The EU Taxonomy establishes the European Commission sustainability reporting requirements for a number of industry sectors including the data centre sector. To do this, it references the European Code of Conduct on Data Centre Energy Efficiency (EU Code of Conduct), maintained and published by the EU Joint Research Centre (JRC) as well as TR 50600-99-1, which is part of the European EN50600 series of data centre standards and broadly replicates the Best Practices detailed in the EU Code of Conduct, in a standards-based format.
The Corporate Sustainability Reporting Directive (CSRD) will therefore use elements of the EU Code of Conduct for reporting and compliance purposes, with a plan to include 3rd party auditing and verification of reporting accuracy.
In order to achieve this the European Commission requested that a drafting group and steering committee create an auditable framework based on the 2022 version of the EU Code of Conduct. This document was published during early 2023 and can be freely downloaded from the EU JRC website at: https://e3p.jrc.ec.europa.eu/publications/assessment-framework-data-centres-context-activity-81-taxonomy-climate-delegated-act
The 2023 version of the EU Code of Conduct was published in February 2023 and is now freely available at: https://e3p.jrc.ec.europa.eu/publications/2023-best-practice-guidelines-eu-code-conduct-data-centre-energy-efficiency
The current status is that CSRD was approved by the European Parliament on 10/11/2022 and ratified on 28/11/2022. The reporting standards are currently due to be published during June 2023 with reporting to commence in 2024 for the previous 12-month period.
The Assessment Framework based on the EU Code of Conduct in relation to Activity 8.1 in the Taxonomy Climate Delegated Act was published in mid-March 2023 and is freely available at: https://e3p.jrc.ec.europa.eu/publications/assessment-framework-data-centres-context-activity-81-taxonomy-climate-delegated-act
Non-EU companies with substantial activity in the EU, and turnover greater than €150 million, will also have to comply, as well as all EU-based companies.
There is currently no plan by the Commission to audit submissions, but those failing to do so will struggle to access Sustainable Investment from European Investors.
Although the Commission will not be auditing submissions, it has been suggested that all reporting will be required to be audited by qualified 3rd party auditors.
More details can be found at the following links:
CSRD is a more rigorous improvement on the existing Non-Financial Reporting Directive (NFRD), and bases its reporting requirements on the EU Taxonomy and applies to the following organisations:
- Companies already subject to the Non-Financial Reporting Directive (NFRD) and those that fall within the additional requirements of the Corporate Sustainability Reporting Directive (CSRD).
- Financial Market Participants subject to Sustainable Finance Disclosure Regulation (SFDR), including pension providers, offering financial products in the EU marketed as environmentally sustainable.
ISO/IEC 30134 Series of Standardised KPIs
It is becoming increasingly important to understand the published ISO/IEC Standardised data centre metrics as these will underpin the coming reporting requirements required by the European Commission, for compliance with Corporate Sustainability Reporting Directive (CSRD) coming during 2023, and potentially the revised Energy Efficiency Directive (EED).
ISO works alongside International Electrotechnical Commission (IEC), in the development of emerging international data centre standards, and ISO/IEC JCT1 SC39 WG1 is the body responsible for the development of the ISO/IEC 30134 series of standardised data centre resource efficiency KPIs (Including PUE).
It is important to differentiate between standards that support data centre design and those that may be used to improve their operation. The ISO/IEC 30134 series of standards are aimed at improvements in operational performance and sustainability rather than engineering design. Elements of this standards series are also mirrored (reproduced) within the European EN50600 series of data centre standards.
The full list of standards in this series are listed below with publication dates included:
International Standard ISO/IEC 30134 Information technology — Data centres — Key performance indicators
ISO/IEC 30134-1:2018 Part 1: Overview and general requirements
ISO/IEC 30134-2:2018 Part 2: Power usage effectiveness (PUE)
ISO/IEC 30134-3:2018 Part 3: Renewable energy factor (REF)
ISO/IEC 30134-4:2017 Part 4: IT Equipment Energy Efficiency for servers (ITEEsv)
ISO/IEC 30134-5:2017 Part 5: IT Equipment Utilization for servers (ITEUsv)
ISO/IEC 30134-6:2021 Part 6: Energy Reuse Factor (ERF)
ISO/IEC 30134-7 Part 7: Cooling Efficiency Ratio (CER)
ISO/IEC 30134-8:2022 Part 8: Carbon Usage Effectiveness (CUE)
ISO/IEC 30134-9:2022 Part 9: Water Usage Effectiveness (WUE)
Energy Efficiency Directive (EED) – Update
The Energy Efficiency Directive (EED) is currently being updated with stakeholder meetings starting in late 2022 and continuing early in 2023. It has been suggested that the updates will potentially require the creation of National databases listing all data centres greater than 500kW. It will also require reporting against the criteria established in the ISO/IEC 30134 series of standardised KPIs and are likely to include kW/h, WUE and ERF as a minimum.
The updated document should be completed during 2023 for publication in 2024.
Mark Acton, the author of this article, is invited to the EED stakeholder meetings, an editor of the EU Code of Conduct, and participated in the steering committee responsible for the creation of the Assessment Framework for CSRD in the context of Activity 8.1 in the Taxonomy Climate Delegated Act.