What does the new EU data-centre rating scheme say about renewable energy?
Commission Delegated Regulation C(2026) 3472, adopted on 21 September 2026, turns EU data-centre energy reporting into a mandatory rating scheme with a public label from 15 August 2027. The label discloses each operator’s electricity sourcing and defines a strict tier for Guarantees of Origin matched on time, location and device age, pushing the European GO market towards local, monthly-matched certificates from younger plants.
Why do data centres matter for the GO market?
Data centres and their energy use is driving change on both the physical electricity and Guarantees of Origin markets. They consumed 68 TWh of electricity in 2024 and the number is expected to reach 114 TWh by 2030 when data centres account for 3.2% of total European electricity demand (IEA, 2025/6). The EU has already pushed data centres towards greater energy efficiency with the recast Energy Efficiency Directive (EU) 2023/1791 and Delegated Regulation (EU) 2024/1364, which set up the European data centre database and the reporting scheme in 2024. Now the newly announced Commission Delegated Regulation C(2026) 3472 Act goes a step further and turns that reporting requirement into a mandatory data centre sustainability rating with a public label.
The Commission-adopted text gives data centres a defined, separately disclosed category for stricter electricity sourcing. It defines what counts as high-quality renewable electricity for the fastest-growing electricity-consuming sector in the EU. For the wider renewable energy market, this is another example of policy development pointing towards temporal, location and age differentiation, the largest market shift in the past few years.
If you have read our coverage on electricity matching, the GHG Protocol's geographic matching proposals, and the latest SBTi's Corporate Net Zero Standard V2.0, some of this information will sound familiar, for example temporal granularity, location matching and device age requirements. However this time, it impacts a single sector whilst bringing wider application to the European renewable energy market supply. This article covers what the EU Commission decided, who the new Act applies to, and what you as an renewable energy buyer or producer should do about it, whether you operate a data centre or a wind park.
What does the label say about electricity sourcing?
The Act (Commission Delegated Regulation C(2026) 3472) builds a public label on top of the data centre reporting scheme that has been running since 2024 and delivers three defining features:
- It grades efficiency. Power Usage Effectiveness (PUE) and Water Usage Effectiveness (WUE) are each graded from A to G. Energy procurement plays no part in the grade and no minimum renewable energy share is required.
- Energy sourcing is disclosed in detail - the label shows total energy consumption by source differentiating between unbundled electricity GOs and PPAs, on-site generation, nuclear GOs and PPAs, and unidentified sources.
- A stricter quality tier is defined and shown separately - data centres reporting under the legislation can decide whether to adhere to more stringent categories, or not.
The label sorts each data centre’s energy sourcing into five categories, differentiates between electricity and nuclear sources, and flags which data centres’ sourcing meets the stricter conditions on time, location and device age.
| Category | What counts | Time matching | Location | Device age | GO condition |
|---|---|---|---|---|---|
|
Unbundled GOs
ERES-G00 · ENUC-G00
|
GOs bought and cancelled by the data centre | No requirement | Any bidding zone interconnected to the data centre, including other Member States | No requirement | Only procured unbundled GOs count (no own PPA or on-site). No double counting. |
|
Unbundled GOs, strict
ERES-G00-NC · ENUC-G00-NC
|
As above, meeting all three stricter conditions* | Monthly or finer, at the finest granularity the Member State issues | Same bidding zone or same Member State, whichever is larger | Commissioned or substantially refurbished within the last 10 years | Only procured unbundled GOs count (no own PPA or on-site). No double counting. |
|
PPA
ERES-PPA · ENUC-PPA
|
Electricity consumed under a PPA | No requirement | Any bidding zone interconnected to the data centre, including other Member States | No requirement | The GOs must be owned and cancelled by the data centre, or the energy is subtracted |
|
PPA, strict
ERES-PPA-NC · ENUC-PPA-NC
|
As above, from a young or refurbished plant* | No requirement | Any bidding zone interconnected to the data centre, including other Member States | Commissioned or substantially refurbished within the last 10 years | The GOs must be owned and cancelled by the data centre, or the energy is subtracted |
|
On-site
ERES-OS · ENUC-OS
|
Electricity from on-site or directly connected generation | No requirement | On site | No requirement | The GOs must be owned and cancelled by the data centre, or the energy is subtracted |
Each category comes in a renewable (ERES-) and a nuclear (ENUC-) version with identical conditions.
* The three following conditions apply to the strict unbundled electricity and nuclear GO categories:
- Time matching: production and consumption periods match at the finest granularity the Member State issues GOs in, monthly at the coarsest.
- Location: the GO comes from the same bidding zone or the same Member State as the data centre, whichever is larger.
- Device age: the plant was commissioned or substantially refurbished within 10 calendar years of the reporting year.
The device age condition applies to the strict PPA nuclear and electricity categories.
There are two key details that differ between the final and draft texts of the Act. Firstly, the strict fixed 15-minute matching requirement across the whole market was loosened to match local Member State’s certificate issuance practice, the most granular being on a monthly basis. which in most Member States. This sends a strong signal for voluntary reporting on the current possibilities on various markets. Secondly, the geographical matching requirement was loosened from the same bidding zone to the same bidding zone or Member State. The device age requirement expanded to include either plants younger than 10 years or those having had substantial refurbishment in 10 years ago.
Who does the label apply to?
Although the Commission Delegated Regulation C(2026) 3472 Act applies energy efficiency labels only for one sector, it impacts other market participants as well.
| Who | How the label applies | What it means for them |
|---|---|---|
|
Data centre operators
At least 500 kW installed IT power
|
Directly Labelled from August 2027. Covers roughly 90% of data-centre electricity consumption in Europe. |
Public comparison of efficiency grades and energy sourcing against competitors. |
|
Renewable energy producers and GO sellers
|
Indirectly Through demand for GOs that meet the strict-tier conditions. |
Local GOs from newer devices could carry a premium, pointing to a two-tier market of general and local GOs and new opportunities for device owners. |
|
Enterprises with CSRD obligations
|
Indirectly As customers of labelled data centres. |
A new data point for value-chain emissions reporting, and a public benchmark auditors can check supplier claims against. |
Smaller facilities can participate voluntarily. Data centres serving defence and civil protection are exempt.
What should renewable energy buyers do?
Although the Act doesn’t directly push data centre operators to buy renewable energy, the label brings public comparison against competitors who already run 24/7 carbon-free energy programmes. To prepare, renewable energy buyers should:
Classify what you already consume. Unidentified is the enemy - simply cancelling GOs against the energy consumption already improves transparency under the label. Keeping certificates from unbundled sources and PPAs separate, differentiating between electricity and nuclear GOs and avoiding double counting will move the data centre higher in the label ranking.
Utilise existing PPAs under stricter requirements. Many existing PPAs already qualify for ERES-PPA-NC, since the only extra condition is the plant’s age. Therefore operators with a PPA contract in place, reporting is mostly a vintage-selection and paperwork exercise. Note that any GOs from a PPA plant that you do not own and cancel will be subtracted from your PPA figure.
Consider nuclear where it exists. In markets with young or refurbished nuclear plants, such as France, Sweden, Finland, nuclear GOs can fill the stricter category requirements at a fraction of the cost. Operators on these markets can arbitrage between renewable and nuclear supply on price.
Build the evidence pack now. EU laws are implemented with strict reporting controls and the label records whether your figures are self- or third-party certified. Cancellation statements and commissioning or refurbishment evidence for every MWh consumed and asset used should be audit-ready from the first label.
What does the label mean for renewable energy producers?
For renewable energy producers, the separate disclosure could support demand and price differentiation for eligible certificates. The outcome will depend on customer requirements, eligible supply and competing renewable and nuclear options.
The 10-year requirement creates a subset of eligible assets. A wind farm commissioned in 2019 qualifies for the strict tier until around 2029 and then is withdrawn. A 1960s hydro plant that undergoes substantial refurbishment re-enters for another 10 years. How this is tracked across portfolios is still unclear.
Monthly production profile matters. Data centres need GOs throughout the year, even during months where renewable energy production is lower. Therefore producers whose portfolio is seasonally complementary hold a stronger position on the market.
Local supply is non-transportable. Every country has its bidding zone, a pool where the GOs originate from. Larger countries have even multiple. The size of the pools varies, in Spain it is deeper due to its younger solar fleet and in the Nordics shallower, due to old hydro plants without refurbishment documentation. Local supply pools mean the spread between local and general AIB-connected GO prices coould decouple.
Plant refurbishment becomes a certificate decision. Repowering decisions will have another economic component - the GO value. Proper documentation on refurbishment makes the asset eligible for higher value GOs. Device owners should keep refurbishment date records as currently no national GO registry holds refurbishment date records. Data centre offtakers can request commissioning-date documentation to check the eligibility of the renewable energy device.
Nuclear GOs are back in the game. In France, Sweden and Finland, young or safety-review-extended nuclear GOs can match the same strict-tier label requirements as GOs originating from renewable energy devices. This could limit electricity GO premiums in nuclear-rich markets and dilute the price for renewable energy producers.
Let Soldera help
The EU has now defined what a premium Guarantee of Origin looks like: produced in the data centre’s own bidding zone or Member State, originating from a device commissioned or refurbished within 10 years and matched to consumption on a monthly basis, or more frequently where applicable.
Meeting that definition is an operational task, exactly what Soldera is built for. Cancelling GOs in the correct local registry, keeping unbundled electricity GOs, nuclear GOs, PPA volumes and on-site generation cleanly separated, and holding the commissioning, refurbishment and cancellation evidence in one audit-ready place.
The timing matters as the first labels, published in August 2027, will reflect 2026 consumption. So the procurement decisions that shape them are being made now. The difference between a credible strict-tier figure and an empty line on your label will come down to preparation. Book a demo to stress-test your current portfolio against these changes or talk to our experts through support@soldera.org.
Schedule a 20-minute demo to find out if Soldera is right for you.