The Spanish government has taken a significant step toward environmental regulation and efficiency in the data center sector, aligning with Directive (EU) 2023/1791 and Delegated Regulation (EU) 2024/1364. The new draft Royal Decree, currently in public consultation until September 15, will require operators to report standardized metrics on energy consumption, water footprint, refrigerant use, electrical resilience, and socioeconomic impact.
Facilities will need to register in the European database ReportENER, managed by the European Commission, to submit information in a common format across the EU. Registration requires company details (legal name, tax ID, address, generic corporate email) and the assignment of a unique identifier for each operator.
Once registered, operators will need to upload data such as:
– Total energy consumption and breakdown by source (specifying the renewable percentage)
– PUE (Power Usage Effectiveness), a key indicator of data center energy efficiency
– WUE (Water Usage Effectiveness), measuring water use per kWh of computational output
– Total water consumption and volume of potable water used
– LAU code for location, available in Eurostat for each municipality
– Refrigerant types and their Global Warming Potential (GWP)
– Contribution to electrical system flexibility and resilience
The European Commission requires these data to be updated and published annually to ensure transparency and comparability among operators and countries.
Some EU member states already have advanced reporting systems:
– The Netherlands: since 2022, requires PUE below 1.2 for new large-scale data centers
– Germany: mandates publication of the exact percentage of residual heat reuse (Heat Reuse Factor, HRF)
– Finland: incorporates WUE reporting into national water management policies, promoting non-potable water use
Although Spain has so far lacked a specific regulatory framework, it has advantages due to its renewable energy mix and favorable climate for free cooling, which could ease the achievement of more ambitious goals.
The National Integrated Energy and Climate Plan (PNIEC) 2023-2030 and the 2024 Artificial Intelligence Strategy include references to sustainability in the ICT sector, with particular emphasis on hyperscale infrastructures deploying in the country. Spain already serves as the gateway for 70% of data traffic into Europe, thanks to its fiber optic network, submarine cables, and access to clean energy.
The European Directive highlights that data centers consumed 2.7% of the EU’s electricity in 2018 and could reach 3.21% by 2030 if no measures are implemented. This has led to the development of a uniform regulatory framework aimed at optimizing energy performance and minimizing environmental impact.
One of the most disruptive proposals in the Royal Decree is the obligation to reuse residual heat generated by servers when technically and economically feasible. In Nordic countries, this practice can be used to heat entire neighborhoods or public pools.
Implementing this in Spain could particularly benefit projects in industrial and residential areas near large data centers, fostering circular economy schemes and reducing carbon footprints.
Requiring indicators such as PUE, WUE, HRF, or renewable energy share will not only enhance operational efficiency but also serve as differentiators in tenders and international agreements. As these metrics are public, transparency might favor operators with better ratios and penalize less efficient ones.

