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EnEfG plus EED - dual challenge for data centers?

News | 10.07.2024

The new German Energy Efficiency Act (EnEfG) poses a number of challenges for data center operators. The European Union's new Energy Efficiency Directive (EED) must also be taken into account. We describe the dilemma operators are facing and the questions many are asking. Find the answers in our webinar(available for free in German here)

The Act to Increase Energy Efficiency in Germany (Energy Efficiency Act - EnEfG), which came into force on November 18, 2023, obliges data centers to save energy. The implementation of the EnEfG has far-reaching implications for the industry, as all public data centers with a connected load of 300 kW or more and private data centers with a connected load of 1,000 kW or more are affected.

New obligations for operators

The new law brings decisive changes for affected data center operators. They must already now or in the next few years:

✓ Comply with a certain energy consumption effectiveness (Power Usage Effectiveness, PUE) depending on when the data center starts operating,
✓ meet requirements for waste heat utilization and avoidance
✓ set up an energy and environmental management system
✓ transmit all important data of the data center to the Federal Office of Economics and Export Control (BAFA) 
✓ from January 1, 2024 to 50% and from January 1, 2027 to 100% electricity from renewable energies.

What applies to whom and when?

The obligations mentioned are linked to deadlines that the data centers affected by the EnEfG must meet:

From January 2024:

✓ Use of 50% green electricity.

✓ Data collection of annual consumption to BAFA.

Until July 2025:

✓ Energy or environmental management system and reporting obligation to BAFA.

From March 2026:

✓ Annual transmission of information to BAFA.

From July 2026:

✓ Data centers starting from this date must achieve a PUE of ≤ 1.2 and a share of reused energy (Energy Reuse Factor, ERF) of ≥ 10%.

From January 2027:

✓ Use 100% green electricity.

From July 2027:

✓ Data centers before commissioning June 2026 must achieve a PUE of ≤ 1.5.

✓ Data centers that go live after this date must achieve an ERF of ≥ 15%.

From July 2028:

✓ New data centers must achieve an ERF of ≥ 20%.

From July 2030:

✓ Data centers built before July 2026 must achieve a PUE of ≤ 1.3.

Act with gaps

The approaches contained in the law are important and sensible in terms of greater sustainability. However, the EnEfG is not fully developed, as various points are still formulated in an unspecific manner. This leads to loopholes that can be exploited and severely weaken the law. For this reason, there are already calls for corresponding clarification.

Further requirements from the EED

Additional requirements from the European Union's new Energy Efficiency Directive (EED), which was published just a few weeks ago, are leading to legal uncertainty in the industry. The EU Commission now wants to use it to further increase energy efficiency in the EU. As data centers have high electricity requirements, the EED also explicitly refers to them. According to the EU, they currently have the fastest growing energy consumption and CO2 footprint of the entire IT sector as a result of cloud computing and the use of internet-based data.

Reconciling national and EU requirements

The problem at the moment is that the new EED has a direct influence on the EnEfG, which has only been in force for a good six months, but differs significantly from German law in some respects. EU member states must either apply EU directives directly or transpose them into national law. The following questions now arise:

What rules apply to Germany?

What problems are caused by conflicting obligations between two hierarchically different regulations?
Different scopes of application in the EnEfG and the EED between the nominal connected loads and IT loads form the first hurdles to understanding for those affected in the data center environment. While the EED is based on the IT load of the data center to comply with the requirements, the EnEfG is based on the nominal connected load of the entire system. This means that even much smaller data centers in Germany are affected by the obligations.

There are further differences in content between the German law and the EU directive, which raise corresponding questions:

Compliance with a PUE and waste heat utilization

The EnEfG sets out clear requirements for data centers regarding PUE and waste heat recovery, but the EED does not. From a hierarchical perspective, the EED carries more weight. Many are now asking themselves whether German or EU law applies to them.

Different reporting obligations

The reporting obligations under the EnEfG and EED also differ to some extent. What obligations do data centers based in Germany have to comply with? How can it be ensured that the data is also transmitted to the European central register?

Problems with the deadlines

The deadlines set by the EnEfG for the first registration and reporting measures have already expired, but the data center operators have not yet been able to submit any data. This raises the following questions: By when does which data center have to submit which data? How does the reporting and registration process work?


There are currently more than 3,000 data centers in Germany. Of these, an undetermined number are still affected by the new law. What measures must now be implemented so that these data centers can continue to operate in compliance with the law? What applies to newly built data centers?

With regard to the EnEfG, the approach of the legislator in Germany continues to cause difficulties due to very high requirements. In addition, there are now some deviating regulations associated with the EED. It is difficult for data center operators to maintain a clear overview. Nevertheless, they must also plan their steps for the coming years. The webinar can provide initial guidance.

EnEfG and EED: What applies to your data center?

The resolutions of the Energy Efficiency Act have far-reaching effects on the industry. They affect all public data centers from 300 kW and private data centers from 1,000 kW connected load. The EU's new Energy Efficiency Directive poses further challenges.

Are you currently operating or planning a data center and need help with the next steps or have questions about EnEfG and EED? The experts at the Data Center Group took up the issue at an early stage and developed solution concepts. Together with you, we will find out whether your existing or planned data center is subject to the new law and the EU directive and which standards and obligations apply to you. We will provide you with free consultation on the necessary measures and support you in their implementation.


Cover picture: Generated by artificial intelligence (Adobe Firefly)

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