Masked inference today — Copperway, no campus dependency.
§ 01 Utilities · EU · Overview
A DSO holds half-hourly consumption for every household on its network. That is personal data at population scale, held by an essential entity, increasingly processed by models nobody in the utility chose.
§ 02 Answer · Direct
The honest version first, before the regulation table.
Regulated network operators sit at the intersection of three regimes: essential-entity duties under NIS2, resilience duties under the CER Directive, and GDPR at population scale because smart-meter and consumption data is personal data. AGICY's honest position is that Copperway can handle masked inference today, and that an EU-owned processing boundary for this data is a post-COD reservation rather than a service we operate. We publish that gap rather than describing a planned campus as available.
| Instrument | Reference | What it obliges |
|---|---|---|
| NIS2 | Directive (EU) 2022/2555, Annex I, sectors 5 and 6 | Drinking water suppliers and waste water undertakings are essential entities, alongside electricity network operators, with Art. 21 risk-management and Art. 23 reporting duties. |
| GDPR | Regulation (EU) 2016/679, Art. 35 and Art. 28 | Large-scale systematic processing triggers a data protection impact assessment, and any processor must be bound by a contract meeting Art. 28(3). |
| CER Directive | Directive (EU) 2022/2557, Annex sectors 3 and 4 | Critical entities in drinking water and waste water must assess and mitigate resilience risk including dependencies. |
| Electricity Market Directive | Directive (EU) 2019/944, Art. 23–24 | Rules on the management of metering and consumption data, including non-discriminatory access and data-format arrangements. |
§ 03 Response · Per instrument
An architecture answer, not a legal determination. Your classification stays yours.
Water and heat operators are frequently treated as lower-tier by vendors and are not, in the directive. Our Trust Center publishes posture and gaps for your Art. 21(2)(d) supply-chain assessment.
Half-hourly consumption for a whole network is the textbook DPIA trigger. We publish our sub-processor list in the Trust Center so the Art. 28 chain is inspectable before you ask.
A dependency on a third-country-parented AI provider is a resilience finding, not just a procurement preference. Whether we are a better dependency is for your assessment; the campus is not operating yet either way.
Where you are the data steward rather than the owner, exporting it to a provider that reserves training rights is hard to defend. Copperway 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 |
|---|---|---|---|
| Modelled all-in cost / M tokens | €4.53 | modelled | Galaxy unit at plan-of-record power and facility cost. Not a price, and not an operating result — the campus is pre-construction.computed/unit_economics.json |
| Effective draw per unit | 10.8 kW | plan-of-record | 9 kW unit TDP at facility PUE 1.2. Air-cooled at ~6U, so no liquid-cooling retrofit is assumed for a customer site.computed/energy_bess_16mw.json |
| Phase 1 fleet (planned) | 1,801 units · 540,300 tok/s | plan-of-record | Planned Phase 1 at Vasilikos, Cyprus. Pre-construction — no capacity is operating under this plan today.computed/fleet_capacity.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 |
§ 06 Analysis · 1 of 3
A hospital handles a few thousand highly sensitive records. A distribution operator handles half-hourly consumption for every connection on its network, which reveals occupancy, working patterns, appliance ownership, and absence. Individually mundane, collectively a population-scale behavioural dataset held by an entity that exists because it is a natural monopoly.
That combination is why the compliance surface is unusually wide: a DPIA under GDPR Art. 35 because the processing is large-scale and systematic, essential-entity duties under NIS2, resilience duties under the CER Directive, and metering-data stewardship rules under the Electricity Market Directive. None of them ban AI. All of them ask who is processing, under whose jurisdiction, and what you can prove.
§ 07 Analysis · 2 of 3
Vendors routinely treat drinking water and district heating as smaller versions of the electricity conversation. NIS2 does not. Annex I lists drinking water and waste water as their own essential-entity sectors, and the CER Directive lists them as critical-entity sectors. The obligations arrive whether or not the operator has an equivalent budget.
Practically, that means a mid-sized water utility inherits the same supply-chain security duty toward its AI provider as a national TSO, with a fraction of the assurance capacity. It is a reason to prefer providers who publish their gaps in a form you can lift into an assessment, which is what the Trust Center is for.
Masked inference today — Copperway, no campus dependency.
Sub-processor list published for Art. 28 chain review before contact.
EU-owned processing boundary — post-COD reservation only, not operating.
§ 08 Analysis · 3 of 3
If the requirement is an operating EU-owned boundary this financial year, we are not the answer and no amount of planned megawatts changes that. The Vasilikos campus is pre-construction. The path that works today is Copperway for workloads where masking is genuinely sufficient, with an SRA reservation if the roadmap needs sovereign capacity later.
The cost model behind that reservation is published rather than quoted: €4.53 per million tokens modelled all-in for a Galaxy unit at plan-of-record power, on air-cooled hardware drawing about 10.8 kW effective per unit. Those are modelled and plan-of-record figures respectively, and they carry that label on purpose.
§ 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