DIGITALEUROPE’s response to the public consultation on a reporting scheme for data centres in the EU

Executive summary

DIGITALEUROPE welcomes efforts to better understand the energy and sustainability impact of data centres in Europe and supports the European Commission’s efforts to establish a common Union rating scheme for data centres. Below, we have outlined our key recommendations for the initial phase of this process: a reporting scheme for data centres in the EU.

• First-year reporting should be done against the specifications set in Annex VII of the Energy Efficiency Directive (EED), with flexibility and additional safeguards for the information provided under point b) of Annex VII.
• Leniency and flexibility should be applied regarding point b) KPIs set out in Annex VII.
• The European database should be established by the Commission by 1 March 2024 to allow sufficient time for operators to provide input.
• The Commission should clarify which exact data points colocation and co-hosting operators will be able to disclose by 2026 pending availability.
• Annex VII of the EED and the four Annexes of the Draft Delegated Act (DDA) should be in alignment. Several indicators that were included in Annex II were not consulted upon during the Technical Assistance Study and should be removed from the DDA at this time.
• Data centres should be required to report once, on the same consistent set of information to avoid duplicative reporting and undue administrative burden.
• Clarity is needed on what data will be made publicly available.
  Measures are required to prevent the disclosure of confidential business information. To prevent risks of public disclosure, DIGITALEUROPE recommends the reported data be erased by the Commission, European database and Member States within two years from the date they are reported.