In recent years, governments worldwide have started to take digital infrastructure emissions seriously. Laws are being rolled out that require data center owners and operators to report critical sustainability metrics—covering everything from energy and water usage to greenhouse gas (GHG) emissions. This push is affecting businesses everywhere: whether you operate your own facility, rent colocation space, or run workloads in the public cloud. The takeaway? Getting your emissions data in order is no longer optional—it's a new baseline for doing business.

The Reporting Mandate is Here

Global initiatives like the European Union’s Corporate Sustainability Reporting Directive (CSRD), upcoming recasts to the Energy Efficiency Directive (EED), and initiatives like the US SEC’s climate disclosure proposal are rapidly closing the window on voluntary “green” disclosures, making third-party assurance and regular reporting a legal requirement. Even in countries like Brazil, Japan, Singapore, and the UK, similar mandates are in play.

At DCG, we’re seeing that most data centers aren’t fully prepared yet. Consistent and complete tracking of sustainability data—like power usage, renewable energy share, or detailed GHG breakdowns—is still lacking. In Uptime Institute’s latest global survey, only 37% of data center operators said they’re ready to publicly report these figures, and less than one-third of them currently include their Scope 3 emissions.

Understanding Scope 1, 2, and 3 Emissions in Data Centers

It's vital to know who’s responsible for disclosing what. According to the GHG Protocol:

• Scope 1: Direct emissions from sources owned or controlled by your organization (e.g., diesel backup generators).
• Scope 2: Indirect emissions from energy you purchase (mainly electricity).
• Scope 3: All other indirect emissions (like those from third-party colocation providers or cloud operations).

Here’s how it typically breaks down:

This can be confusing—some colocation providers, like Equinix, count all energy as Scope 2 and “pass” emissions to tenants as Scope 3. Others, like NTT, divide responsibility differently. But as climate disclosure rules tighten, everyone in the chain must be able to track their slice of the emissions pie.

What Data Are You Now Expected to Track?

To stay compliant, you’ll need to collect and disclose:

• IT power consumption (metered per client/rack/zone)
• The facility’s PUE (Power Usage Effectiveness)—12-month rolling average
• Breakdown of energy sources (coal, gas, wind, solar, etc.)
• Total megawatt hours (MWh) of renewable energy used
• Emissions factors (market-based vs. location-based)
• Water usage for cooling
• Waste heat recovery and reuse numbers
• Emissions from refrigerants (Scope 1)
• Annual reporting of Renewable Energy Certificates (RECs) or Guarantees of Origin (GOs)

Typically, this information is gathered monthly or quarterly—allowing you to track progress throughout the year and prepare reliable annual sustainability reports. Expect to submit these numbers by March following the end of each year.

Collaboration is Key

If you’re using colocation or public cloud, you’ll need your service providers to supply reliable, granular data on your portion of energy use and attributed GHG emissions. Cloud and colo contracts should make data handover mandatory—otherwise, you risk not having what you need for compliance.

Colocation operators, meanwhile, may require tenants to provide certain IT operational info, since new European rules (like EED recast) are about to require energy and emissions reporting from facilities as small as 100kW of IT load.

What’s Next for Data Center Operators?

As digital infrastructure professionals, it’s time to rethink how sustainability data is collected, shared, and reported. The days of “voluntary” environmental reporting are ending. Here’s what DCG recommends:

• Audit your data sources: Do you have the metering and access you need for accurate, regular data capture?
• Clarify contract terms: Ensure your suppliers agree to provide the specific, granular sustainability data you’ll need under law.
• Establish processes: Month-by-month tracking, cross-team collaboration (between facilities, IT, and procurement), and a clear reporting/preparation calendar will minimize surprises.
• Stay updated: As reporting standards evolve, be ready to adapt your metrics and reporting templates.

Bottom Line

Data center sustainability is about to become as routine as physical security and uptime. Legal mandates will require accurate reporting from every player—operators, tenants, cloud, and colocation providers alike.
Those who move early will be better able to control risk, reduce surprise costs, and demonstrate real accountability.
At DCG, we believe this is an opportunity—not just a compliance burden—for data center pros to lead the way on responsible digital infrastructure.

Note: This summary is inspired by current best practices and industry reporting trends. All examples and regulatory references are based on 2023-2024 developments as observed by the DCG team.