Energy Efficiency Act

Energy Efficiency Improvement Act (EnEfG) and EU Energy Efficiency Directive (EED)

The Energy Efficiency Act (EnEfG), which took effect on November 18, 2023, presents data center operators with a number of challenges and obliges them to save energy. In addition, the EU's Energy Efficiency Directive (EED), which took effect on March 14, 2024, must now also be taken into consideration.

What do the laws mean for existing data centers and what needs to be considered when building a new data center?

 

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Illustration Sustainability

Current legal situation and further requirements by the EED

Additional requirements from the European Union's new Energy Efficiency Directive (EED), which was only published after the German Energy Efficiency Act took effect, are leading to legal confusion in the industry. This is how the laws diverge:

 

Energy Efficiency Act (EnEfG) Energy Efficiency Directive (EED)
effective since 18.11.2023 in effective since 14.03.2024
The first mechanisms already apply from 01.01.2024 The first mechanisms already apply from 15.09.2024
Applies for 300 kW connected load Applies to an IT load from 500 kW
Sets requirements for reporting obligations Sets requirements for reporting obligations
Controls the energy efficiency value PUE
Sets minimum limit for waste heat utilization

What applies to your data center? Find out more in our article or get free advice.

 

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Webinar on the Energy Efficiency Act and the Energy Efficiency Directive

Fabian Buda (Head of Business Development) has prepared further content on the Energy Efficiency Act (EnEfG) and Energy Efficiency Directive (EED) in the webinar and answered frequently asked questions from the audience. You can access the webinar for free at any time.

What do data center operators need to be aware of?

Current requirements according to the German Energy Efficiency Act (EnEfG) and the Delegated Regulation (EED) of the EU:

The resolutions of the Energy Efficiency Act affect all data centers with a connected load of 300 kW or more.

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The connected load is the contractually agreed connected load of the grid operator or, if I share a transformer with someone else, the highest arranged distribution, the height of the input switch. If this is over 300 kilowatts, your data center is affected by the Energy Efficiency Act (EnEfG).

Each server room is defined as a data center, even if it is not located in an external building.

The decisive factor here is the extent to which two data centers are involved. If these centers are structurally and technically separate from each other, then they are two data centers that are not subject to reporting requirements, even if they have a cumulative connected load of 300 KW. 

As EU law takes precedence over national laws, the Delegated Regulation (EED) generally takes precedence over the EnEfG. However, if national laws exceed the EED, they must be complied with. The EED is therefore only a basic requirement for all EU countries.

An energy monitoring identifies potentials for energy savings and economic considerations.


By utilizing waste heat, energy efficiency can be significantly improved.

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Have your data center certified with the "Blue Angel for Data Centers" eco-label. 

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Contact us for further measures for new or existing data centers.

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In the section "Energy efficiency of data centers", the draft stipulates that data centers must not exceed a certain value of energy consumption effectiveness or Power Usage Effectiveness (PUE).

This is staggered by year of data center commissioning: 

Operating before July 1, 2026: From July 1, 2027 PUE 1.5 | From July 1, 2030 PUE 1.3

Operation from July 1, 2026: PUE 1.2

An obligation for mutual notification of load assumptions or customers (i.e. energy suppliers) has been decided. How the implementation is to take place, however, is not regulated. The obligation to use waste heat does not apply if the heat network operator does not respond to the request for 6 months or if no buyer can be found. In this case, the data center operator must prove that it can provide the necessary capacities, supply a suitable infrastructure, and that an investment plan and financial framework conditions have been regulated, or that the customer does not accept the offer despite it being in line with the market.

The proportion of reused energy (ERF - Energy Reuse Factor) must be at least 10% for commissioning from 
1.7. 2026 must be at least 10%,
15% from 1.7. 2027 and 
20% from 1.7.2028. 

From 01.01.2026, the establishment of an energy or environmental management system is mandatory

from 1 MW connected load for private data centers and
from 300 kW for the public sector

All important data of the data center must be entered into a data center database in the future. The purpose of this is to monitor, control, improve and document environmental issues relating to data centers. A distinction is made between public information and protected data. Here, the balancing act between data protection due to security-related concerns and a register to simplify the comparison of data centers is to be achieved. The federal government will be required to report annual energy consumption as early as 2024. From mid-2025, there will be mandatory reporting and the establishment of an energy or environmental management system. In March 2026, a mandatory annual transmission of information to the federal government will come into force.

Data center operators are obliged to purchase 50% unsubsidized electricity from renewable energies from 2024 and 100% from 2027. The guarantees of origin (HKN) - i.e. the proof of the region from which the electricity is sourced - do not have to come from Germany or the EU.

This is not currently planned or envisaged.

When does what apply? All measures, year after year

Time requirements according to the German Energy Efficiency Act (EnEfG):

Solar plates on a roof

From January 2024:

Use of 50% green electricity [§11/5 EnEfG].

Data collection of annual consumption (mandatory from a connected load of 300 kW for public data centers and 1000 kW for private data centers).

2 men before a forest

By July 2025:


Energy or environmental management system and reporting requirement to the federal government.

Electricity masts

As of March 2026:
Annual information submission to the federal government.


From July 2026:
Data centers that go live on or after this date must achieve a Power Usage Effectiveness (PUE) ≤ 1.2 and Energy Reuse Factor (ERF) ≥ 10%.

Little plant

From January 2027:
Use of 100% green electricity [§11/5 EnEfG].


From July 2027:
Data centers before June 2026 startup must now achieve a Power Usage Effectiveness (PUE) ≤ 1.5
Data centers going live from this date must achieve an Energy Reuse Factor (ERF) of ≥ 15% [§11/2 EnEfG].

Incandescent lamp lying on an earth

As of July 2028:
From now on, new data centers must achieve an Energy Reuse Factor (ERF) ≥ 20%.

Forest with trees

From July 2030:
Data centers built before July 2026 must achieve a power usage effectiveness (PUE) ≤ 1.3 from now on [§11/1 EnEfG].

EnEfG Cheat Sheet

Would you like to be informed at a quick glance? We offer you all the information in a compact overview as a download. Here you will find a clear overview of all the periods and measures of the Energy Efficiency Act.

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A final report and presentation of the tools developed to support a successful heat transition in the data center sector

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EnEfG plus EED

double challenge for data centers?

Our measures for the green transformation

Photovoltaics & Facade Justification

Energy recovery and natural heat reduction of the IT protective shell

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