Remaining EED reporting deficiencies need immediate attention

The second round of the EU’s Energy Efficiency Directive (EED) information and key performance indicator (KPI) reporting must be completed by May 15, 2025. Embarking on the 2024 data submittal seems problematic, given that as of January 31, 2025, most countries have not completed data reporting for 2023. Additionally, three countries still have not designated a member state representative to start the 2023 or 2024 reporting processes, which means that operators in those countries cannot report to the EU database. Furthermore, 21 countries have not enacted the national legislation and regulations required for reporting. Data center operators are concerned that national legislation or regulations, such as those previously made by Germany and the Netherlands, will change or add definitions and reporting requirements.

Data center operators have expressed a high degree of frustration with the 2023 reporting process. They see a need for the European Commission to make process adjustments, including clarification of confidentiality requirements, tightening of critical definitions, and issuance of guidance on the measurement and reporting process for the ICT capacity KPIs. Without these and other changes, which are unlikely to be implemented before the May 15th report deadline, the data reported for the 2024 operating year will be incomplete and, as a result, unusable for making actionable decisions on data center labeling and minimum performance thresholds.