Key takeaways
- The European Commission is consulting on possible minimum performance standards for data centres. The consultation opened on 21 September 2026 and closes on 14 December 2026 at 23:59 CET. No EU threshold has been set.
- The Commission says the answers will inform a legislative proposal planned for the second quarter of 2027. Its call for evidence states that the initiative’s timing and final content are not decided.
- Reporting under Article 12 of the Energy Efficiency Directive is a separate duty that already applies to sites with at least 500 kW of installed IT power. A reported figure does not pass or fail any EU standard today.
- The most useful operator response is a measured example: what a candidate indicator or threshold would mean at one real type of site, with its metering boundary, cost and constraints written down.
- Heat reuse and grid services depend on infrastructure outside the operator’s fence, such as a heat network or a grid connection. Evidence that shows this dependency is information a single EU-wide threshold could otherwise miss.
If the Commission proposes an EU performance floor for data centres, it will start from a thin evidence base. Its report of 21 September 2026 counts 770 data centres in the first round of EED reporting, around 36% of the sites it estimates were required to report, and bases its EU average PUE of 1.36 on the 681 of them that reported a reliable value. Only 67 of the 770 reported any reuse of waste heat.
Between now and 14 December, European data-centre operators can add their own measured data to that base. The public consultation is the one channel open to every operator. After it closes, input narrows to targeted workshops and the Commission’s preparatory study, and by the time a proposal appears its indicators will be largely set. This guide covers what is being decided, which evidence carries weight, and a worksheet for preparing it.
What is being decided, and what is not
The EU already requires qualifying data centres to report energy and sustainability data. Article 12 of Directive (EU) 2023/1791 covers data centres with an installed IT power demand of at least 500 kW, and the indicators and reporting format are set by Delegated Regulation (EU) 2024/1364. Our EED reporting guide explains that duty field by field.
On 21 September 2026 the Commission took two further steps. It adopted Delegated Regulation (EU) 2026/7000, which sets up a common EU rating scheme for data centres, and it launched a consultation and call for evidence on minimum performance standards. A rating scheme grades sites; a minimum performance standard would set a floor that a site has to meet. The consultation is about the second, and the Commission’s call for evidence says it wants to test the need for standards, their feasibility, their scope, the indicators to use and possible thresholds.
Nothing in the consultation sets a PUE limit, a compliance date or an exemption for small sites. Germany is a separate case with its own law, the EnEfG. Bill 21/8027, which would loosen the German PUE targets, had its first Bundestag reading on 24 September 2026 and went to committee. It is not law, and it does not decide the EU rule. Our regulation tracker keeps the status of each national and EU instrument in one table.
| Date | Step | Status |
|---|---|---|
| 2023 | Directive (EU) 2023/1791, Article 12: reporting duty for sites of 500 kW installed IT power or more | In force |
| 2024 | Delegated Regulation (EU) 2024/1364: indicators and reporting format; first report due 15 September 2024, then every 15 May | In force |
| 21 Sep 2026 | Delegated regulation on a common rating scheme adopted by the Commission (2026/7000) | Adopted; in force only after Parliament and Council scrutiny ends without objection |
| 21 Sep 2026 | Consultation on minimum performance standards opens | Open |
| 14 Dec 2026, 23:59 CET | Consultation closes (Commission listing) | Deadline |
| Q2 2027 | Legislative proposal | Planned; timing and content not decided |
The consultation closes 14 December
Get new guides on the EU standards and national rules every Monday, while there is still time to respond.
Why a measured example counts for more than an opinion
The consultation page invites data-centre operators and owners alongside equipment suppliers, grid and energy companies and public bodies, and asks for evidence on need, feasibility, indicators and thresholds. The Commission’s preparatory study names three tests any standard has to pass: technical feasibility, economic proportionality and administrative workability.
Those three tests decide what a useful answer looks like. A statement for or against a target tells the Commission very little. A site that shows its measured baseline, one realistic retrofit, what it would cost and how long the work would take gives the drafters something they cannot get from national averages. A new build and a constrained 15-year-old hall can report the same PUE figure and face very different costs to improve it. Only operators hold that comparison.
PUE, power usage effectiveness, is total site electricity divided by the electricity used by IT equipment. It is the indicator most readers will expect, and it has a known weakness: our containment and liquid-cooling worked case models a 1 MW site where direct liquid cooling on about 75% of the load cuts total energy by roughly 10.6%, yet PUE moves only from 1.46 to 1.41, because the server fan power it removes was counted as IT load. If a candidate indicator would reward or hide a change like that at your site, the consultation is the place to say so, with numbers.
Consultation evidence worksheet
Use this table to gather material before opening the official questionnaire. It is our editorial worksheet, not an EU form. Where data do not exist, leave the field blank and say why. Keep modelled gains separate from measured performance.
| Question to prepare for | Evidence to assemble | Context that makes the number usable |
|---|---|---|
| What does the site consume now? | Annual site electricity and IT electricity for the same period, the metering points and the share of the year covered. Compute PUE only when the two boundaries match. | Facility type and age, IT load as a share of design capacity, climate, redundancy level, missing meters. State whether each figure is measured, estimated or modelled. |
| How much water does cooling use? | Water input for the period and the boundary used; drinking-water share where known. | Cooling design, seasonal pattern and local water stress. A lower energy figure can move the burden to water. |
| How much heat could be reused? | Recoverable heat by temperature and season, heat actually delivered, and known demand nearby. | Distance to a heat network, seasonal match, who owns the connection, what the heat would replace, and cost. Heat at a cooling loop is not heat delivered to a customer. |
| Can the site support the grid? | Any flexibility or grid service the site already provides, with duration and limits, backed by meter data or a contract. | Local grid conditions, redundancy design and customer service levels. Battery capacity on paper is not a dispatchable service. |
| What would a retrofit take? | One or two realistic options with capital and operating cost, lead time, downtime and the modelled change in energy and water use. | Existing plant, rack density, the lease or ownership split, safety and resilience limits; sensitivity to IT load and electricity price. |
A sequence for the ten weeks to the deadline
- Start from your EED report. Take the figures already filed, and write down the reporting year, the facility boundary, the calculation method and the gaps. The EED guide lists the indicators and which of them are published.
- Model one decision. Pick an intervention the site could actually make, such as containment, a cooling retrofit or a heat-recovery connection, and show the inputs and the range of results. Do not predict an EU pass or fail while no standard exists.
- Name the constraints. Record where uptime commitments, the grid connection, water supply, customer contracts or the lack of a local heat buyer change the engineering answer. Give cost and lead time where you have them, and say so where you do not.
- Answer in the Commission’s own form. The consultation page links the questionnaire, accepts answers in any official EU language and requires you to register or log in before responding. Check its questions and the deadline again before you submit.
The deadline is 14 December 2026 at 23:59 CET. The Commission plans a proposal for the second quarter of 2027 and says its timing and content may change. Until there is a legal text, the practical steps are the ones above: build evidence that holds up, and stay compliant with the reporting rules and national laws already in force.
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