The Netherlands published 2025 Energy Efficiency Directive (EED) reports (detailing 2024 operating data) for 104 data centers; an increase of 24 facilities compared with the number of data centers that reported data in 2024 (for the 2023 operating year). The number of reporting data centers is still significantly below the estimates for the total number of data centers in the Netherlands provided by Cloudscene (289), datacentermap.com (194) and the Dutch Data Center Association (184).

The submitted data is also incomplete: 27% of the facilities representing 48% of the total reported data center space did not provide total and IT energy use. By extension, this means these facilities did not report PUE or water usage effectiveness (WUE) metrics (Table 1). While this report addresses only the data reported in the Netherlands, Uptime Intelligence's previous analysis of the European database data published by the European Commission for the 2023 operating year indicates that the problems of missing and incomplete data submissions can be expected to extend to the full European dataset for 2024 (see Uptime Institute EED survey responses: data center labeling and rating process, data reporting improvements).

Table 1 Netherlands’ energy use and data center space values for operating years 2023 and 2024

The Netherlands data for the 2024 operating year denotes two ongoing problems relating to compliance with the EED reporting requirements:

1. Many data centers are not aware of — or have chosen to ignore —the EED data reporting mandate.
2. A significant number of those that do report choose to withhold data based on confidentiality concerns or claims that tenants will not provide the data.

The submitted data that details total and IT energy use, water use and renewable energy use indicate that the PUE, water use effectiveness (WUE) and renewable energy factor (REF) closely match the metrics supplied from the 2023 operating year data (Table 3). The question remains: how would the data profile change if all data centers submitted their information and KPIs to the database?

Key missing data

Number of data centers

The exact number of data centers in the European Union is unknown. A search of data services and associations that track facilities reveals estimates for the Netherlands that range from 184 to 289. The inventories capture an unspecified mix of co-hosting/cloud, colocation and telecoms facilities, but ignore enterprise data centers. Additionally, the information does not identify whether the inventoried facility has the 500 kW or more of connected power or installed IT power demand that triggers reporting to the EU database on data centers. Most, if not all, colocation and co-hosting facilities will exceed this threshold, while some telecoms data centers managing regional or local traffic, as well as enterprise data centers, may not.

An additional 27 Netherlands data centers submitted data reports for the 2024 operating year, compared with 2023. Five of these data centers began operations in 2023, 2024 or 2025; the remainder started operations between 1977 and 2021. Five data centers that submitted reports for 2023 did not report for 2024; all these data centers were older, suggesting they may have been decommissioned.

Most of the growth in reporting for 2024 came from enterprise (12) and co-hosting data centers (10); groups that were underrepresented in the report for 2023. After adjusting for the five data centers that reported for 2023 but not for 2024, seven additional colocation facilities reported for 2024 (Table 2).

Table 2 Number of reported data centers by type

The continued lack of reporting by enterprise data centers remains a concern. Microsoft (with two data centers) and Google (with one data center, Greenbox) reported to the enterprise category, indicating that they are used for internal operations such as delivering software as a service and search capabilities. The three data centers represented 82% of the total enterprise space (289,000 square meters) and 73% of the enterprise IT space (172,000 square meters),

The remaining 12 traditional enterprise operations had a total of 64,000 square meters of space, including 22,000 square meters dedicated to IT. There should be more traditional enterprise data centers with 500 kW or more of connected power in the Netherlands than are currently reporting. For example, only three data centers are reported by financial institutions and no manufacturers or logistics facilities are listed.

The major public cloud facilities for providers such as AWS, Google, IBM, Microsoft and Oracle are absent from the Netherlands submissions. These facilities are likely embedded in the colocation data. While the database has a category for co-hosting operations in colocation data centers, it appears that some colocation operators are not using this category.

Space and energy information

A total of 14% of data centers did not report their total space, and 27% did not report total and IT energy use (representing 50% of total reported space). Most of the data was withheld by the large colocation and co-hosting operators: EdgeConnex, Equinix, Interxion, Microsoft and Google (24 of 27 facilities).

The data is likely being withheld, in part, because the Netherlands is publishing the individual data sheets, contrary to the direction in Article 5, paragraph 3 of the Delegated Regulation (2024/1364). This clause instructs the Commission — and by extension the member states — to maintain the confidentiality of the information and key performance indicator (KPI) data.

Approximately 22% of the facilities that reported to the EU database on data centers for the 2023 operating year withheld total and IT energy use data, suggesting that some data center operators are claiming confidentiality for energy use and other data across their portfolio of EU data centers.

PUE and WUE data

The Netherlands PUE data for the 2024 operating year was consistent with the data from 2023 (Table 3 and Figure 1). The average PUE value decreased slightly, but the weighted average and median values increased. A total of 72% of the data centers (47 of 65 facilities) that reported PUE had a value of less than 1.5, the proposed EU minimum performance standard. Another nine of the facilities had a PUE between 1.5 and 1.65, suggesting that they could lower their PUE below 1.5 through system and operational improvements.

Table 3 PUE and WUE data by operating year

Figure 1 Netherlands PUE data by facility by operating year

The number of data centers that reported annual water use and IT energy consumption, enabling the calculation of the water usage effectiveness (WUE), increased from 36 to 51. The larger data set for the 2024 operating year yielded higher WUE values, leading to a significant year-on-year increase in both the average and median WUE values (Table 3 and Figure 2). However, the 2024 Netherlands WUE values were close to the 2023 EU average and median values, suggesting that the 2023 Netherlands data set is not representative of the overall data center portfolio. WUE values for 18 of the 51 reporting facilities would not meet the proposed minimum performance standard (MPS) value of 0.4 liters/kWh of IT energy use.

Figure 2 Netherlands’ WUE data by facility count and operating year

Facility-level water use is relatively low and does not represent a significant environmental concern. Of the 58 data centers that reported water consumption, 44 used 14.2 cubic meters/day (3,750 gallons per day) or less, the equivalent of 25 European households (a typical household uses 0.57 cubic meters/day). Of the remaining 14 data centers, the average water use of 13 is equivalent to the use of 75 to 600 households. The largest data center occupies 146,000 square meters (1.3 million square feet) of total space and used 4,300 cubic meters/day (1.1 million gallons per day), the equivalent of 7,600 households.

The reported data indicate that a WUE MPS standard should have two categories/criteria for the WUE MPS: the climate region in which the data center is located; and the average daily water usage. The Commission and their consults addressed this in their fourth consultation proposals but need to be more concise in their proposals. The relatively low water consumption of the data centers reporting water use in the Netherlands, even where the WUE exceeds 1.0, suggests that water consumption may not be a significant environmental concern at locations with higher WUE values.

Renewable energy factor

The REF could be calculated for 59 of the 104 reporting facilities; 47 of the 59 facilities had a REF of 100%.

ICT capacity and network bandwidth

There is limited reporting on the server and storage ICT capacity, as well as the network bandwidth (Table 4). Where ICT capacity is reported, the unit of measurement and the percentage coverage are typically not provided.

Reporting of these values is hindered by the lack of a standardized methodology to calculate server and storage capacity, as well as network data. Colocation operators reported that tenants are unwilling or unable to provide the information. Two large colocation operators reported that fewer than 5% of their tenants responded to their request for the ICT indicators.

Table 4 ICT capacity and network bandwidth reporting for the 2024 operating year

Observations

The 2025 Netherlands reported EED data (for the 2024 operating year) indicates that the reporting process still suffers from the failure of some operators to report and incomplete data submittals. The Commission and member states, in consultation with IT operators and their country-level data center associations, need to consider how to combine outreach and penalties to achieve full compliance with the EED reporting requirements. They must also address concerns regarding confidentiality and data availability (in the case of ICT and network bandwidth indicators).

Overall, the industry has a good story to tell regarding operational metric such as PUE and WUE. The majority of facilities, even the older ones, are maintaining reasonable average PUE and WUE values. They are also minimizing absolute and average daily water use.

Analysis of the PUE and WUE values reported in 2025 suggests that the proposed 2030 PUE MPS value of 1.5 and WUE MPS values of 0.4 liters/kWh are reasonable and achievable in the Netherlands. However, the likely large number of missing data centers and the fact that IT energy use was reported for only 41% of the total space indicate that the data remains too incomplete and potentially unrepresentative to set MPS values. The data set must be complete and of high quality before the Commission uses it to set MPS values.