publishing the scenario that does not work is how we would like to be judged on the ones that do.
§ 07 Questions · FAQ
The questions a procurement or compliance team actually asks, answered without upgrading our own status.
§ 08 Start · Next step
Copperway works now. Reserved capacity is a pre-COD instrument. If you need an operating EU-owned boundary this quarter, we will tell you so.
Reviewed 2026-08-22 · claim-status rubric