Why a headless CMS for EU data sovereignty needs its own build
A self-hosted headless CMS in EU-controlled infrastructure can address the transfer and access concerns that come with a US-hosted SaaS, but only if the build covers every place personal data lives, not just the CMS database. For most EU organizations, that means editor accounts, the media library, the CDN and asset storage, and form submissions. Each of these can create a transfer on its own, and a move that relocates the database while leaving logins, images or form data with a US provider leaves the core exposure in place. The short answer on the platforms is this: Strapi Community Edition is MIT licensed, but admin SSO, audit logs and review workflows sit in paid Enterprise or add-on tiers, so the license and plan you choose determine which controls you can run. Payload is MIT licensed and built on Next.js, which suits teams already writing TypeScript front ends. Directus is under the Monospace Sustainable Core License 1.0, which explicitly permits internal use and professional services to deploy or host it for a licensee, but it is not an OSI-style permissive license, so legal review is needed. The right choice depends on your content model and on which skills your team already has.
The Schrems II and CLOUD Act questions are about who can compel access to data, not only where the servers sit. The Court of Justice invalidated the EU-US Privacy Shield in Case C-311/18 while holding that standard contractual clauses remained valid, and the EDPB Recommendations 01/2020 note that where a provider must access data in the clear and a third country's public authority powers go beyond what is necessary and proportionate, no effective technical supplementary measure may be available. The US CLOUD Act provision at 18 U.S.C. 2713 reaches data in a provider's possession, custody or control regardless of location. So a US parent company running an EU data center can still be compelled to disclose data. Your assessment should therefore ask which entities hold administrative access to the hosting, backups, CDN logs and support channels, and whether any of them are subject to third-country law with extraterritorial reach. Confirm this with your legal team and your hosting providers, since the answer depends on contracts and ownership, not on the data center address alone.
Before choosing a hosting location, map the data flows on paper: editor and admin accounts (including any SSO provider), the media bucket and its public URLs, the CDN that caches assets and API responses, webhook targets, and the form endpoints that store submissions. Each one needs a named owner, a region, and a documented answer to who can access it in the clear. For the EU personal data rules that apply to form submissions and transfers, the GDPR text on transfers in Regulation (EU) 2016/679 on EUR-Lex is the primary reference. Ask your DPO to confirm whether the EU-US Data Privacy Framework applies to any US-based vendor in the chain, noting that its adequacy decision is under appeal in Case C-703/25 P, which is a reason to design for EU-only control rather than rely on it alone.
Which EU requirements shape the CMS build
This table maps each EU legal requirement to what it asks of the headless CMS build, from where the editor, media and form data live to who can reach them. Read it as a list of design questions to settle with your legal and security teams before choosing hosting, not as a statement of compliance.
| Requirement | Source | What it means for the build |
|---|---|---|
| Transfers include onward transfers to third countries | GDPR Article 44 and Chapter V | Every hop that moves personal data outside the EU needs a transfer basis, so map subprocessors and backups, not only the primary host. |
| Remote support access counts as a transfer | EDPB Guidelines 05/2021 (version 2.0) | A vendor engineer in a third country viewing CMS data on screen during support is a transfer, so define support access paths in advance. |
| Storage outside the EEA counts as a transfer | EDPB Guidelines 05/2021 (version 2.0) | Database, media buckets, logs and backups placed in a non-EEA cloud region bring the transfer rules into scope even if editors are in Europe. |
| EU processor under third-country law | EDPB Guidelines 05/2021, Example 12 | Using an EU-based processor that is subject to extraterritorial third-country law is not itself a transfer, but complying with a foreign authority request would be, so assess that exposure first. |
| US provider reach under the CLOUD Act | 18 U.S.C. 2713 | US providers must preserve or disclose data in their control wherever it is stored, so the provider's jurisdiction matters even for EU regions. |
| Foreign court orders need a treaty basis | GDPR Article 48 | A third-country disclosure order is enforceable in the EU only under an international agreement, which shapes how you answer a foreign demand for CMS data. |
| Supplementary measures may not be enough | EDPB Recommendations 01/2020 | Where a provider must access data in the clear and foreign powers exceed necessity, encryption alone may not close the gap, which favors self-hosting in your own EU infrastructure. |
| Data Privacy Framework status is pending appeal | Commission Implementing Decision (EU) 2023/1795; Case C-703/25 P | Adequacy for US organizations on the DPF List is under appeal, so do not treat DPF listing as a settled basis for a SaaS CMS. |
| Fines for Articles 44 to 49 | GDPR Article 83(5)(c) | Infringements carry fines of up to EUR 20 million or 4% of worldwide annual turnover, which makes hosting location a board-level decision. |
| Switching and non-personal data controls | Data Act Articles 25, 29, 32 and 50 | Plan export and exit paths from any hosted CMS, since switching rights apply and charges are banned from 12 January 2027. |
Where content, media and editor accounts actually live
Start with a data inventory, because the sovereignty question has a different answer for each store. The content database is the core of it. A self-hosted Strapi 5 instance can run on PostgreSQL 14 or later, MySQL 8.0 or later, MariaDB 10.3 or later, or SQLite 3, but not on MongoDB or other NoSQL databases. Place the database in an EU region of infrastructure your organization controls, restrict administration to the platform team, and confirm in writing that the hosting provider's support staff cannot reach it from a third country. Remote access from outside the EEA counts as a transfer under the EDPB guidance, even when someone only views a screen, so the support model needs the same scrutiny as the storage location. Backups follow the database: they are copies of personal data and need the same location, access list and retention rule. Logs deserve the same treatment, since request logs often carry IP addresses, user agents and editor identifiers.
Media, uploads and preview environments hold less obvious personal data. Images of staff, customer photos and uploaded PDFs sit in whatever storage provider the upload configuration points to, and a CDN in front of that storage may cache copies in edge locations outside the EU. Confirm the bucket region, the CDN's cache and logging regions, and whether the CDN provider is itself subject to third-country access rules. Editor and administrator identities are a separate decision. Strapi SSO covers administrator login to the admin panel through an identity provider such as Microsoft Azure Active Directory. It does not authenticate end users of your website, which the Users and Permissions plugin handles. So an EU-hosted identity provider for editors does not, on its own, keep end-user accounts in the EU. API tokens should be scoped per consumer, stored in the secrets manager of the EU environment, and rotated on a schedule your security team sets. Preview environments are often forgotten: they copy production content and must be placed, administered and logged as production is.
Which hosting pattern keeps control inside the EU
In this pattern your organization opens accounts with an EU-region cloud provider, deploys Strapi, Payload or Directus into its own virtual network, and runs the database, media storage and backups under its own identity and key management. Control stays with your staff or your implementation partner, and the main residual question is the provider's own contractual and legal exposure rather than where your data physically sits.
- Administrators: Your team holds the cloud root and IAM roles, so you decide who can read databases, snapshots and object storage, and you can revoke access without asking a vendor.
- Backups: Backup copies, retention periods and restore tests live in EU regions you select, and you control the encryption keys protecting them.
- Support access: Provider support staff access is governed by the provider's support terms, so confirm which support tiers, locations and access approvals apply to your account.
- Sub-processors: The cloud provider and any managed services it uses are sub-processors you must list and assess, including whether any of them are subject to non-EU law with extraterritorial reach.
- Questions to confirm: Which regions and availability zones host every component, whether any managed service replicates outside the EU, and what the provider's documented process is for government access requests.
Ask your provider in writing to confirm the hosting region for each service and its processor terms, because EU residency alone does not settle the access question.
In this pattern the CMS runs on hardware or a private cloud located in an EU facility that your organization or a contracted operator controls. It suits teams with existing data center capacity, strict network segmentation rules or public sector requirements to keep infrastructure in a named facility. Control is highest for administrators and backups, but it carries more operating work for your team.
- Administrators: Physical and hypervisor access is held by your staff or a named operator, and you can restrict console and bastion access to approved personnel.
- Backups: Backup targets are on-site or in a second EU facility you choose, and restores depend on your own runbooks and capacity.
- Support access: Vendor support for Strapi, Payload or Directus is usually remote, so define how a vendor engineer views data, through what session, and with whose approval.
- Sub-processors: Hardware suppliers, colocation providers, managed network operators and any remote support tooling each need to be inventoried and reviewed.
- Questions to confirm: Who can enter the facility, whether remote administration tools route through non-EU infrastructure, and how the operator's own staff access is logged and reviewed.
Confirm with the facility operator, in writing, the physical location, staff access model and any sub-processors it uses, since private cloud contracts often rely on third-party platforms.
In this pattern a CMS vendor hosts the platform for you in an EU region. Strapi Cloud is one example of this model. Strapi Cloud plans are listed at 35 US dollars per month per project for Starter, 90 for Pro and 450 for Business, and the Business plan carries a 99.9% uptime SLA. Those list prices and the SLA are the vendor's published terms, not a substitute for confirming where your project is hosted and how the vendor's processors operate.
- Administrators: The vendor operates the infrastructure, so you control only project and user roles inside the CMS, not the underlying servers or keys.
- Backups: Backup location, frequency and restore procedure are set by the vendor, so request a written description and test a restore if your recovery targets are strict.
- Support access: Vendor staff may access your environment during incidents, so ask for their access approval process, logging and whether they are located outside the EU.
- Sub-processors: The vendor's cloud host, email, monitoring and support tools are sub-processors, and each may route data outside the EU.
- Questions to confirm: Which EU region is used for the project, whether media and backups stay in that region, and whether a data processing agreement with standard contractual clauses covers every sub-processor.
Confirm the hosting region and processor terms directly with the vendor before you sign, and get the current sub-processor list in writing.
Which open-source CMS fits an EU-controlled deployment
Strapi, Payload and Directus can all run in infrastructure you choose, but their license terms, team skills and paid feature sets differ in ways that matter for sovereignty. The cards below cover what to check for each before you commit to a platform.
Strapi Community and Enterprise editions
Strapi's Community Edition is licensed under the MIT Expat license, while code under ee directories belongs to the separately licensed Enterprise Edition. For an EU-controlled deployment, the audit logs and review workflows that many compliance teams ask for are Enterprise features, so confirm which edition your requirements need before you design around the free build. Strapi 5 runs on PostgreSQL, MySQL, MariaDB or SQLite, not MongoDB, which affects your database hosting choice. The current release is v5.58.0.
Payload as a Next.js framework
Payload is an MIT-licensed open source framework built on Next.js, so the CMS, the admin interface and the front end usually share one codebase and one deployment pipeline. That suits teams with strong TypeScript and React skills who want data location decided at the infrastructure level, since the application and its database run in the environment you select. Your team will own more of the runtime, upgrades and security patching. Confirm with counsel how the MIT terms apply to your own modifications and contractor work. The current release is v3.91.0.
Directus under MSCL-1.0-GPL
Directus is licensed under the Monospace Sustainable Core License 1.0, which permits use for any purpose other than a competing use. The license explicitly covers internal use and professional services to deploy or host Directus for a licensee, which matters if an integrator runs it inside your EU cloud account. Because the license is not a standard OSI license, have your counsel read the competing-use definition against your business model before you build a service on top of it. Directus fits teams that want a database-first approach over existing SQL data. The current release is v12.5.0.
Team skills for self-hosting
All three platforms move hosting, patching, backups and access control to your side. Strapi and Directus teams need Node.js operations skills, database administration and familiarity with each product's admin and permissions model. Payload teams also need Next.js and React engineering, because the CMS and front end are closely coupled. Ask any implementation partner who will operate the instance after go-live, how upgrades are tested, and which person owns the database backup and restore runbook.
Paid features that touch sovereignty
Administrator single sign-on and audit logs are the features most often needed to show that only authorized staff changed content in an EU environment. In Strapi, SSO is an add-on for the Growth plan and included in Enterprise, while audit logs are an Enterprise feature. Strapi SSO covers administrator login only, so end-user authentication is a separate decision. Check each platform's current tier and feature list directly with the vendor before you rely on them in a compliance file.
Choosing by content model and team
The right platform follows your content model, editorial workflow and in-house engineering capacity more than any single feature. A content model with heavy relational structure and a SQL-first data team points one way, while a developer-led front end with custom routing points another. Use a short written scope to compare the three against your real models, then confirm license fit with your own legal counsel. DeployOpen can prepare that comparison as part of a fixed-scope implementation plan.
Which CDN, asset storage and form choices keep transfers in scope
A self-hosted CMS can still send personal data outside the EU through the services around it. The cards below cover the delivery, storage, form and sign-in components where a transfer or third-country access exposure most often appears, and what to confirm with each provider before signing.
CDN and edge caching
A CDN caches published pages and API responses close to readers, and its edge logs record IP addresses and request paths. If the provider terminates connections or writes logs outside the EEA, those logs are personal data processed outside the EU. Confirm the regions where edge logs are stored, whether the provider can offer EU-only processing, and which sub-processors touch request data. Limit what is cached to public content so personalized or form-linked responses never pass through shared caches.
Object storage for media
Images, PDFs and video uploaded by editors are stored in an object bucket that may sit with a different provider from the CMS database. Check that the bucket region is fixed in the contract, that replication and backups do not copy objects to other regions, and that the provider's support staff cannot read content from outside the EU. Metadata such as uploader names and file paths can also be personal data and should follow the same rules.
Form submission storage
Contact, application and feedback forms collect personal data from the public, and that data is the most sensitive content in many CMS deployments. Under GDPR, the controller must have a lawful basis, a retention rule and an answer for any transfer. Store submissions in the same EU-controlled database as the CMS, set a retention period for each form, and confirm that the CMS's form or webhook plugins do not forward submissions to a third-party inbox or service by default.
Email and webhook delivery
Notifications triggered by a submission or publish event often leave the CMS through a transactional email service or a webhook into a marketing or CRM tool. Each hop is a separate transfer if the receiving system is outside the EEA or is administered from one. Ask the email provider for its sending region, its sub-processors and whether message bodies are retained. For webhooks, send only the fields the receiver needs, and record which destination each form type reaches.
Identity provider placement
Editor accounts and administrator sign-in pass through an identity provider, which holds names, email addresses, login times and sometimes device data. If the identity service is hosted by a non-EU provider, or its administrators can access tenant data from abroad, editor accounts become a transfer. Strapi's SSO covers administrator login only, so decide where end-user accounts live separately. Confirm the tenant region, the directory and log locations, and who holds administrative access from outside the EU.
Remote support and vendor access
Support engineers working from outside the EEA who can view a screen, a log or a database row are making a transfer, even if the data never leaves the EU. Contracts should state where support access originates, how it is logged, and how the customer approves it. Ask each vendor for its access model and its position on government access requests, since an EU processor subject to third-country law can still expose data in ways the controller must assess.
How a migration off US-hosted CMS SaaS runs in phases
The sequence moves content, media, editor accounts and form data from a US-hosted SaaS into EU-controlled infrastructure in an order that keeps legal review ahead of technical work and proves deletion at the end. Each phase closes with a written output the client can file and check.
Inventory data flows and transfers
DeployOpen works with the client's engineering and marketing leads to list every place personal data and content touch the SaaS: content entries, media files, editor and admin accounts, form submissions, webhooks, preview and build pipelines, CDN and asset storage, analytics tags and support access. For each flow, the team records where data is stored, which vendor sub-processors and support locations can view it, and whether any administrator or support session is held from outside the EEA. The phase is done when the inventory is signed off by the client owner and every flow has a named location and owner.
Complete sovereignty and legal review with the DPO
The client's data protection officer reviews the inventory against the transfer rules in Chapter V of the GDPR, including how the SaaS vendor's transfer mechanisms, sub-processor list and third-country access exposure apply to each flow. The review should cover whether remote display of data for support counts as a transfer under the EDPB's 05/2021 guidelines, and whether the vendor could be compelled to disclose data under US law, such as the CLOUD Act. The output is a written decision record that states which flows must move, which may remain, and the legal basis for each. Confirm the exact wording of the decision with counsel, since this phase does not produce a legal opinion.
Choose the target architecture and platform
With the decision record in hand, the team selects the open-source platform and the hosting model. The choice between Strapi, Payload and Directus depends on the content model, editor needs and team skills, and each product's license terms must be checked against the client's use, including internal use and professional services. Hosting options are set in the client's own cloud account, EU data center or private network, along with the database, object storage for media, the CDN origin and backup location. The output is an architecture diagram and a platform decision record that names every component, its region and its operator.
Map the content model and export
DeployOpen rebuilds the content types, fields, relations, locales and roles in the target platform, then maps each SaaS entry type and field to its new home. A test export is taken from the SaaS through its API, and media files are copied to EU storage with their references rewritten. Where the SaaS payload format differs from the target, transformation scripts are written and version-controlled. The phase closes when a sample of entries and media from each content type loads correctly in a staging instance and a field-by-field mapping document is approved by the content owner. Where the target is Strapi, the team plans for its own data migration rules and works from a verified database backup.
Run the new CMS in parallel
For a defined period agreed in the plan, the SaaS and the EU-hosted CMS run side by side. Editors keep working in the existing system while the new one receives scheduled content syncs, and front ends are pointed at the new API in a staging environment first. Reconciliation scripts compare entry counts, media checksums and publish states between the two systems and report differences to the migration lead. Form submissions and webhooks are tested end to end so that no personal data is sent to the old vendor after the cutover plan is set. The phase is complete when reconciliation reports show no unresolved differences and the front-end team has signed off on the new API responses.
Cut editors over with SSO and roles
Editors and administrators are moved to the new platform with roles that match the access model approved in the content mapping. Administrator login is connected to the client's identity provider where the chosen edition supports it, and the team confirms which login features need a paid plan before cutover. Editor training covers the new workflow, preview and publishing rights. The old SaaS is put into read-only mode for the cutover window, and front-end routing is switched once reconciliation passes. The output is a cutover record listing the switch time, the accounts migrated, the roles assigned and the editors who completed training.
Decommission the SaaS and collect deletion evidence
After the cutover is stable, the team asks the SaaS vendor to delete the client's content, media and account data, and records the request and the vendor's written confirmation. Access tokens, webhooks, API keys, DNS records and CDN origins that point to the old system are revoked and removed. Backups and exports held by the client are inventoried and kept or deleted under the retention rules set in the DPO review. The final output is a decommissioning pack containing the deletion confirmation, the revocation log, the updated data flow inventory and the DPO's sign-off. The vendor's deletion timeline and retention terms should be confirmed in the contract before this phase begins.
Evidence a DPO or regulator will ask for
This table lists the records a data protection officer or supervisory authority is likely to request when a headless CMS moves to EU-controlled hosting, with what each record proves and which component or log produces it. Read it as a preparation checklist: DeployOpen prepares these records and controls for your assessment, but independent auditors and regulators make the final determination.
| Evidence item | What it proves | Produced by |
|---|---|---|
| Transfer inventory and data map | Which personal data classes move, where they are stored, and whether any leave the EEA | Architecture review of CMS, media storage, CDN, form handlers and editor accounts |
| Processor and sub-processor list with locations | Who can access content and form data, and in which countries they operate | Vendor contracts, hosting provider records and CDN configuration exports |
| Records of where each data class is stored | That content, media, user accounts and form submissions sit in named EU regions | Infrastructure-as-code state, database and object storage region settings |
| Access logs for admins and vendor support | Who viewed or changed data, and that remote access from third countries is controlled and recorded | CMS audit logs, identity provider sign-in logs, VPN and bastion logs |
| Transfer basis for any remaining third-country flow | The legal mechanism (SCCs or a Data Privacy Framework basis) and the assessment supporting it | Signed standard contractual clauses, transfer impact assessment, DPF listing check for the vendor |
| Backup location and restore tests | Backups stay in the agreed jurisdiction and data can be recovered within the tested process | Backup job configuration, storage region records and dated restore test reports |
| Deletion records for migrated SaaS data | Content and media removed from the former US-hosted SaaS after verified cutover | Export manifests, vendor deletion confirmations and sign-off records |
| Data Act switching documentation | The exit path to another provider or on-premises infrastructure, with notice periods and data export formats | Exit plan, export runbook, contract clauses on switching and tested export output |
What buyers ask before moving to EU-hosted headless CMS
Does self-hosting a headless CMS in the EU remove transfer risk?
No, hosting location alone does not settle it. Under EDPB Guidelines 05/2021, remote access from a third country, even only displaying data on a screen for support, counts as a transfer, and so does storage in a cloud outside the EEA. Self-hosting in your own EU infrastructure removes the vendor-side access path, but you still need to map every support session, backup location, CDN edge and email or analytics service that touches form submissions. Under Article 48 of the GDPR, a foreign court order is enforceable only through an international agreement, which is one reason to document the legal basis for each access path. Ask your counsel to review the data flow map before you sign anything.
What cost drivers apply to EU-hosted headless CMS, and which are one-time?
Costs fall into four groups: the CMS software, hosting, implementation and recurring operations. Community editions of Strapi, Payload and Directus carry no license fee for the core product, but Strapi's Growth plan lists at 45 US dollars per month including 3 users, and Enterprise is priced on request, according to Strapi's self-hosted pricing page. Implementation (content modeling, front-end build, migration and security hardening) is one-time. Hosting, backups, patching, monitoring and the paid features you choose recur every month. Ask each quote to separate these lines, name who holds each contract, and state which features require a paid tier.
How long does a headless CMS migration to EU hosting take?
The duration depends on the content volume, the number of content types, the media library size, the number of front ends and the state of the data. No supplied source gives a standard timeline, so treat any single number with caution. The biggest drivers are the content model audit, the mapping of URLs and redirects, the media transfer and the editor retraining. If you move between major versions, such as Strapi 4 to 5, the migration adds codemods, data migration scripts and a breaking changes review. Ask the partner for a written scope with a milestone plan, and ask which steps depend on your team's decisions.
What must our team provide before an EU CMS implementation starts?
Your team needs to supply the inputs that cannot be guessed from outside. These include a data flow inventory listing every system that receives form or editor data, the list of editors and their roles, the content types and locales you publish, and your identity provider details for SSO. You also need to name a decision owner for the hosting region, the backup location and the subprocessors. Finally, provide access to the legacy SaaS export, your existing redirect map and the front-end repository. Missing inputs usually extend the scope, so ask the partner to list them in the statement of work.
Can an internal platform team run a self-hosted headless CMS alone?
Many teams can, but the answer depends on the skills available and the operating model you choose. Running the CMS requires a supported database such as PostgreSQL 14 or later, MySQL 8.0 or later, MariaDB 10.3 or later, or SQLite 3 for development, and a Node.js version that is on an Active or Maintenance LTS track, according to Strapi's installation documentation. Ongoing work includes applying upgrades, testing backups, reviewing access logs and handling incidents. If your team lacks these skills, a partner can plan, implement, harden and document the platform, then provide a retainer for upgrades and support. Ask the partner which tasks transfer to your team at handover.
What do Data Act switching rights mean for a CMS hosted in the EU?
The EU Data Act, applicable since 12 September 2025, gives customers the right to switch from a data processing service to another provider or to on-premises infrastructure. The notice period is at most two months, the transition period is 30 days, and switching charges are banned from 12 January 2027, according to Articles 25, 29 and 50 of Regulation (EU) 2023/2854. These rights apply to hosted services you buy, so they matter when a SaaS vendor is the provider. For a self-hosted platform you control, the practical question is whether your export format, content model documentation and backup routines make a future move feasible. Ask the vendor how they export content and media.
Do we need paid Strapi features to meet SSO and audit requirements?
It depends on what you need to prove and who logs in. In Strapi's self-hosted plans, SSO is an add-on for Growth and included in Enterprise, while audit logs and review workflows are Enterprise features, according to Strapi's self-hosted pricing page. Strapi SSO covers administrator login to the admin panel only, so end-user authentication on the front end is handled separately by the Users and Permissions plugin. Confirm the current edition terms in Strapi's license file before you rely on any feature, because the code under ee directories is covered by a separate license.
Which personal data in CMS forms and media needs GDPR controls?
Form submissions often contain names, email addresses, job titles and free-text messages, all of which are personal data under Regulation (EU) 2016/679. Media libraries can hold images of people, and editor accounts hold personal data too. Your controls should cover the lawful basis for each form, the retention period, the location of the database and backups, and the transfer analysis for any third-party embed, analytics script or email service. Confirm the rules with your data protection officer, since the right answer depends on your purposes and your processors.
What to ask an implementation partner on EU hosting
Start by asking the partner to map each data class to a location, a legal entity and an access path. Content records, uploaded media, editor and administrator accounts, form submissions, logs, backups and CDN caches each need their own row. Ask which country each one is stored in, which account or tenancy owns it, and whether any copy, including a backup or a replica for support, sits outside the EEA. Ask who holds administrator and support access to the Strapi, Payload or Directus instance, the database and the object storage bucket, and from which countries those people log in. Under the EDPB Guidelines 05/2021 (version 2.0), even displaying data on a screen for remote support from a third country is a transfer, so the answer to the access question is a data protection question, not only an IT one. Require the partner to name the remote support tooling and to show how sessions are brokered from inside the EEA without the data leaving it.
Next, ask for the sub-processor list for every component: hosting provider, object storage, CDN, email relay for form notifications, error monitoring, and any managed database. For each, ask whether the provider is controlled from outside the EU and whether it is subject to third-country law with extraterritorial reach, such as the US CLOUD Act provision at 18 U.S.C. 2713. Ask how the design changes if the Data Privacy Framework adequacy decision is set aside. The appeal in Case C-703/25 P is pending, so the partner should show which contracts rely on standard contractual clauses as a fallback and whether the stack can move to EU-controlled providers without a rebuild. Ask for a written exit plan that uses the Data Act's switching rights, including the two-month notice period and the 30-day transition in the Data Act.
Finally, ask how upgrades and exit are evidenced. For a Strapi project, ask how a v4 to v5 move is handled in a sovereign environment: where the upgrade tool and data migration scripts run, where the backup of the database is kept, and who signs off on the output. Ask what evidence arrives at handover, such as a current data map, a transfer impact assessment, the signed contract list, access logs for support sessions, a tested restore, and an export of content and media in a documented format. DeployOpen prepares this evidence for your assessors, but independent auditors and supervisory authorities make the final judgment. Confirm the scope of that evidence in the written statement of work before work starts.
How DeployOpen scopes and builds a sovereign headless CMS
DeployOpen plans, implements, hardens and documents self-hosted open-source CMS platforms inside your own cloud accounts, data centers or air-gapped networks. For EU data sovereignty, that means the CMS, its database, media storage and editor accounts are placed and controlled within the boundaries your legal and security teams agree before any build begins.
How we scope
- Map where content, media, form submissions and editor accounts will be stored, processed and administered, including any remote support access from outside the EEA.
- Document the agreed scope in writing, covering hosting location, CDN and asset storage choices, identity provider integration and the migration path from the current SaaS CMS.
- Confirm with your counsel and data protection officer which transfer tools, processor terms and supplementary measures apply before any deployment work starts.
How we build
- Deploy the chosen CMS (Strapi, Payload or Directus) in the agreed EU environment with database, backups and secrets managed in your infrastructure.
- Configure editor SSO, roles, content models and form data handling so personal data flows only to the storage locations approved in the scope.
- Test access controls, data residency settings, backup restores and the CDN and asset URLs served to visitors before cutover.
How we hand over
- Deliver architecture diagrams, data flow records and configuration documentation that show each location where personal data is held or accessed.
- Provide a migration runbook covering content export, media transfer, URL and redirect mapping, and the rollback steps if cutover needs to be reversed.
- Train your administrators on upgrades, licence terms of the chosen edition and the paid features your scope requires, so the team can run the platform after handover.
How we support
- Offer ongoing support, upgrades and continuous security testing as a retainer, with the scope and response expectations agreed in writing.
- Plan version upgrades around vendor support windows, such as the end-of-life dates published for each CMS major version, and test them before production rollout.
- Prepare evidence for your own compliance assessments, such as records of processing and access logs, while independent auditors remain responsible for any audit opinion.
