Air-gapped ad tech: what an air-gapped network means and when rules require one

Buyers and vendors use "isolated", "sovereign", "dedicated" and "air-gapped" as if they were one thing. They are not. The table orders the levels by how much connectivity remains.

A classified region is not air-gapped from everything. AWS describes dedicated connectivity from a customer's network into its Secret Cloud (AWS). It is cut off from the public internet, not from its users. Our comparison of sovereign cloud providers covers the connected sovereign offerings in detail.

The legal weight differs by source. A statute binds directly; a contract clause binds the parties who sign it; a certification scheme binds only those who seek the label. The table labels each source we read.

The last row is an editorial judgement, not a finding from a statute. None of the public texts in the table uses the words "air gap". Classified information is handled under separate national security rules that this page does not cover.

FedRAMP. Agencies still categorise systems as low, moderate or high impact under FIPS 199. FedRAMP's 2026 classes "loosely align" with those baselines, but the programme says there is "not a direct correlation between FedRAMP Certification Class and Impact Level" (FedRAMP, classes). The first 20x Class A certification was granted on 25 August 2026, and the first full Class C on or before 2 November 2026 (FedRAMP, 2 November 2026).

FedRAMP also says commercial cloud services "are not usually federal information systems". They are components used by one, unless built for the government or run on its behalf under contract (FedRAMP, classes). That matters for an ad platform used by an agency's marketing team.

IL5. Microsoft's summary of the guide says IL5 covers controlled unclassified information that needs more protection than IL4. Microsoft quotes the guide as treating a FedRAMP High authorisation, supplemented with DoD "FedRAMP+" controls, as a basis for IL5. IL5 requires physical separation from non-federal tenants and accepts logical separation between federal ones (Microsoft Learn, IL5).

IL6. IL6 "is reserved for the storage and processing of information classified up to the SECRET level". It needs a DoD or federal community cloud whose entire infrastructure is "dedicated and separate" from other offerings (Microsoft Learn, IL6). Microsoft's pages are dated April 2023 and updated October 2024, so the current guide on DISA's site should be checked before relying on section numbers.

What French policy says. Rule 9 of the state cloud doctrine applies when a commercial cloud would hold data whose breach could harm public order, security, health or intellectual property. That cloud must hold SecNumCloud or an equivalent European qualification and be protected from unauthorised access by third-country authorities (numerique.gouv.fr). The doctrine binds state administrations, not private companies.

Who holds the label. ANSSI's catalogue of 27 October 2026 lists qualified cloud services from Thales Cloud Sécurisé (S3NS), OVH, Orange Business and Outscale. Outscale's qualification runs to 30 November 2026 (ANSSI catalogue).

A SecNumCloud service is a connected public or private cloud with strict operating rules, not an air gap. The EU's own scoring model for sovereignty is explained in our guide to the EU Cloud Sovereignty Framework. Country rules on where data must be stored are in data residency requirements by country. A sovereign cloud addresses jurisdiction and control; an air gap addresses connectivity.

This section is our analysis of realistic cases, not a legal finding. The facts that change the answer are whose data is processed, whether the service is run on behalf of the government, and whether any classified or controlled information touches the ad system.

1. An agency or defence contractor buying media. The ads run on the public internet, so the delivery path cannot be air-gapped. What may be controlled is the buyer's own data, such as uploaded CRM lists or applicant data. If that data is controlled unclassified information, DFARS and CC SRG terms in the contract can reach the platform that stores it.
2. Advertising inside a closed network. Base television, ship and aircraft entertainment systems, and screens in secure facilities can show messages on networks with no internet path. Here an ad server, scheduler and proof-of-play log can run fully offline. Our guide to programmatic DOOH platforms covers the connected version of the same screens.
3. A bank, utility or health system marketing its own services. Its marketing data usually sits in corporate IT, separate from operational networks such as plant control systems. Isolation demands here come from the organisation's security policy and vendor contracts.
4. A clean room for highly sensitive data. Some data owners require analysis inside their own perimeter with only aggregates released. That is isolation by design and contract, usually with network egress controls rather than an air gap.

Each row describes the dependency in general terms. Vendors differ, and a specific product's documentation decides the detail.

The pattern is clear. Anything that depends on the open market, outside measurement or shared identity stops at the gap. Anything that serves known campaigns to a known audience can run inside it. Self-hosted components make the offline set larger: see self-hosted DSP infrastructure requirements and the Prebid Server self-hosting guide.

Each point below turns a vague "air-gapped" into a term both parties can test.

• Isolation level: which row of the isolation table is meant, in words both parties can audit.
• Data classes: which data must stay inside (campaign data, audience data, logs), and which may leave in aggregate.
• Transfer method: manual media, one-way transfer or a monitored link, and who approves each transfer.
• Updates: how software, security patches and vendor lists are brought in and verified.
• Evidence: which audit reports apply, such as a SOC 2 Type II report or a FedRAMP class; see SOC 2 for ad tech platforms.
• People: whether vendor staff need clearances or must be resident in a given country.

Our ad tech compliance hub links the related legal pages.

1. NIST Computer Security Resource Center, Glossary, "air gap" (source: CNSSI 4009-2022 from IETF RFC 4949 Ver 2). https://csrc.nist.gov/glossary/term/air_gap
2. 48 CFR 252.239-7010, Cloud Computing Services (JAN 2023). eCFR (read through the eCFR API, 1 November 2026 version). https://www.ecfr.gov/current/title-48/chapter-2/subchapter-H/part-252/subpart-252.2/section-252.239-7010
3. Microsoft Learn, "DoD Impact Level 6 (IL6)" (page dated 4 April 2023). https://learn.microsoft.com/en-us/azure/compliance/offerings/offering-dod-il6
4. Microsoft Learn, "DoD Impact Level 5 (IL5)" (page dated 4 April 2023, updated 10 October 2024). https://learn.microsoft.com/en-us/azure/compliance/offerings/offering-dod-il5
5. 44 U.S.C. 3608, Federal risk and authorization management program. Legal Information Institute. https://www.law.cornell.edu/uscode/text/44/3608
6. FedRAMP, "Memo to Milestone: FedRAMP Grants the First Full FedRAMP 20x Class C Certification" (2 November 2026). https://www.fedramp.gov/2026-11-02-memo-to-milestone/
7. FedRAMP, "Choose a Class" (Consolidated Rules for 2026, checked 9 November 2026). https://www.fedramp.gov/2026/providers/start/class/
8. 10 CFR 73.54, Protection of digital computer and communication systems and networks. eCFR (read through the eCFR API). https://www.ecfr.gov/current/title-10/chapter-I/part-73/subpart-H/section-73.54
9. DINUM, "Les règles de la doctrine" (cloud au centre), numerique.gouv.fr (checked 9 November 2026). https://www.numerique.gouv.fr/offre-accompagnement/cloud-administrations/programme/
10. ANSSI, catalogue of certified, qualified and approved products and services (updated 27 October 2026). https://messervices.cyber.gouv.fr/visas/catalogue-produits-services-profils-de-protection-sites-certifies-qualifies-agrees-anssi.pdf