Greenhouse Datacenters has once again reported under the European Energy Efficiency Directive (EED) and has not marked any data as commercially confidential, even though the regulation offers that option. All figures on energy consumption and efficiency are publicly available at the Netherlands Enterprise Agency (RVO). That is a deliberate choice: whoever offers colocation is selling trust.
For the customers of a colocation data center, the facility's energy consumption is not an abstraction. It carries through into their own energy bills, their own sustainability reporting, and increasingly into the requirements their own customers place on them. A supplier that is selective about what it shares on this point simply shifts that problem onto its customer.
Greenhouse therefore does not treat the reporting as a form to be filled in as sparingly as possible, but as information that belongs in the chain. That same consideration is built into the design. Cooling, airflow, and capacity utilization are not items optimized after the fact to hit a number, but choices made upfront. Efficiency and environmental impact are determined there, not in the reporting about them.
"For us, energy efficiency is not a box-ticking exercise, but a guiding principle," says Alan Lucas, CISO of Greenhouse Datacenters. "It's the same logic as with security: what you don't measure, you can't manage, and if there's something in a report like this you don't dare publish, you probably don't have it under control."
Under the Besluit activiteiten leefomgeving (Dutch Environment and Planning Decree), a data center qualifies as an environmentally hazardous activity. This gives rise to two obligations that both serve an environmental goal, but are separate from one another.
The reporting and publication obligation for data center energy efficiency stems from Article 12 of the EED and applies to data centers with an installed IT capacity of at least 500 kilowatts. Greenhouse submits this data annually to RVO, which forwards the reports to the European Commission.
The energy-saving obligation is national legislation. Greenhouse falls under the energy-saving information obligation, with the Omgevingsdienst Haaglanden (ODH) as the supervisory authority. Where EED reporting aims for insight and comparability at the European level, the energy-saving obligation is about actually taking measures.
The reporting system is young. The European Commission's dashboard now lists 776 data centers with a combined consumption of 16.7 TWh¹, with the Commission itself noting that not all member states are yet fully represented. In colocation, this raises a question of its own: customers manage their own IT infrastructure, meaning responsibility for energy efficiency is divided. The measurement methodology is fixed; the demarcation between provider and customer is not yet.
Greenhouse actively pursues that demarcation in consultation with RVO and the ODH. Server settings in a colocation setup are the customer's responsibility. For this, Greenhouse follows the approach that the industry associations and the joint environmental agencies (omgevingsdiensten) established in 2024: an annual audit of a sample of one hundred randomly selected servers, recorded in a logbook that the regulator can request and spot-check in real time.
This makes the reporting not a yearly project but an embedded process. That is also the precondition for the comparability the directive is aiming for: figures are only meaningful if they are produced the same way again next year.
Data centers are energy-intensive, and reporting on that does not change. What can change is how much of that energy translates into computing power. During its most recent inspection, the ODH determined a Power Usage Effectiveness of 1.15 for the data center at Industriestraat 53 in Naaldwijk.
By comparison, the weighted European average in the Commission's dashboard stands at 1.36¹. The best-performing EU country averages 1.15², the same value the ODH recorded at Greenhouse. The same assessment also shows that smaller data centers generally score higher than the largest ones.
The next phase of the directive will not stop at reporting. The European Commission is working on an energy efficiency package for data centers featuring a European rating system, and is also starting work on minimum performance standards. A draft regulation for that rating system was out for consultation this past spring. Transparency about energy consumption is, for now, still a choice. That is about to change.
¹ European Commission, Policy Reporting Platform, aggregated data center reporting data, accessed [date]. https://link.europa.eu/q7x39t
² European Commission (DG Energy, AIT, Borderstep and EY), "Assessment of the energy performance and sustainability of data centres in EU, First technical report," July 2025. https://data.europa.eu/doi/10.2833/3168794
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