DIGITALEUROPE response to EUDCEAR’s second technical report and recommendations on revising the reporting scheme

DIGITALEUROPE welcomes the EUDCEAR second technical report and provides additional feedback on the key performance indicators (KPIs) as work progresses on establishing a rating scheme for data centres. We also address initial indications on the revision of the first delegated act on the reporting scheme under the Energy Efficiency Directive (EED).

We support the development of an effective rating scheme that builds upon and enhances the existing reporting framework. The scheme must strike a careful balance between transparency and business confidentiality, whilst taking a holistic view of both infrastructure and IT performance metrics.  

DIGITALEUROPE opposes the introduction of minimum performance standards (MPS) at this early stage. The lack of robust baseline data from multiple EED reporting cycles makes any attempt to set meaningful performance standards premature and potentially harmful, risking market distortions and hindering Europe’s digital goals. Furthermore, the complex interdependencies between water usage, energy efficiency and heat reuse, require careful consideration. We support a phased, evidence-based approach aligned with market realities and broader EU policy objectives.  

This paper addresses two key elements: (1) feedback on KPIs for the data centre rating scheme and (2) recommended amendments of the first delegated act on the EED’s reporting scheme.