Sovereign CRM: what “hosted in Europe” does not prove

A CRM hosted in Europe is not sovereign for that reason alone. The word describes no verifiable property of the software, and no authority polices its commercial use. The enforceable object goes by another name, qualification, and ANSSI writes in its FAQ that the scheme recognizes a specific cloud offering, and not a cloud provider or an infrastructure.

The buying question therefore splits into four: which offering exactly is qualified, inside which technical scope, against which version of the framework, and until what date. A fifth applies to any agentic CRM, namely what becomes of that scope once the agent leaves the software to call a model. The first four answers sit in a public catalogue refreshed every month. The fifth is not in it.

“Sovereign” cannot be checked, “qualified” can

The same adjective covers at least four different products: servers standing on a territory, a locally incorporated entity, an entity with no ownership ties to a third country, and an offering actually qualified by an authority. The first three are declared in one sentence on a slide, at no cost. The fourth is entered in a public catalogue, with a decision number and an expiry date. That is what makes it the only one that sorts vendors.

The third meaning is checkable only because one framework puts numbers on it. Chapter 19.6 of the SecNumCloud 3.2 framework requires the provider's registered office, central administration and main establishment to sit inside an EU member state, and caps third-country holdings of capital and voting rights at 24% individually and 39% collectively. Outside that text, the same sentence stays unverifiable.

What gets qualified is a named offering, not a vendor

Those thresholds belong to a framework, and a framework does not apply to a company: it applies to whatever that company had assessed. The ANSSI FAQ says so plainly, and it adds the duration. A qualification is valid for three years, conditional on the provider honoring its commitments throughout, and it is monitored through annual surveillance audits. One group can therefore be qualified on one offering and not on the next.

The framework goes further than the FAQ. Its chapter 3.2 provides that qualified providers remain free to deliver services outside the scope they were qualified for, but may not claim the qualification for those services. A qualification is not an attribute of the vendor that radiates across its catalogue. It stops at the line that carries it.

The grammar is identical on the American side. The FedRAMP Consolidated Rules for 2026, officially launched on June 24, 2026, define the certified object as a specific, packaged cloud computing product or service, and the Marketplace calls itself the authoritative place to confirm whether a cloud service offering holds a FedRAMP designation, is working toward certification, or is connected to agency reuse. Three statuses, and none of them certifies a company.

The catalogue says what the adjective never will

If the qualified unit is an offering, then verification becomes a matter of reading a table. The ANSSI catalogue of certified and qualified solutions, dated September 2026 and refreshed on September 1, lists 25 qualified SecNumCloud offerings held by 11 providers. Every row carries the service name, the service models covered, a start date, an end date and a link to the qualification decision. The nearest expiry falls on November 30, 2026.

That table says something no slide ever will. Chapter 2.1 of the framework names CRM among its examples of in-scope SaaS services, alongside messaging and collaboration tools. The qualified software offerings that do exist are collaboration suites, document sharing tools and school management systems. In September 2026 the word CRM appears nowhere across the 134 pages of the catalogue.

ANSSI publishes providers under qualification separately, 17 of them at that date, noting that only the projects providers have agreed to make public are shown. Two practical consequences follow: an announced process is not a qualification, and a name missing from that second list proves nothing. The FedRAMP Marketplace draws the same line between a certified offering and one working toward certification.

The scope ends where the model call begins

A CRM vendor absent from the catalogue therefore leans on the qualification held by its host. The borrowing is legitimate, provided the vendor says where it stops, and the framework itself takes the trouble to warn: compliance with SecNumCloud, says chapter 3.3.2, does not replace the legal or regulatory requirements attached to specific categories of data, such as data classified Diffusion Restreinte or health data.

In an agentic CRM, what the borrowing leaves outside is the part that does the work. One run chains the capture of a message through a delegated token, a database write, context assembly, inference, a tool call out to a third-party service, then a log entry. A hosting qualification covers storage and compute for the listed offering, not an inference API operated by another provider under another contract. Those six segments are detailed in kasar.app/blog/ou-sont-mes-donnees-crm.

The framework does hand buyers one usable document on this point. Its chapter 5.3 requires the provider to list, in a dedicated document, the residual risks tied to extra-European laws designed to collect customer data or metadata without prior consent. That document exists for qualified offerings. Nothing stops a buyer from asking an unqualified vendor to produce one.

Who does the law actually bind?

Since qualification stops before inference, the question moves to statute, and statute does not address the market. Article 31 of French law 2024-449 of May 21, 2024 was implemented by decree 2026-272 of April 14, 2026, published in the Journal officiel of April 16 and in force the following day, covering data of particular sensitivity held by State administrations, operators and public interest groupings.

The order of August 12, 2026 completed the mechanism by approving the annexed requirements framework in its version 3.2. Its article 2 deserves reading in full: compliance is evidenced by a qualification issued by ANSSI, or by a certification from the European Union or a state party to the European Economic Area recognized as equivalent by that same agency. The European door is open in the text, and it still concerns no private buyer.

The American perimeter reads the same way. The FedRAMP rules state that only a federal agency can determine whether its use case falls within the program's scope, and that what matters is the agency use case rather than the service itself. On the European side, the Commission policy page on the Cloud and AI Development Act, updated on June 3, 2026, describes four assurance levels that public bodies draw on according to their risk assessments.

Those four levels are worth borrowing, because they replace an adjective with a scale. Level 1 requires data to be processed and stored in infrastructure located in the Union, level 2 demonstrated independence from third countries, level 3 EU ownership and control, level 4 the absence of third-country interference. A private company buying a CRM is targeted by none of these texts.

Seven lines to get in writing before the demo

A private buyer therefore has to contract alone for what no statute imposes. The SecNumCloud framework makes that easier than it looks, because it has already drafted the clauses: its chapter 19.1 lists them for qualified offerings. The seven lines below borrow from it and work on any vendor, European or American. A verbal answer validates none of them.

• The exact name of the qualified or certified offering, its technical scope, the framework version and the end date. The ANSSI catalogue publishes that end date row by row, so it can simply be copied across.
• The share of the product that sits outside that scope, spelled out. That is where inference, tool calls and an agent's execution logs actually live.
• The document listing residual risks tied to extra-European law, which chapter 5.3 of the framework already imposes on qualified providers. An unqualified vendor can write one anyway.
• The subprocessor list: dated, versioned and public, naming the model provider and its host, and not only the infrastructure hosts.
• A termination clause with no penalty if the qualification is lost mid-contract, modeled on chapter 19.1 of the framework, which already imposes it on qualified offerings.
• A reversibility clause: files in one or more documented formats usable outside the service, with a stated deadline and what the export contains beyond the records your users typed in.
• The agent action log, exportable and tied to an identity, tool calls included. No statute imposes it on a CRM, which is exactly what makes it a purchasing requirement.

Three grades are enough to score each line: a dated public document, a written and named answer, or nothing. That scoring crowns no winner, least of all by nationality. It separates vendors that produce dated documents from vendors that produce adjectives, and that split runs through European and American catalogues alike, line by line.

Kasar is an AI-native CRM whose agent is called Leo: it captures interactions across email, LinkedIn, WhatsApp, calendar and calls, and it exposes an MCP server. Those are the objects lines 2, 6 and 7 ask about, and the grid applies to us exactly as it applies to anyone else. The 14-day trial is there to test them rather than to take our word.