EU Data Centre Sustainability Reporting Obligations Now in Effect

Under Commission Delegated Regulation (EU) 2024/1364, data centres across the European Union are now required to report key sustainability metrics. The Regulation supplements the Energy Efficiency Directive (EU) 2023/1791, and while Ireland has yet to transpose the Directive into national law, the Regulation is directly applicable and enforceable.

First EU-Wide Deadline Approaches

Despite missed deadlines related to the Directive’s transposition in Ireland, operators must comply with the Regulation's first reporting deadline on 15 September 2024. Subsequent reports will be due annually by 15 May.

Who Is Affected?

The reporting obligations apply to operators of data centres with an installed IT power demand of 500 kW or more.

What Must Be Reported?

Operators must upload two types of data to a new European Commission database:

• Annex I – General facility details, including ownership, location, and type
• Annex II – Key Performance Indicators (KPIs), such as:

o Installed IT power and floor area
o Total energy use and renewable energy share
o Battery storage capacity
o Water usage
o Waste heat reuse potential

Limited Flexibility: "Comply or Explain"

For the first reporting period only, operators unable to collect specific KPIs for technical reasons may “comply or explain”, justifying omissions in their submissions.

Immediate Steps for Operators

With the Commission’s data portal expected to go live before September 2024, operators are urged to:

• Begin collecting the required data now
• Establish internal processes to ensure timely annual reporting

While legislative delays persist in Ireland, EU-wide reporting obligations are in full effect. Data centre operators must prepare to meet the September 2024 compliance deadline, or risk regulatory consequences.