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Compliance GuideEED 2024/1364

Data centre reporting: water, energy and the new rules

6 min read · Last updated 11 June 2026

Data centres are moving from lightly regulated to closely watched. EU rules now require annual energy and water reporting for larger facilities, a UK efficiency target applies through the Climate Change Agreement, and water-use scrutiny is rising fast as most new capacity is proposed where water is already scarce.

At a glance
Applies to
Data centre operators, with the strictest reporting duties on larger facilities (broadly above 500 kW of IT load).
EU reporting
The Energy Efficiency Directive delegated regulation (EU 2024/1364) requires annual reporting of energy use, PUE and water use (WUE) for facilities above 500 kW IT, applying to EU sites.
UK efficiency
The data-centre Climate Change Agreement sets a sector energy-improvement target of 14.5 percent against a 2022 baseline by the end of 2030, in return for Climate Change Levy relief.
Energy audits
Large operators also fall under ESOS, the mandatory four-yearly energy audit (Phase 3 deadline was 5 March 2025).
Resilience
UK data centres were designated Critical National Infrastructure in September 2024, the first new CNI sector since 2015, raising resilience expectations.
Water
Under the Climate Neutral Data Centre Pact, new facilities in cool climates using potable water in water-stressed areas target a maximum water use of 0.4 litres per kWh from 1 January 2025.

What reporting now applies?

The EU has set the pace. Its Energy Efficiency Directive delegated regulation (EU 2024/1364) requires larger data centres, above 500 kW of IT load, to report energy consumption, power usage effectiveness (PUE) and water usage effectiveness (WUE) each year. It applies to EU sites and sets a template the rest of the market is watching.

In the UK, larger operators already fall under ESOS, the mandatory energy audit, and the sector's Climate Change Agreement carries an energy-efficiency target of 14.5 percent against a 2022 baseline by the end of 2030 in exchange for Climate Change Levy relief.

Why is water the new pressure point?

Cooling makes data centres water-hungry, and the geography is working against them: a large majority of water-intensive developments are proposed for areas that are already water-stressed. That puts water draw at the centre of planning scrutiny.

The industry's own Climate Neutral Data Centre Pact has responded with a target of no more than 0.4 litres of water per kWh for new facilities in cool climates that use potable water in water-stressed areas, from 1 January 2025, and UK water-use reporting for the sector is being actively developed.

What does CNI status change?

In September 2024, UK data centres were designated Critical National Infrastructure, the first new CNI sector in nearly a decade. The designation raises expectations on resilience, continuity and incident mitigation.

That matters because cooling sits at the intersection of resilience and efficiency: it is both a major energy and water cost and a leading cause of outages, so changes to cooling have to improve efficiency without ever putting uptime at risk.

How do you cut water and energy without risking uptime?

The order matters: protect resilience and compliance first, then add the efficiency gain. On the water side, holding cooling systems safely at higher cycles of concentration reduces the make-up water drawn and the blow-down sent to drain, while keeping Legionella control intact.

You can size the water and chemical cost of a cooling tower, and the reducible share, with our cooling tower water and cost calculator, then confirm what is achievable per site.

Questions answered

Frequently asked

Do data centres have to report water and energy use?

Larger ones increasingly do. The EU Energy Efficiency Directive delegated regulation (EU 2024/1364) requires annual energy, PUE and water (WUE) reporting for facilities above 500 kW IT, and UK water-use reporting for the sector is being developed.

What is the data centre Climate Change Agreement target?

An energy-efficiency improvement of 14.5 percent against a 2022 baseline by the end of 2030, in return for Climate Change Levy relief for participating operators.

What does Critical National Infrastructure status mean for data centres?

UK data centres were designated CNI in September 2024, the first new CNI sector since 2015. It raises expectations on resilience, continuity and incident mitigation, which shapes how cooling and water systems can be changed.

How can a data centre cut cooling water use?

Mainly by holding cooling systems safely at higher cycles of concentration, which reduces make-up water and blow-down while keeping Legionella control intact. Cooling-tower literature shows around a 20 percent make-up saving moving from 3 to 6 cycles.

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