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CSRD and your data centre estate
CSRD now covers fewer companies, but the ones that remain in scope must still have their figures assured, and their customers still ask. This guide sets out what changed, where your estate shows up in the numbers, and how to check whether the asset data underneath would stand up to an assurer.
Free PDF, about 16 pages. Regulatory position as of November 2026. Written for sustainability, finance, data centre, facilities and IT asset teams.
CSRD and your data centre estate
Martin Docherty, DCIS®
Fewer companies in scope. The same questions for those still in it.
In 2025 and 2026 the EU narrowed the Corporate Sustainability Reporting Directive. From financial year 2027, EU companies are in mandatory scope only if they have more than 1,000 employees and more than EUR 450 million turnover. The reporting standards have been simplified.
What has not changed is the part that depends on your estate. The revised standards still ask for energy use and Scope 1, 2 and 3 emissions, and reports still need limited assurance. EU data centres above 500 kW still report energy and water figures every year, whatever the size of the company that runs them, and a public rating scheme is on its way.
Every one of those figures is built on a list of equipment. If the list does not match the floor, neither does the figure.
What you will get from this guide
What changed, in plain terms. The 2025 and 2026 changes to CSRD, what is law and what is still in progress, the EU data centre reporting rules, and the UK position, all as of November 2026.
Where the estate shows up in the numbers. Energy and Scope 2, embodied carbon in hardware and why a refresh shows up as a spike, idle and comatose equipment, and allocation to tenants and business units.
Why PUE will not carry the report on its own. What it measures, what it does not, and why liquid cooling makes it harder to compare.
Two tests you can run this month. The trace test checks your asset record against the floor in both directions. The one-figure test asks whether you could rebuild a reported number from the evidence you hold.
An estate evidence worksheet and an assurance checklist. A vendor-neutral list of the data an assurer is likely to ask about, and where yours comes from today.
Written for the people who produce, check or sign off the figures
- Sustainability and ESG reporting leads
- Finance controllers and the people who prepare for assurance
- Data centre and facilities managers
- IT asset managers
- Colocation and telecoms providers answering customers' carbon questions
It covers enterprise, colocation and telecoms estates, in the UK and the EU.
“If your largest tenant asked you to show, asset by asset, how the carbon figure for their space was derived, could you?”
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