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EEDWorkflowEU

EU Energy Efficiency Directive Data Centre Reporting Workflow

A workflow for deciding which EU data centres are in scope, assigning owners, collecting energy-performance evidence, and preparing annual reporting.

Use it to organize Article 12 and Annex VII data before submitting to the European database and publishing required information.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
5 sections8 primary sources
Overview

Article 12 of Directive (EU) 2023/1791 requires Member States to make owners and operators of data centres with of at least 500 kW publish specified energy-performance information. This workflow turns that requirement into an operational sequence for facilities, data-centre operations, sustainability, legal, and reporting teams.

Section 1

1. Build the in-scope data centre inventory

Start with a site-by-site inventory for EU facilities and mark the installed information technology power demand for each data centre. The Article 12 reporting threshold is at least 500 kW of .

is the threshold input. Do not substitute total facility connection capacity, utility consumption, nameplate generator capacity, or a momentary IT load unless the applicable reporting methodology treats that figure as installed IT power demand.

Record why each site is in scope, out of scope, or excluded. The Directive excludes data centres used for, or providing services exclusively with the final aim of, defence and civil protection. Recital 86 also frames the obligation around spaces and equipment serving primarily or exclusively data-related functions, such as server rooms and associated cooling, lighting, battery arrays, and uninterruptible power supplies.

  • Facilities owner: maintain the EU site list, municipality, operational start date, floor area, and installed power evidence.
  • Data centre operations owner: confirm which server-room spaces and associated equipment are counted in the data-centre boundary.
  • Reporting owner: document the calculation or source record used for and keep it separate from whole-facility energy-use metrics.
  • Legal or public-sector customer owner: confirm whether a defence or civil-protection exclusion is being relied on.
  • Sustainability owner: keep the final in-scope inventory aligned with annual reporting preparation.
Section 2

2. Collect Annex VII data for the last full calendar year

For each in-scope data centre, collect the minimum information listed in Annex VII before the annual submission window. Separate standing site attributes from annual performance metrics so the team can reuse stable fields while refreshing the prior-year performance data.

The annual evidence pack should include data-centre identity and ownership, floor area and installed power, annual incoming and outgoing data traffic, data stored and processed, and key performance indicators covering energy consumption, power utilisation, temperature set points, waste heat utilisation, water usage, and renewable-energy use.

  • Site attributes: data-centre name, owner and operator names, start-of-operations date, municipality, floor area, and installed power.
  • Digital activity metrics: annual incoming data traffic, outgoing data traffic, and amount of data stored and processed.
  • Energy and performance metrics: energy consumption, power utilisation, temperature set points, waste heat utilisation, water usage, and use of renewable energy.
  • Method basis: map KPI calculations to the methodology in Annex II to Delegated Regulation (EU) 2024/1364.
Section 3

3. Run evidence checks before reporting

Treat the reporting file as a controlled evidence pack, not a one-off spreadsheet. Each metric should trace to the source system, meter, facility record, platform export, procurement record, or calculation workbook used to produce it.

Before approval, check that the data covers the last full calendar year, that site boundaries match the in-scope inventory, that confidential or trade-secret information is reviewed before publication, and that explanations exist for material changes from the previous reporting cycle.

  • Scope check: , site boundary, owner/operator names, and exclusion decisions are documented.
  • Completeness check: every Annex VII category has a value, a documented reason for no value, or a clear escalation owner.
  • Consistency check: energy, water, renewable-energy, waste-heat, and temperature-set-point data align with the systems of record used by facilities and sustainability teams.
  • Publication check: legal reviews any information withheld under Union or national rules protecting trade and business secrets or confidentiality.
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Section 4

4. Submit and publish on the annual cadence

Use 15 May as the normal annual reporting checkpoint. The Commission announcement for the delegated regulation stated that operators report KPIs to the European database by 15 September 2024 for the first cycle and then by 15 May in 2025 and subsequent years.

After submission, retain the submitted data, approval record, publication review, and evidence links. The Commission database is public at an aggregated level, and the Commission has published analysis of data submitted in the 2024 reporting period, so teams should expect their data to support sector-level assessment.

  • Reporting lead: owns platform access, submission status, and the annual 15 May reporting calendar.
  • Facilities and operations: provide source data early enough for validation and correction before approval.
  • Legal: confirms what can be publicly available and what is protected by trade-secret or confidentiality rules.
  • Sustainability or energy lead: compares the submitted metrics against efficiency actions, waste-heat reuse plans, water use, and renewable-energy sourcing.
Section 5

5. Track updates and improvement actions

Do not close the workflow at submission. Article 12 links the reported data to Commission assessment, possible further measures, minimum performance standards, and the feasibility of a transition toward a net-zero emission data-centres sector.

Maintain a change log for Commission guidance, database instructions, delegated-regulation updates, and internal changes that affect scope or metrics. For data centres with equal to or greater than 1 MW, Article 12 also says Member States shall encourage owners and operators to take account of the European Code of Conduct on Data Centre Energy Efficiency best practices.

  • Regulatory watch: monitor Commission data-centre reporting guidance, database user instructions, and rating-scheme updates.
  • Operational watch: flag new builds, expansions, closures, ownership changes, metering changes, cooling changes, and renewable-energy sourcing changes.
  • Improvement watch: track actions on energy consumption, water usage, waste-heat utilisation, cooling effectiveness, demand-side flexibility, and renewable-energy use.
  • Leadership review: review annual metrics against investment plans before the next reporting cycle starts.
Primary sources

References and citations

European Commission: Energy performance of data centres
energy.ec.europa.eu5 citations
Referenced sections
  • Commission overview of data-centre monitoring and reporting, the European database, reporting support resources, aggregated dashboard, and Commission assessment work.
  • Confirms that the EED introduced monitoring and reporting for data-centre energy performance and that the European database covers data centres with significant energy consumption.
  • Identifies the Commission-prepared European database and guidance resources for reporting data-centre energy performance and water footprint.
Show 2 more
  • Confirms the European database, the Commission's aggregated dashboard, and the July 2025 analysis of data submitted in the 2024 reporting period.
  • Identifies Commission reporting guidance resources and the planned Data Centre Energy Efficiency Package described on the Commission data-centre page.
"energy performance and water footprint of data centres"
More quoted passages
"introduced an obligation for the monitoring and reporting"
"collects and publishes data"
"analysis of the data submitted in the 2024 reporting period"
"Data Centre Energy Efficiency Package"
Commission adopts EU-wide scheme for rating sustainability of data centres
energy.ec.europa.eu2 citations
Referenced sections
  • Commission announcement sources support the delegated regulation, KPI reporting cadence, Article 12 publication requirement, and sustainability-rating purpose.
  • Grounds the first reporting deadline and the recurring 15 May annual cadence for KPI reporting to the European database.
"report the key performance indicators to the European database"
More quoted passages
"by 15 May in 2025 and subsequent years"
Commission Delegated Regulation (EU) 2024/1364
eur-lex.europa.eu2 citations
Referenced sections
  • Delegated regulation establishing the first phase of the common Union rating scheme for data centres and the KPI reporting framework.
  • Supports using the delegated regulation as the source for the common Union rating scheme information and KPI methodology.
"establishment of a common Union rating scheme for data centres"
More quoted passages
"common Union rating scheme for data centres"
Directive (EU) 2023/1791, Annex VII
eur-lex.europa.eu
Referenced sections
  • Lists the minimum information to monitor and publish for data centres covered by Article 12, including site details, activity data, and annual performance KPIs.
"MINIMUM REQUIREMENTS FOR MONITORING AND PUBLISHING"
Directive (EU) 2023/1791, Article 12
eur-lex.europa.eu
Referenced sections
  • Requires covered owners and operators to make Annex VII information publicly available while preserving applicable trade-secret and confidentiality protections.
"except for information subject to Union and national law"
Directive (EU) 2023/1791, Article 12 and Article 33
eur-lex.europa.eu
Referenced sections
  • Supports tracking Commission assessment, possible minimum performance standards, the data-centre rating scheme, and the 1 MW best-practices encouragement.
"minimum performance standards"
Directive (EU) 2023/1791, Article 12 and Recital 86
eur-lex.europa.eu
Referenced sections
  • Grounds the 500 kW installed IT power threshold, the defence and civil-protection exclusion, and the data-centre boundary language for primarily data-related spaces and associated equipment.
"with a power demand of the installed information technology (IT) of at least 500kW"
Directive (EU) 2023/1791, Energy Efficiency Directive
eur-lex.europa.eu
Referenced sections
  • Primary legal source for Article 12 scope, exclusions, annual public-information obligation, European database, 1 MW best-practices encouragement, Article 33 delegated acts, and Annex VII reporting fields.
"By 15 May 2024 and every year thereafter"

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