The European Union has reduced the number of companies directly subject to mandatory sustainability reporting. For data-centre operators, however, this is no regulatory all-clear. EU Taxonomy criteria, energy-efficiency rules and facility-level disclosure requirements follow different legal paths and may continue to apply independently of corporate reporting obligations. As capacity expands across Europe, the ability to measure and demonstrate energy performance, water use, waste-heat recovery and technical efficiency is becoming a strategic issue for operators and investors.

Data-centre growth is making that challenge increasingly urgent. According to the International Energy Agency, the sector consumed around 415 TWh of electricity worldwide in 2024, equivalent to approximately 1.5 per cent of global electricity demand. In its base-case scenario, the IEA expects consumption to rise to around 945 TWh by 2030, driven particularly by artificial intelligence, while future efficiency gains and available power-system capacity will influence the eventual outcome. [1]

Germany offers an indication of the pace of expansion in one of Europe’s largest data-centre markets. Bitkom and the Borderstep Institute calculated total IT connection capacity at German data centres and smaller IT installations at 2,980 MW in 2025, nine per cent more than the year before. [2] With that growth comes increasing scrutiny of how facilities consume energy and how reliably operators can document their environmental performance.

Three rules, three different purposes

The regulatory landscape becomes easier to understand once three key instruments are separated: the EU Taxonomy, the Corporate Sustainability Reporting Directive (CSRD) and the Energy Efficiency Directive (EED).

The EU Taxonomy is primarily a classification system. It determines whether an economic activity can be considered environmentally sustainable. To qualify as taxonomy-aligned, an activity must contribute substantially to at least one of the EU’s six environmental objectives, avoid significant harm to the others, comply with minimum social safeguards and meet the applicable technical screening criteria. [3]

For data centres, “data processing, hosting and related activities” fall under Activity 8.1. But eligibility alone is not enough. A facility may be covered by the Taxonomy without meeting the technical conditions required for alignment. [3]

The CSRD addresses a different issue: which companies have to disclose sustainability information. Directive (EU) 2026/470 has significantly reduced the number of companies directly covered. Under the revised framework, companies with more than 1,000 employees and net turnover above €450 million will in principle remain within scope, subject to national implementation by EU Member States. [4]

For operators, the message is straightforward: being outside the CSRD does not mean being outside sustainability regulation. Taxonomy requirements, technical energy rules and requests from customers, banks or investors can remain relevant.

Energy rules reach down to individual facilities

This distinction becomes particularly important under the Energy Efficiency Directive. EU Delegated Regulation 2024/1364 covers data centres with an information technology power demand of at least 500 kW. Operators must report indicators including energy consumption, water use and waste-heat utilisation. [5]

A company may therefore fall outside direct CSRD reporting while still operating facilities subject to energy-performance reporting. Large customers, financial institutions and public-sector organisations may also request the same data independently of formal reporting thresholds.

Germany illustrates how EU rules can be translated into national procedures. There, the threshold is based on the rated IT connection capacity, understood in practice as the maximum capacity for which the UPS systems serving the data-centre white space are designed. Operators submit their information through the German Energy Efficiency Register for Data Centres, from which the data is forwarded to the European database. German operators therefore do not report directly to the EU. [5]

For international readers, that national layer matters. Germany and Austria implement EU legislation through their respective domestic frameworks, while Switzerland, as a non-EU country, follows its own legislation. Swiss operators can nevertheless be affected indirectly where European customers, investors or corporate groups require EU-compatible sustainability data. In multinational portfolios, one compliance process cannot automatically be transferred from one jurisdiction to another.

Taxonomy requirements become engineering requirements

For data centres seeking Taxonomy alignment, sustainability moves quickly from compliance language into engineering practice.

Under Activity 8.1, the relevant “Expected Practices” of the European Code of Conduct for Energy Efficiency in Data Centres or the standard CLC/TR 50600-99-1 must be implemented. Compliance is subject to independent verification and must be reassessed at least every three years. Where individual practices cannot be implemented for technical, logistical or planning reasons, operators have to justify this; comparable alternatives may be accepted where they achieve similar energy savings. [6]

That has direct consequences for cooling, power distribution, monitoring and operating procedures. Refrigerant choice is one example: the technical criteria specify a maximum Global Warming Potential of 675 for refrigerants used in the cooling system. [6]

The requirements also extend beyond energy. Under the Do No Significant Harm, or DNSH, principle, an activity that contributes to one environmental objective must not seriously undermine others. For data centres, this brings issues such as physical climate risk, water availability, circular-economy requirements, waste management, reuse and recycling into the assessment. [6]

For planners, the conclusion is clear: sustainability performance cannot simply be documented after a facility has been built. It increasingly has to be designed into the infrastructure itself.

New builds need measurement by design – existing sites need transparency

For new projects, that means incorporating future verification requirements early. Site selection, power supply, cooling architecture, metering, waste-heat recovery and operational strategy should be planned not only for efficiency, but also for measurability.

A facility may perform well technically and still struggle to demonstrate that performance if the appropriate meters, data points and documentation structures were never installed. Adding them later can be expensive and disruptive. Monitoring should therefore be treated as part of the engineering architecture rather than an administrative add-on.

Existing facilities face a different task: making the installed base transparent. Retrofit assessments need to establish actual IT loads, consumption patterns and load profiles, while examining cooling generation and distribution, electrical systems, UPS infrastructure and operational management. Refrigerants, higher cooling-water temperatures, free cooling, containment, waste-heat recovery and more granular monitoring may all become part of the optimisation strategy.

The decisive factor is rarely one component in isolation. A highly efficient chiller or UPS cannot compensate for weak system design, unsuitable operating parameters or inadequate monitoring. In existing data centres especially, sustainability performance emerges from the interaction between technical architecture, operation, measurement and documentation.

Sustainability moves from reporting into operations

This changes the role of sustainability inside the data-centre organisation. Operators increasingly need reliable, auditable information on energy flows, refrigerants, water consumption, waste-heat potential and climate risk. The numbers must not only exist; they need to withstand scrutiny from regulators, customers, auditors, banks and investors.

Reduced CSRD obligations therefore do not eliminate the need for robust technical data. Even operators outside direct sustainability-reporting requirements may have to demonstrate facility performance to third parties.

For data-centre specialists such as Prior1, this means translating regulatory requirements into technical concepts for planning, construction, expansion, retrofit and operation. The aim is not simply to comply with individual rules, but to create infrastructure in which the relevant performance indicators can be measured, improved and verified over the long term.

Europe is preparing the next step: comparability

The EU’s current data collection may also lay the groundwork for a more fundamental change. The European Commission is assessing reported data-centre information and preparing a Union-wide rating and labelling system. A binding A-to-G classification comparable with familiar European energy labels does not yet exist for data centres, but the planned system is intended to improve comparability in areas including energy efficiency, water consumption, clean-energy use and waste-heat utilisation. [7]

If such performance becomes easier to compare, the consequences could extend beyond regulation. Efficiency could become a more visible criterion when customers choose providers, banks assess financing and investors evaluate assets. What begins as mandatory data collection could therefore evolve into a market benchmark.

Germany also shows how quickly national requirements can evolve. In June 2026, the German Federal Cabinet approved a draft amendment to the country’s Energy Efficiency Act – Energieeffizienzgesetz, or EnEfG. At the time of publication, the legislation was still progressing through the parliamentary process. [8] [9]

For non-German readers, the distinction is important: the EED establishes the European framework, while the EnEfG represents Germany’s national implementation and additional regulatory provisions. Other EU countries follow their own national legislative routes.

The broader lesson is more important than the detail of any one national law. Data centres are built for decades, while regulatory thresholds and sustainability metrics can change within years. Operators therefore need infrastructure capable of generating reliable information on energy, cooling, water, waste heat and other performance indicators throughout its operating life.

Fewer reports, higher expectations

The narrowing of the CSRD may reduce reporting obligations for some companies, but it does not reduce the technical sustainability challenge facing data centres. EU Taxonomy criteria, facility-level efficiency rules, customer demands and emerging benchmarking systems are all moving the industry towards greater transparency.

For operators, the relevant question is therefore shifting. It is no longer simply whether the company has to publish a sustainability report, but whether the facility can provide convincing evidence of how efficiently and sustainably it operates.

Energy efficiency, cooling architecture, refrigerants, water demand, waste-heat recovery, climate resilience and technical documentation are increasingly becoming part of the long-term quality of a data-centre asset.

Sustainability cannot be created retrospectively through reporting. It has to be built into the infrastructure – and, increasingly, it has to be measurable.

This article provides a professional overview and does not constitute legal advice. Specific obligations should always be assessed under the applicable national legislation.

Sources

[1] International Energy Agency: Energy and AI – Energy demand from AI
https://www.iea.org/reports/energy-and-ai/energy-demand-from-ai

[2] Bitkom / Borderstep Institute: Rechenzentren in Deutschland: Update 2025
https://www.bitkom.org/sites/main/files/2025-11/bitkom-studie-rechenzentren-in-deutschland-2025.pdf

[3] Regulation (EU) 2020/852 – EU Taxonomy Regulation
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0852

[4] Directive (EU) 2026/470
https://eur-lex.europa.eu/eli/dir/2026/470/oj

[5] Commission Delegated Regulation (EU) 2024/1364
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1364

[6] Commission Delegated Regulation (EU) 2021/2139 – consolidated version
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R2139-20260101

[7] European Commission: Energy performance of data centres
https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-rules/energy-efficiency-directive/energy-performance-data-centres_en

[8] German Federal Ministry for Economic Affairs and Energy – Federal Cabinet decision, June 2026
https://www.bundeswirtschaftsministerium.de/Redaktion/DE/Pressemitteilungen/2026/06/20260624-bundeskabinett-beschliesst-eeg.html

[9] German Bundestag – legislative procedure concerning implementation of the Energy Efficiency Directive
https://dip.bundestag.de/vorgang/gesetz-zur-beschleunigung-der-umsetzung-der-energieeffizienzrichtlinie/336643

So ist er aus meiner Sicht deutlich näher an einem EURO SECURITY EMEA-Fachartikel: weniger „Regelwerk Punkt für Punkt“, mehr These → Konsequenz → Praxis. Vor allem habe ich die vorher vielen Ein- und Zwei-Satz-Absätze zusammengezogen; dadurch liest sich der Text flüssiger, ohne die regulatorischen Details oder Fußnoten zu verlieren.