At Leitmotiv, we aim to work towards an alternative digital economy that operates within planetary boundaries, where excessive concentration of corporate power is contained by democratic forces and where human rights, dignity, and equality are respected and promoted. That is our Leitmotiv for the digital future. To make such a future practically attainable, a first-order priority is to have much more transparency about how that digital economy is actually produced right now.

Data center facilities are a crucial part of the upstream supply chain of the digital economy. We can imagine these facilities as the factory buildings of the digital economy, inside of which crucial "digital resources" (compute, storage and transport/networking capacity) are produced. This production happens through machinery, namely ICT equipment, that is powered by electricity and housed in specially cooled and secured facilities.

Without digital resources, there is no Microsoft 365, ChatGPT or online video games. It is clear that we need to produce digital resources to have a digital economy, but that doesn't mean that the production process in its current form is inevitable, efficient or desirable. Currently, the production of digital resources inside hyper-scale facilities of Big Tech corporations, national cloud and hosting providers as well as co-location facilities hides crucial information on the efficiency of the production process, its value creation as well as its environmental externalities.

Why do we need more transparency about the production of digital resources?

We can already observe the negative consequences of an opaque digital resources market: highly concentrated, lack of competition, overproduction and no transparent pricing for customers. More transparency on input/output prices, production process, quality, efficiency, as well as the environmental impact of production, allows for more effective competition.

From a societal perspective, we need transparency because it enables public debate, policy-making and political decision-making that structures and regulates the production of digital resources. Without more openness, we cannot detect anti-competitive behavior, see if key businesses are profitable or if countries will face capacity constraints and, very importantly, we cannot keep a check on the climate and environmental damage of this sector — now and in the future.

With regard to transparency about the environmental impacts of our current digital resource production, the EU has already made important steps. Concerned about a general lack of information on this environmental impact, the EU required the collection and publication of data center sustainability data in the Energy Efficiency Directive (EED) in 2023 and further elaborated this reporting scheme in a delegated regulation adopted by the European Commission in 2024. As the delegated regulation stipulates, "the information and key performance indicators should be used to provide a basis for transparent and evidence-based planning and decision making by Member States and the Commission, and to assess certain key elements of a sustainable data centre, including how efficiently it uses energy, how much of that energy comes from renewable energy sources, the reuse of any waste heat that it produces, the effectiveness of cooling and the use of water".

How effective has this EU regulation been, and what can we learn from its implementation, both inside and outside the EU?

Where are we in 2025 with regard to transparency on the environmental impacts of data centers in Europe?

At Leitmotiv we have already started to assess the current state of environmental transparency around data centers as part of our larger Data Center Environmental Transparency Project. As a first step in this process, we have gathered and analyzed information shared by data center operators in the Netherlands. This information was shared with Dutch authorities based on the EED and its national implementation. The reason we started here is that, quite exceptionally in Europe, the Dutch authorities shared this information with the general public. What we found merits attention by European and non-European policymakers and politicians, even more so because the Netherlands ranks third in Europe in terms of available data center capacity (digital resources) and is a top 20 market worldwide.

Many data center facilities did not report anything at all

A first and striking conclusion from our research is that many data center operators appear not to have reported to the Dutch authorities at all. The Dutch authorities received reports on 104 individual data center buildings and made those public, even though we estimate there are at least 160 data centers in the Netherlands that are required to report under the EED (above 500 kW of installed IT capacity) based on publicly available information and industry sources.

To give an example: In the municipality of Hollands Kroon, above Amsterdam, both Microsoft and Google have well-known hyper-scale data centers. The municipality mentions these on its website as "two of the largest data centers in the Netherlands" and Google lists its facility on its own website as well. Yet, the Dutch authorities have not published any EED reports from these facilities, despite claiming that they publish all reports they receive from Dutch operators under the EED.

A significant share of facilities is withholding information on environmental impact and energy consumption

A second conclusion from our initial research in the Netherlands is that many reporting data centers have withheld essential information on their environmental impact when reporting to the Dutch authorities. According to the EED reports the Dutch authorities have received, data centers consumed "only" 0.9 terawatt hours (TWh) of electricity in 2024, even though Statistics Netherlands (CBS) already estimated data center electricity consumption at 3.7 TWh for 2021.

By our own calculations, data center electricity consumption in 2024 was closer to 4.5 TWh. In short: there is quite a gap between what is being reported to the Dutch authorities and the actual impact of the facilities.

Compliance with EED is especially low for US and UK-owned data center facilities

A third takeaway from our initial research in the Netherlands shows how compliance with EED reporting requirements is especially low among data center facilities that are ultimately owned by US companies. Out of the 27 data center facilities that did not report their electricity use to the Dutch authorities, 24 were ultimately owned by US legal entities.

The existing stock of data center facilities is nowhere near full capacity

A fourth and final conclusion refers to current occupation rates of data centers, which is highly relevant for the debate in the Netherlands and the EU on the apparent need for increased compute and storage capacity. In April, the European Commission opened consultations for a new ‘Cloud and AI Development Act’ (CADA). One of the key objectives of the CADA proposed EU legislation is to “triple the EU’s data centre capacity in the next 5-7 years”. The assumption underlying this legislation and much of the surrounding public debate is that there is scarcity and that this is caused by ‘red tape’ and limited access to energy, water, land and capital.

However, our initial research in the Netherlands reveals that reporting data centers are nowhere near full capacity. Every data center has a maximum electrical capacity (its reservation on the grid) and an actual electrical capacity (electrical capacity allocated to IT equipment, primarily servers). Our research reveals that, on average, the data centers that have reported to the Dutch authorities are only at around ⅓ of their total electrical capacity. Put simply: they are ⅔ empty. We don’t know the actual capacity utilization rate for non-reporting entities, but if we include them in our data using generous estimates – data centers in the Netherlands are at 50% capacity at most. The Netherlands is unlikely to be an outlier in that regard (see this recent article in the Financial Times by Martha Muir on a similar situation in the United States). Such insights are relevant especiallyat a time when so many politicians and policymakers are in such a rush to build more data center facilities.

RVO reported data

RVO data with estimates for non-reporting entities added by Leitmotiv

Conclusions: Analysis of the EED reporting in the Netherlands

As our research on the implementation of the EED in the Netherlands shows, there can be no evidence-based planning and decision-making on the environmental impact of data centers without increased transparency. Such transparency also has broad public support, with 85% of respondents in a recent European survey indicating they want data centers to disclose their environmental impacts.

However, our research at Leitmotiv points to some crucial shortcomings in the structure of the EED, a concerning lack of compliance by non-EU companies (as well as a lack of enforcement by authorities), and low rates of occupation that question the narrative of a lack of capacity.

Even a bigger concern for the overall debate on transparency in our digital economy is how data center transparency plays out in non-EU countries. If we know so little in the EU about data center sustainability, even though the EED is a relatively progressive piece of legislation, the situation may be even worse elsewhere.

Here at Leitmotiv, our objective is to dive deeper into the lack of data center transparency in Europe through more elaborate research on the implementation of the EED — and make it relevant to other parts of the world as well. As our work progresses, we will keep you in the loop!