While the data centre industry is on the rise, operators have new hurdles to overcome: reporting requirements.

New regulations are emerging, particularly in the EU, that require operators to annually disclose details such as energy consumption, water usage, and waste heat reuse.

From international requirements like the EU Energy Efficiency Directive (EED) and the Corporate Sustainability Reporting Directive (CSRD) to local market rules like Germany’s Energieeffizienzgesetz (EnEfG), there’s a new generation of demands that have added to the myriad of existing compliance mechanisms for operators.

Questions remain over whether the industry is addressing the vast volumes of data required to preference to manage energy requirements, let alone every other metric such directives are looking at.

Dorothy Maguire, Director Sustainable Infrastructure - Deloitte (moderator)
John Booth, Technical Director, National Data Centre Academy & Consultant - Carbon 3iT
Luisa Cardani, Head of Data Centres Programme - techUK
Sarah Peterson, Managing Director - Clear Sustainability
Mark Moloney, Sustainability Director - CyrusOne
Andy Lawrence, Executive Director of Research - Uptime Intelligence

Managing both national and international reporting requirements for data centres in 2025 has increased the complexity operators face.

Luisa Cardani, head of data centres programmes at techUK, noted that the industry is already incredibly complex and until recently, has not been exposed to such a level of scrutiny.

Because the data centre industry has not been subject to such scrutiny before, Cardani said that its meant some operators going “bananas” trying to understand why all of sudden they’re being grilled.

“They say: ‘We were doing fine before you came when,’ when in reality, I can see why they think that they're doing great, but the rest of the world has no visibility of that. With policies like the EED and others around sustainability, it's about finding data that then will then refine the policy or the law to get better outcomes.”

The EU’s Energy Efficiency Directive (EED) was the central regulation discussed during the debate.

Designed to promote energy efficiency across the EU, it includes data centre-specific requirements, including:

• Mandatory Reporting: Data centres must report their energy performance annually, including metrics like energy consumption, Power Usage Effectiveness (PUE), waste heat utilisation, and renewable energy use.
• Waste Heat Utilisation: Sites with a capacity over 1 MW are encouraged to utilise waste heat unless it is technically or economically unfeasible.
• Renewable Energy Integration: The legislation features a strong emphasis on promoting the use of renewable energy sources to reduce carbon footprints.
• Energy Efficiency Measures: Facilities are also expected to implement measures to optimise energy consumption, such as improving cooling systems and using more efficient IT equipment.

John Booth, managing director and principal consultant at Carbon 3iT and technical director of the National Data Centre Academy, pointed out that initial reporting challenges arose due to delayed timelines and inconsistent national portals, suggesting improvements were necessary for clearer outcomes.

Beyond those initial challenges, operators have faced issues around reporting data points they may not have ownership of, as Mark Moloney, sustainability director at CyrusOne, which operates data centre sites across Europe, said: “We can’t share something we don’t have or have ownership of.”

“With customer-specific data points, like server capacity, storage capacity, and bandwidth capacity, they're just numbers we didn't have. The other question is, why do [the regulators] want them? Why do you want that information? Surely this is about data centre efficiency, so I don't it.”

Data centres in the UK aren’t bound by the EED following the country’s departure from the EU. However, the UK is considering introducing its own energy efficiency rules for data centres.

techUK’s Cardani observed that the UK's unique position in learning from EU implementation experiences potentially leads to more effective future policies, though she expressed that some of the country’s operators remain uncertain.

“We have a lot of members worried because they're not entirely sure how to provide the data. With contracts and non-disclosure agreements, it becomes very difficult to provide some of that information.”

Andy Lawrence, executive director of research at the Uptime Institute, noted that despite these complexities, the directive has had a positive impact on improving data collection practices.

According to Lawrence, Europe’s data centres are already showing better reporting numbers compared to their global counterparts as a result of the EED, though overall data collection remains surprisingly low in areas such as water usage, carbon emissions, and server utilisation.

He further warned that a lot of the data, even some simple points, aren’t being collected well, adding: “Scope Two carbon emissions, I would have thought quite easy, but it’s like 40-40%, with Scope Three more like 15%.

“It's too early to know if it's going to have an effect. But people are getting ready for it,” Lawrence said. “I think there are a lot of banana skins for the operators coming along and for the regulators, but they're going to be in phase two and phase three when we get to the more prescriptive things that are going to come down the line.”

Booth highlighted upcoming challenges with phase two of the EED, specifically noting the introduction of a minimum energy performance rating scheme as a significant concern.

He questioned the criteria upon which ratings would be based, pointing out inherent advantages for countries with decarbonised energy grids, such as France, Norway, and Sweden, over those with more carbon-intensive grids like Germany and Poland.

Booth also criticised the EU's decision to increase the reporting threshold from an original proposal of 100 kilowatts to 500 kilowatts following lobbying from the telecom sector.

He advocated for aggregating smaller sites, suggesting this would ensure more comprehensive industry reporting and potentially reduce the threshold further.

“If you look at all of a telco operator's estate, it's going to be potentially as big as a quite large colocation, and they should be reporting, and yet, they've managed to escape the net.”

Balancing stringent regulations with maintaining competitiveness remains a critical challenge for the data centre industry and was a recurring theme throughout the panel discussion.

CyrusOne’s Moloney underscored the importance of not over-regulating the European market, cautioning that overly restrictive measures could push operators to relocate to regions with less demanding environmental standards.

“We need to ensure Europe remains a viable place to do business,” he said. “The reality is, sustainability measures, when managed correctly, actually reduce costs, but the regulations must remain sensible and flexible enough not to inadvertently harm Europe's competitive position globally.”

Sarah Peterson, managing director at advisory firm Clear Sustainability, echoed the need for balanced regulations but urged operators to engage more actively with policymakers rather than taking a defensive stance.

“The data centre industry has historically tried to regulate itself, believing it was doing a good job due to its economic contributions,” Peterson said. “But we cannot just rely on the claim that we create jobs as a shield. The reality is that regulations are coming regardless, and we should engage proactively to shape them.”

Peterson emphasised that transparency and active collaboration with regulators would help create legislation that genuinely reflects the industry's operational realities, reducing unintended consequences and compliance burdens.

Uptime’s Lawrence further highlighted the risk of unintended consequences, citing examples such as overly prescriptive temperature controls, which might inadvertently increase overall energy use or restrict technology adoption, including advanced AI solutions.

He argued for a cautious, evidence-based approach to future regulatory developments, stressing the need for ongoing dialogue between industry stakeholders and policymakers to ensure regulations are both effective and practical.

Looking ahead, with even more rigorous reporting requirements on the horizon, the panel agreed that environmental reporting would likely broaden, extending to areas such as water usage, biodiversity impacts, and enhanced transparency on Scope 2 and Scope 3 carbon emissions.

Booth noted that increasing scrutiny around sustainability practices would inevitably lead to more detailed and potentially burdensome reporting frameworks.

He encouraged operators to prepare proactively rather than reactively, suggesting that those who adapt quickly could leverage reporting as a competitive advantage.

Cardani predicted further alignment between UK and EU regulations, as the UK closely monitors the EU's implementation of EED and similar policies. She emphasised the opportunity for UK-based operators to influence more streamlined and effective reporting processes based on lessons learned from Europe’s early experiences.

CyrusOne’s Moloney highlighted the industry's readiness, noting that many operators had already begun preparing their systems and data collection practices in anticipation of increased scrutiny. However, he urged caution against overly prescriptive regulations that might negatively impact Europe’s competitive standing.

Peterson reiterated the importance of active industry engagement with policymakers. She argued that ongoing dialogue and collaboration were essential to ensuring future regulations reflect practical industry capabilities and lead to genuine sustainability improvements.

Ultimately, the panellists agreed that collaboration between operators, industry bodies, and regulators would be crucial in navigating the increasingly complex landscape of reporting requirements, ensuring a balance between operational feasibility, sustainability goals, and competitive viability.