The Sustainable Digital Infrastructure Alliance (SDIA) provides comprehensive feedback on the European Union's Delegated Act for a common Union rating scheme for data centers. Emphasizing the need for holistic indicators that span resource inputs to IT equipment and network traffic impacts, SDIA advocates for earlier reporting deadlines to monitor infrastructure growth effectively. The Alliance calls for greater transparency, advocating for the public release of detailed environmental performance data to foster accountability, enable civil society research, and support sustainable digital economy development. Through its suggestions, SDIA aims to strengthen the draft in alignment with EU goals for sustainability and transparency.

We welcome the draft Annexes to the Delegated Act on establishing a common Union rating scheme for data centers. We particularly support the Commission's approach in Annex 2, which includes a holistic set of indicators covering all relevant aspects of digital infrastructure—from input resources (water, energy) to energy output, grid flexibility, and key metrics for IT equipment and network traffic.

We commend this well-researched and comprehensive approach for Europe's critical digital foundation, which will support a thriving, sustainable digital economy.

Below are our comments and suggestions to further strengthen the Drafts in alignment with the goals of the European Union, its Member States, and citizens.

Supporting Comments by the Öko Institut e.V.

We explicitly endorse and support the "Feedback on Commission Draft Delegated Regulation" by the Öko Institut (dated 09.01.2024), which was submitted directly to the European Commission.

Timeline of the reporting

2026 is too late. Both the data center sector1 and governments2 agree that digital infrastructure will experience significant growth in the coming years. The current reporting deadline would miss this critical growth period—a time that requires close monitoring by policymakers and civil society.

Therefore, we ask to revert to the original 2024 deadline for the first reporting. Reporting entities should submit the required information by the end of 2024 to ensure proper monitoring of infrastructure growth driven by the introduction of Generative Artificial Intelligence.

Further, we urge the Commission to consider our proposal for publishing the minimal data points listed below (see "Minimal Public Data Set"). This would allow civil society organizations like the SDIA to create a long-term archive of the data for accountability, transparency, research, and innovation beyond Eurostat's 5-year storage period. Since digital infrastructure typically has a 10- to 20-year useful life, environmental performance data should be maintained for a corresponding duration.

Lastly, we ask the Commission to clearly communicate that reporting will occur annually from the point of publication, ensuring consistent data collection and publication going forward.

Equal Treatment for All Operators

Modifying reporting deadlines for colocation and co-hosting operators would create unfair preferential treatment and delay a comprehensive overview of Europe's digital infrastructure by two years. The recast of the Energy Efficiency Directive (EED) should apply uniformly to all operators, regardless of their market segment.

If colocation and co-hosting data center operators face challenges meeting their obligations, the delegated act should address these issues directly—not create workarounds for incomplete data disclosure (reference: "Where a colocation and co-hosting data center operator cannot gather the information and key performance indicators referred to in paragraphs 1 and 2, it shall indicate the percentage of the data center computer room floor area covered by the information communicated").

Transparency

In the current draft only aggregated and calculated metrics will be made public, which hinders the work of civil society organizations and researchers. Digital infrastructure increasingly affects the lives of citizens through noise, water use, energy use, etc.

Citizens may ask:

• Why is there a data center in my neighborhood but we do not benefit from the heat it produces?

• What is the pollution generated by the diesel generators of the data center?

• How much energy does the data center in my area consume and how does this affect availability of power and energy prices?

We have seen many cases of misleading or no information provided by digital infrastructure providers, as well as efforts to obfuscate ownership of facilities.