The Holding · Research

Research

Independent research on hybrid sovereignty and the regulation of frontier technology in national security contexts.

The research programme of the Managing Partner sits at the intersection of comparative regulatory law, technology infrastructure, and the operating doctrine of strategic state instruments.

01

Working Thesis

Working Title

Hybrid Sovereignty

The Italian Golden Power doctrine and the regulation of frontier technology in national security contexts.

Author
Giovanni Costantini
Advisor
Prof. Salvatore Fava
Status
Working draft
Expected
2026
Imprint
Mirafiore Editore (Private Imprint)

Abstract

The Italian Golden Power doctrine — codified in Decree-Law 21/2012 and substantially amended through 2022 — is among the most consequential instruments of state strategic control in the European regulatory landscape. Its remit has expanded from the traditional sectors of defence, energy, and telecommunications to encompass cloud infrastructure, semiconductor manufacturing, biotechnology, and the high-risk AI systems addressed by Regulation (EU) 2024/1689.

Hybrid Sovereignty argues that the operational doctrine of the Golden Power has not kept pace with the architectures it is now asked to govern. The instrument was designed for transactional control — the veto, the prescription, the divestiture — over assets located within national borders. The infrastructures it must now address are extraterritorial by construction: sovereign-cloud arrangements, open-weights foundation models, supply chains that cross multiple jurisdictions simultaneously, and computational substrate whose effective seat may move with a single configuration change.

The thesis develops a framework for what it calls hybrid sovereignty: a doctrine of strategic control that operates simultaneously through traditional instruments (notification regimes, special powers, audit rights) and through architectural intervention (data-residency requirements, cryptographic key custody, mandatory transparency of model weights and training data, and the institutional design of regulated transparency).

The work is comparative in scope — drawing on the United States Committee on Foreign Investment regime (CFIUS), the United Kingdom National Security and Investment Act (NSIA), the German Außenwirtschaftsverordnung (AWV), and the French «Investissements Étrangers en France» regime — but Italian in its primary subject. Its purpose is not advocacy but operational: to provide a usable framework for institutional counsel and policy designers operating at the edge of the contemporary regulatory landscape.

02

Adjacent Research Lines

Lines of work running alongside the principal thesis. Some will resolve into standalone papers; others into chapters of Hybrid Sovereignty.

L·01

Cross-jurisdictional Regulatory Conflict

The structural collisions between EU, US, and APAC regulatory regimes when applied to platform-scale infrastructure.

  • GDPR Article 49 derogations versus CLOUD Act compelled disclosure
  • EU AI Act Annex III versus US sector-specific AI guidance
  • Schrems II adequacy and the architecture of data transfers
  • NIS2 supply-chain obligations versus extraterritorial export controls

L·02

Sovereign Technology Funds — Operating Doctrine

Comparative study of state-owned technology investment vehicles and the institutional design that distinguishes capital allocation from regulatory capture.

  • Cassa Depositi e Prestiti, Italy
  • Bpifrance and the French sovereign equity programme
  • Mubadala, Temasek, GIC — APAC sovereign capital model
  • The German Zukunftsfonds and the European Tech Champions Initiative

L·03

Institutional Response to Platform-Scale Infrastructure

How national institutions adapt — or fail to adapt — to infrastructure operated at a scale that exceeds the traditional unit of regulatory analysis.

  • The DMA gatekeeper regime and structural separation
  • The institutional design of regulated transparency under the DSA
  • National-security review of cross-border cloud arrangements
  • Foundation-model governance under the AI Act and the GPAI Code of Practice

03

Publication & Distribution

Hybrid Sovereignty will be published under Mirafiore Editore, the holding’s private imprint, in 2026. First edition will be a numbered hardcover with limited institutional distribution; trade paperback and embargoed PDF editions will follow on a calendar to be determined.

Working papers and structured commentary on adjacent research lines may be distributed earlier under limited circulation to engagement clients and institutional partners. Such distribution is governed by bilateral non-disclosure.

Institutional partners with relevant fact patterns — ministries, sovereign-adjacent bodies, regulatory authorities, research centres — may approach the holding for commissioned work in the adjacent research lines. All such engagements proceed by written brief.

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