Data Centre Energy & Carbon Disclosures: CSRD for IT Infrastructure
Whether you’re an IT service provider, SaaS company, or digital subsidiary, data centre energy use is usually your most material environmental impact. Some organisations report under CSRD directly; others use VSME voluntarily to meet customer, investor, or group reporting needs.
Either way, CSRD places clear expectations on how energy consumption and related emissions from IT infrastructure are measured, explained, and documented. This guide focuses on the practical realities of data centre reporting for software and IT businesses, rather than industrial-style emissions accounting.
Why Data Centre Energy Matters Under CSRD
Under CSRD and ESRS E1, companies must disclose energy consumption and greenhouse gas emissions that are material to their activities. For IT and SaaS businesses, this typically means:
- Electricity used by on-premise servers
- Energy and emissions associated with cloud hosting
- How efficiency is managed over time
These disclosures often form the backbone of ESG requests from enterprise customers, as explained in CSRD supplier requirements: what small businesses should expect in 2025.
On-Premise vs Cloud: Reporting Differences
On-Premise Data Centres
For on-premise infrastructure, reporting is relatively direct.
Typical data points include:
- Total electricity consumption (kWh or MWh)
- Energy source (grid mix, renewable contracts if applicable)
- Scope 2 emissions using national or supplier emission factors
Where metering is limited, estimates based on server load or utility bills are acceptable, provided assumptions are documented.
Cloud-Hosted Infrastructure
Most SaaS companies rely on hyperscale providers such as AWS, Azure, Scaleway, OVHcloud, Hetzner, or IONOS.
In this case:
- Energy consumption is usually estimated
- Emissions are typically treated as Scope 3
- Transparency of methodology is more important than precision
Companies should explain:
- Which providers are used
- Which regions host workloads
- What data sources or dashboards are relied upon
This approach aligns with common practice described in the energy & GHG emissions topic hub.
Understanding and Using PUE (Power Usage Effectiveness)
PUE is a key efficiency metric for data centres and is often referenced in CSRD narratives.
PUE formula: Total data centre energy ÷ IT equipment energy
What to disclose:
- Whether PUE data is available
- Source of the PUE figure (operator-reported, provider average)
- How PUE is used internally (monitoring, vendor selection, targets)
For cloud providers, company-wide or regional average PUE figures are usually sufficient. You are not expected to calculate PUE independently.
Obtaining Energy and Emissions Data from Cloud Providers
Most major providers now publish sustainability data relevant for CSRD reporting.
Common sources include:
- Provider sustainability dashboards
- Annual environmental reports
- Account-level emissions estimation tools
Good practice is to retain:
- Screenshots or exports of dashboards
- Methodology notes from providers
- Dates and scope of the data used
If data is incomplete, this should be stated clearly. CSRD allows estimates where direct measurement is not feasible.
Calculating Carbon Emissions
Scope 2 (On-Premise)
- Multiply electricity consumption by relevant grid emission factors
- Disclose whether figures are location-based or market-based
Scope 3 (Cloud Hosting)
- Use provider-supplied emissions estimates where available
- Otherwise, apply average data centre emission factors
- Document assumptions consistently year-on-year
A broader explanation of indirect emissions is available in Scope 3 emissions for consumer goods suppliers, which uses similar estimation principles despite a different sector focus.
Data Quality and Documentation Expectations
CSRD does not require engineering-level precision for SMEs and service companies.
What is expected:
- Clear boundaries (what’s included and excluded)
- Consistent methods year-to-year
- Transparent explanation of estimates and limitations
Well-documented spreadsheets and provider reports are usually sufficient for both CSRD and VSME-aligned reporting.
Frequently Asked Questions
Do we need exact energy figures from our cloud provider?
No. Reasonable estimates using provider tools or published data are acceptable, especially in early reporting years. Transparency matters more than precision.
Is PUE mandatory to report?
PUE is not mandatory, but it is a recognised efficiency indicator. If available, it strengthens your narrative around data centre efficiency.
Are cloud emissions Scope 2 or Scope 3?
They are usually reported as Scope 3, as the infrastructure is owned and operated by the provider, not your company.
Can this be managed without specialist software?
Yes. Most IT and SaaS companies manage data centre disclosures using provider dashboards and spreadsheets. The key is consistent documentation.
Key Terms
- CSRD – Corporate Sustainability Reporting Directive
- ESRS E1 – Climate change and energy standard
- PUE – Power Usage Effectiveness
- Scope 2 – Emissions from purchased electricity
- Scope 3 – Indirect value-chain emissions
Next Steps
Start by mapping where your workloads run and which providers are used. Collect available energy or emissions data, document assumptions, and decide how PUE or efficiency indicators are explained.
With a clear, proportionate approach, data centre energy reporting becomes a manageable part of CSRD compliance—supporting both regulatory readiness and credible sustainability conversations with clients and investors.