Brussels, 29th July 2025. The Climate Neutral Data Centre Pact (CNDCP or Pact), which represents more than 85% of data centre capacity in Europe, has today published a paper cautioning against rushed implementation of minimum performance standards for data centres. Pact members are committed to delivering climate neutral data centre operations by 2030 and have already made significant progress in increasing the environmental sustainability of these critical foundations of the digital economy.
Whilst supportive of the concept of minimum performance standards (MPS) for sustainability in principle, the Pact’s paper, submitted to the Commission’s consultants tasked with defining MPS, argues that the current plans fall short strategically and tactically. If these shortcomings are not addressed, the imposition of MPS could hinder progress in this critical area.
The CNDCP paper, published today, and available on the Pact’s website, raises concerns in several areas:
- Poor quality data and rushed implementation
The proposed MPS draws on data collected from data centre operators under the reframed Energy Efficiency Directive. Yet this data is incomplete, inconsistent and in places simply wrong. Time should be taken to collect, collate and analyse more and better data from across the EU.
- Scope and strategic intent
The design of the MPS currently focuses on the largest data centre operators – although these are the facilities already doing most and achieving the highest sustainability standards.
Drawing on data from the EED means that the smallest, and often the worst performing data centres (under 500KW) are excluded and so cannot be scrutinised. This is a serious strategic failing for a set of MPS designed to improve sustainability across the entire sector.
- Lack of climate normalisation
Climate and water scarcity vary enormously across the European Union. The current proposals take no account of regional variations. This must be addressed to deliver a meaningful indicator of real-world performance. The CNDPC advocates a sliding scale of power usage effectiveness (PUE) and water usage effectiveness (WUE) and has already defined such metrics.
- Misalignment of policy goals
At a time when European and national governments are working to attract next generation AI and cloud-based technologies and achieve strategic autonomy and digital sovereignty, poorly formulated MPS may actively discourage investment. Worse, incomplete understanding of the complex interrelation of numerous sustainability factors could unintentionally exclude some of the most environmentally efficient data centres and reduce customer choice.
The Pact’s paper explores these shortcomings, among others, and suggests important mitigations. It calls upon the Commission to provide better clarification and to engage more deeply with industry so that minimum performance standards are effective in excluding those data centres which fall short in environmental sustainability without damaging Europe’s growth and prospects in the digital economy.
Matt Pullen, chair of the CNDCP Board, commented, “The Pact is in favour of well-designed and effective minimum performance standards as a way of achieving the Commission’s policy objective of excluding the worst performing data centres from the market. However, the current proposals are confused. A lot more work is needed to ensure the proposed MPS deliver their intended outcome without inflicting significant harm on Europe’s digital ambitions.”
Download and read the full paper here.
For further information please contact:
Ben Maynard
Ben.maynard@storyandstrategy.co.uk
+44 (0)7968 537982
