EnEfG for data centres: measured PUE or fines

Who must report

Germany defines its threshold differently from the EU: 300 kW of net connected power, not installed IT load. That is a wider net, and it is measured at the grid connection, so a facility can be in scope in Germany while sitting below the EU threshold. Reports go to the RZReg via the federal reporting portal by 31 March each year, six weeks before the EU deadline for the same data.

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.

The caps are on measured PUE

EnEfG is the sharpest national regime in Europe because it attaches numbers to consequences. Existing facilities must reach PUE 1.5 by July 2027 and 1.3 by 2030; facilities entering operation from July 2026 must reach 1.2 within two years. These are caps on measured PUE. An estimate cannot demonstrate compliance with a hard numerical cap, which makes the difference between measured and estimated values a legal distinction, not a quality preference.

Alongside the caps: electricity must be 50 percent renewable from 2024 and 100 percent from January 2027, waste-heat reuse obligations ratchet up for new builds, and facilities above 1 MW need an energy management system. Fines run €50,000 to €100,000 per infraction.

Two filings, one dataset

A German facility files twice from the same data: RZReg by 31 March, the EU platform by 15 May. The formats differ and both evolve, which is why we version every filing template and treat format changes as new versions rather than silent edits. Prepare once in January and both deadlines are administrative events instead of projects.

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.