France reports at 100 kW: the server-room threshold

Who must report

France transposes the EED with the lowest threshold in Europe: 100 kW of installed IT power demand, a fifth of the EU default. That reaches a long tail of server rooms, campus facilities, and small commercial sites, many of which have never employed anyone whose job includes energy reporting.

The content does not shrink with the facility. A 120 kW server room owes the same 24 datapoints as a 20 MW campus, computed the same way, from the same kinds of documents. What changes is who has to do it: at this size there is no sustainability team, so the filing lands on IT managers and facilities staff as an unfamiliar annual obligation.

What gets reported

Delegated Regulation (EU) 2024/1364 defines the content everywhere in the EU: facility identification and redundancy levels (Annex I), and 24 key performance indicators (Annex II) spanning energy, water, waste heat, renewables, ICT capacity, and data traffic. From those, the reporting platform computes four sustainability indicators: PUE, WUE, ERF, and REF.

The inputs are less exotic than the acronyms suggest: twelve months of electricity and water bills, meter or BMS readings where they exist, and a small set of declared facts about the facility. The hard part is provenance. Every figure must stay traceable to the document it came from, because measured and estimated values are not interchangeable once caps and verification enter the picture.

Small facility, same evidence standard

Small facilities are the least likely to have submetering, which makes water figures and IT-load measurement the common gaps. The pragmatic path for a first filing is bills plus a small number of declared facts, with the gaps flagged honestly and a measurement plan for the following cycle. That is a defensible filing; a spreadsheet of unsourced estimates is not.

How NRGKit files it

We compute the 24 datapoints from your bills and exports with deterministic, auditable code, flag what is missing with a gap report, and produce the filing pack against the current template version for your register. Every figure carries its lineage. You review and sign before anything is submitted: you remain the filer of record, and no filing leaves draft status without a human signature.

Founding Filing Partners get the whole 2027 filing season done with them for £1,950 for the year, including the capacity headroom readout computed from the same bills.