Europe’s Chips Act 2.0 Keeps Quantum Pilot Lines but Leaves Quantum Fabrication Out of Its Strategic-Project Priorities

September 17, 2026 – The European Quantum Industry Consortium (QuIC) said the European Commission’s Chips Act 2.0 proposal gives quantum fabrication no route to strategic-project status, the instrument the proposal uses to back an advanced semiconductor foundry. QuIC, a non-profit association of quantum companies, research organizations and investors founded in 2021, said it submitted the paper, Quantum in the Chips Act 2.0, as feedback on proposal COM(2026) 504 through the Commission’s Have Your Say portal and published it on its website.

The Commission adopted the proposal on June 3 as part of its Technological Sovereignty Package. It would repeal the 2023 Chips Act. It would continue the Chips for Europe Initiative, the act’s program for chip design, pilot lines and competence centers, and add photonic integrated circuits to it as a new component. It also introduces strategic projects, which can receive EU funding alongside co-investment from member states and industry, in six priority areas listed in Annex II.

Parliament and the Council will negotiate the text under the ordinary legislative procedure, with the Industry, Research and Energy Committee leading in Parliament and Oliver Schenk (EPP) as rapporteur.

For quantum chips, the proposal keeps a dedicated operational objective and the six pilot lines named in Annex I, one per hardware platform:

Annex I also provides for quantum design libraries, testing facilities and enabling technologies such as cryogenics and packaging. For the most mature developments, it provides support for first industrialization. The recitals state that the Commission’s evaluation of the 2023 act found the quantum chip pilots fit for purpose, and the explanatory memorandum says their impact will only become apparent later.

QuIC said the proposal “provides the language of industrialisation for quantum without an instrument capable of delivering it.” None of Annex II’s six priority areas is quantum. Quantum chips appear there once, as users of advanced chips, in the first area, European Advanced Semiconductor Manufacturing, which the annex says expands on Article 19 and for which it estimates public and private investment of €20–40 billion.

Of the 14 recommendations in QuIC’s December 2025 position paper, the consortium counted nine as not reflected in the proposal, four as partly reflected and one as discontinued. The discontinued item is QuIC’s request to keep the Integrated Production Facility status and open it to small in-house facilities that fail the first-of-a-kind test, which asks whether a facility brings an innovative process or product to the EU market. The proposal merges that status into a new one that keeps the test.

The Ten Gaps in QuIC’s Paper

QuIC tied each gap to the provision where it said the gap should have been addressed:

• No quantum area in Annex II, which the paper calls the only gateway to strategic-project status.
• An asymmetry with Article 19, which gives an open foundry for advanced semiconductors its own provision and top priority, while quantum foundries appear only inside the quantum objective in Article 5(c)(i).
• No route for small-scale and in-house production now that the Integrated Production Facility and Open EU Foundry statuses have been merged into one that still requires a first-of-a-kind facility.
• Uncertain eligibility under Article 14(6)(c), whose reference to advances in semiconductor technology could exclude trapped-ion, neutral-atom and superconducting facilities.
• No quantum indicator in Annex III, where the workforce indicator now reads “semiconductor and photonics” instead of the 2023 act’s semiconductors and quantum.
• Photonics at the wrong wavelengths, with a new photonics component built on silicon, silicon nitride and indium phosphide, no reference to ultraviolet, and visible light named only for augmented and virtual reality.
• No licensing route or exploitation obligation for moving publicly funded pilot-line processes and intellectual property into production.
• No multi-project wafer access and no metrology infrastructure.
• No quantum enabling hardware among the value-chain segments in Annex II point 6.
• No published criteria for the differentiation in support between platforms that Annex I says will be made.

QuIC’s Recommendations and the Quantum Act Boundary

QuIC said it was not asking Europe to build a quantum foundry this year, because many quantum processes are not ready for a production line and volumes remain low. It asked Parliament and the Council to add quantum chip manufacturing to Annex II so that a quantum foundry could become a strategic project once processes mature. As a fallback, it asked for a recital, one of the regulation’s explanatory preamble paragraphs, committing to add quantum later by delegated act, an amendment the Commission adopts under the regulation and that Parliament or the Council can block.

It also asked for a European multi-project wafer and shuttle program with reserved capacity, subsidized access for small companies and academic groups, and a published run calendar. Its other requests covered cryogenic characterization and qualification, packaging, metrology, licensing roadmaps from each pilot line and a quantum extension of EUROPRACTICE, the service that gives universities access to design tools and foundry runs. An annex to the paper drafts ten quantum indicators for Annex III.

QuIC cited three US transactions as evidence of urgency. IBM committed more than $10 billion to quantum computing over five years on June 2, a plan that includes the Anderon quantum wafer foundry in Albany, New York, and on July 23 agreed to acquire HRL Laboratories, a developer of silicon spin qubits. On July 31 IonQ, a US maker of trapped-ion quantum computers, completed its purchase of SkyWater Technology, a US contract chipmaker. The paper said fabrication capacity that European quantum companies buy from specialized foundries is moving into companies that sell quantum computers, under voluntary and revocable commitments.

On the boundary with the Quantum Act, which the Commission has not yet proposed, QuIC said the Chips Act should keep what depends on semiconductor infrastructure, from fabrication and pilot lines to design kits, packaging, component supply chains and quantum chip industrialization. The Quantum Act, in QuIC’s view, should cover systems, applications, procurement, standards, certification and system-level skills. The Commission’s explanatory memorandum says the two acts will need coordinating.

The paper lists eight contributors from Tyndall National Institute, Bull, Equal1 Labs, Peak Quantum, Qilimanjaro Quantum Tech and QuIC, among them QuIC’s executive director, Cécile Perrault, and acknowledges Horizon Europe support under the QOMPASS grant.

My Analysis

I checked QuIC’s reading of the annexes. It is accurate on Annexes II and III and on the photonics wavelengths. Annex IV still describes the initiative as focused exclusively on semiconductor and quantum technologies, which QuIC reads as drafting drift given the Annex III change. QuIC left out a comparison that would have strengthened its case. In September, the US government finalized awards, paid out against milestones, for cryogenic CMOS design kits, quantum packaging and integrated photonics at 422 nanometers for trapped ions, the design enablement and visible-wavelength photonics that QuIC lists among European quantum companies’ needs.

Budgets and Priority Areas in the Chips Act 2.0 Proposal

The Commission put no budget figure on any component of the Chips for Europe Initiative 2.0, because funding under the EU’s next long-term budget, the 2028–2034 multiannual financial framework, can only be requested later, the explanatory memorandum says. Quantum shares that missing number with every other component, although Annex II attaches investment estimates to an advanced semiconductor fab, a memory fab and a leading-edge chip design program. Annex II point 6 presents its value-chain segments as examples and gives the European Semiconductor Board, made up of member-state representatives and chaired by the Commission, a key role in choosing them. The board could pick quantum enabling hardware without any change to the text, though nothing commits it to.

QuIC’s fallback, a delegated act adding quantum to Annex II after adoption, is available. In a July presentation to member-state officials in the Council’s industry working party, the Commission said Article 17 lets it update Annex II by delegated act after taking the board’s opinion, a power the explanatory memorandum’s summary leaves out. The same presentation calls the Annex II areas indicative, and the six Article 16(1) recognition criteria it lists do not refer to Annex II, so a quantum consortium could still seek strategic-project status without a listed area. The Commission designates strategic projects from proposals selected for funding by the Chips Joint Undertaking, the EU body that runs the Chips for Europe Initiative and co-funds the pilot lines, so the Joint Undertaking will decide through its calls how much room quantum gets.

What the US Department of Commerce Funded for Quantum Fabrication

The US Department of Commerce, which administers the chip subsidies in the 2022 CHIPS and Science Act, a US law separate from the EU’s Chips Act, has committed money this year to the kind of fabrication capacity QuIC wants Europe to fund. It signed nine letters of intent worth $2.013 billion with quantum companies and foundries on May 21, and I argued at the time that the package paid for factories and supply chains more than for research. Two foundries accounted for $1.375 billion of it, divided between $1 billion for IBM’s Anderon and $375 million for the Quantum Technology Solutions unit of GlobalFoundries, a US-based contract chipmaker. The final awards kept that split. Anderon’s award was finalized on September 16, and the company said its first quantum wafers are already running in Albany. GlobalFoundries’ award, finalized on September 8, pays for cryogenic CMOS process design kits, advanced packaging and heterogeneous integration across several quantum architectures, drawn over five years as milestones are met.

The $100 million award to Quantinuum, which builds trapped-ion quantum computers, covers low-loss integrated photonics at 422 nanometers, cryogenic control chips and optical components at trapped-ion wavelengths, according to its securities filing. Quantinuum said GlobalFoundries would fabricate its next-generation ion traps and control electronics on 300-millimeter wafers.

QuIC’s paper names design enablement, packaging and qualification as the binding constraint for European quantum companies and warns that if non-European foundries qualify cryogenic design kits first, European companies will have to move production. GlobalFoundries’ award covers the first two. The paper also says trapped-ion and neutral-atom platforms need photonics between 400 and 800 nanometers and in the near ultraviolet, a range that includes 422 nanometers.

GlobalFoundries does not appear in QuIC’s paper. It is the independent foundry among the US awards, a contract manufacturer that sells no quantum computers and already makes PsiQuantum’s photonic chips in Malta, New York. Had QuIC included it, the paper would have had a better example for its main request than for its warning about who owns foundries: an independent foundry paid to develop the design kits and packaging QuIC wants the Chips Act to fund. The department also received GlobalFoundries shares worth about $375 million at the issue price and holds shares in Quantinuum, one of GlobalFoundries’ quantum customers.

Anderon, HRL and SkyWater Are Three Different Kinds of Deal

QuIC’s paper places the three transactions within two months by counting from IBM’s June 2 release. IonQ agreed to buy SkyWater in January and completed the purchase on July 31. IBM and the Commerce Department announced Anderon under a letter of intent on May 21, twelve days before the June 2 release. IBM agreed to buy HRL on July 23 and completed the acquisition on August 26.

SkyWater was an independent contract manufacturer whose Minnesota fab has made D-Wave’s annealing processors for years, including the Advantage2 prototype in D-Wave’s March 2025 paper in Science. It now also makes the first chips for IonQ’s Superion 256 system, so the same fab serves its owner and D-Wave, one of IonQ’s competitors. IonQ has said SkyWater will keep serving all its foundry customers as a subsidiary under its own name. QuIC calls that a voluntary commitment rather than a regulatory guarantee, and I have not seen a public approval condition that would make it one.

Anderon moves capacity the other way. IBM has put its in-house quantum wafer process into a subsidiary that sells fabrication to other vendors, and Anderon’s website promises customers it will never compete with their products. Anderon sells no quantum computers, while IBM, its owner, competes with the hardware vendors Anderon wants as customers, the tension I raised in June. Anderon’s customer contracts will settle that, and I have not seen one published.

HRL was a research laboratory owned by Boeing and General Motors, and QuIC’s paper says it sourced nothing from European foundries or suppliers and names no European user of its fabrication. IBM’s Jay Gambetta told Reuters that HRL’s team, which makes its chips at its California facility, will start making them at IBM’s New York facility, as I reported in August.

IonQ is the only buyer among the three that took over an independent foundry, and the paper names no European company that uses SkyWater. For Europe, QuIC bases its case on the pattern and cites IonQ’s earlier European purchases: Oxford Ionics in the UK for about $1.075 billion, almost all of it paid in IonQ stock, and a controlling stake in ID Quantique in Switzerland.

Merchant Quantum Fabrication in Europe

QuIC’s paper says a European manufacturer that depends on a production line such as SkyWater’s has no European alternative to move to. That is right for a contract foundry at SkyWater’s maturity, with three qualifications.

The Dutch company QuantWare raised €152 million in May (equivalent to $178 million) to build KiloFab, a plant in Delft. QuantWare sells its own superconducting processors to other system builders under the Quantum Open Architecture model, and it has offered foundry services for other companies’ superconducting qubit designs since 2022. It now also sells packaging services. Its investors included Intel Capital and In-Q-Tel, the US intelligence community’s venture investor, alongside the Invest-NL Deep Tech Fund.

Quantum Foundry Copenhagen, owned by the Novo Nordisk Foundation, announced on September 4 a 5,300-square-meter chip fab due to open in 2027, as I covered at the time. The plant will offer wafer fabrication to quantum technology vendors worldwide on commercial terms. Henna Virkkunen, the Commission’s executive vice-president for technological sovereignty, welcomed the plant in the announcement, presenting it as building on the European Chips Act and the Quantum Europe Strategy.

The SPINS pilot line, coordinated by imec, plans multi-project wafer runs and standardized quantum process design kits for start-ups and small companies.

None of the three is yet a contract foundry on SkyWater’s scale. QuantWare’s foundry services cover superconducting designs only, and the Copenhagen plant opens in 2027. In imec’s own description, the multi-project wafer runs it is working toward for SPINS are research-grade. QuIC’s paper, published two weeks after the Copenhagen announcement, mentions neither QuantWare nor the Copenhagen fab.

The Quantum Act Timetable and Its Overlap With the Chips Act

The Commission has assigned quantum fabrication to both acts. Its Quantum Europe Strategy of July 2025 set the aim of building an EU quantum foundry under the Chips Joint Undertaking, according to the European Parliament’s summary. Its October 2025 call for evidence on the Quantum Act, which I covered at the time, listed scaling up industrial capacity, including pilot lines and a design facility, as the act’s second objective. The Chips Act 2.0 proposal contains no instrument for a quantum foundry and says consistency with the Quantum Act will provide a comprehensive European quantum policy framework.

The Quantum Act is behind schedule. The Commission’s 2026 work program placed it in the second quarter. Thomas Skordas, deputy director-general of DG CNECT, the Commission’s department for digital policy, said the Commission could present it late this year but that internal delays could push it into 2027, the regulatory news service MLex reported. At a September 3 event in the European Parliament, Skordas called the act more of an enabling framework than a regulation, and the Commission’s representative said “the act is not about budget,” according to a press release on the event.

QuIC warned that if each act treats quantum fabrication as the other’s job, no one is accountable for it. The Chips Act 2.0 text is already before Parliament and the Council, and the Quantum Act has not been proposed. If Parliament and the Council leave quantum out of Annex II on the assumption that the Quantum Act will handle fabrication, nothing the Commission has proposed so far would.

What Parliament and the Council Can Still Change

Adding a quantum priority area to Annex II commits no money by itself. If Parliament and the Council list a quantum area, the Chips Joint Undertaking gets a stated priority to write calls against, and nobody has to wait for a later delegated act.

Most of QuIC’s other requests could go into Annex I, which the Commission can amend by delegated act. Annex I point 3 already covers cryogenics, packaging and first industrialization, so a quantum multi-project wafer program, shared cryogenic qualification and a quantum extension of EUROPRACTICE would extend existing actions. Annex III can be amended the same way, and QuIC’s drafted indicators, including the share of pilot-line capacity used for production-grade external runs, already follow the annex’s format.

QuIC’s paper contains part of the case against committing to a quantum foundry now. It concedes that many processes are not ready for a production line. The Commission’s evaluation says the quantum pilots’ impact will only show later, and QuIC cites a Quantum Flagship roadmap update, still in preparation, that puts foundry-level operations for mature modalities in 2030–2035, behind a decision gate in 2030. A foundry designated before processes stabilize would be built around a guess about which platforms reach volume.

The Commerce Department is now shareholder, counterparty and regulator for most of the companies it funds, and Europe does not need to copy that arrangement. A filing by Rigetti, another award recipient, warns that this could complicate its deals and lead other governments to ask for equity, and one by D-Wave warns that a future court, Congress or administration could find the agreements “unauthorized, void or voidable.” None of QuIC’s requests would require equity stakes.

The EU’s own advanced-manufacturing strategic project envisages pilot production in 2030–2033, and the milestones in the three US awards whose terms were filed with securities regulators fall due by September 2031. The explanatory memorandum schedules the first evaluation report four to five years after the regulation starts to apply, which puts it no earlier than 2030.

Europe’s quantum companies fabricate their chips in Europe today, many of them through shared multi-project wafer runs, according to the QuIC members consulted for the paper. Parliament and the Council are deciding whether the regulation that will govern that work names quantum fabrication as a strategic-project area or leaves it to an act the Commission has not yet proposed.