The EnEfG Reporting Obligation 2027: What Operators Need to Know Now

Who is affected

The Energy Efficiency Act (EnEfG) applies to all data centres in Germany with an installed IT rated capacity of at least 500 kW. This threshold is intentionally low: it captures not only hyperscalers and colocation operators, but also mid-sized companies with their own server rooms that have grown organically over the years.

What matters is the installed rated capacity of the IT infrastructure, not the actual consumption. A data centre with 600 kW of installed capacity that consistently operates at only 400 kW still falls under the reporting obligation. Operators who are unsure whether their facility exceeds the threshold should conduct a full inventory of installed hardware capacity before the first deadline has passed.

The deadline structure at a glance

The EnEfG provides for a phased implementation that confronts operators with several successive deadlines. By July 2025, a certified energy management system (EnMS) compliant with ISO 50001 or an environmental management system compliant with EMAS had to be in place.

15 May 2026 marked the first submission deadline for BAFA reports. By that date, operators were required to register their facility and submit initial consumption data. From 2027, stricter requirements apply: data centres must demonstrate that at least 15% of waste heat is being utilised, or provide a technically and economically justified exemption. At the same time, the obligation to source a proportion of energy from renewables takes effect.

The end target is defined for 2030: a maximum PUE of 1.3 for existing facilities.

What the report must contain

The BAFA report is not an informal self-declaration. It follows a structured schema that requires specific technical and operational data. Each report must include a unique facility ID assigned during initial registration.

In addition, the following must be provided: the annual waste heat volume in MWh, the temperature profile of the waste heat produced (supply and return temperatures), an assessment of the current utilisation rate, an economic analysis of potential utilisation pathways, and documentation of measures already planned or implemented. Operators who have not realised any waste heat utilisation must set out technical or economic reasons. A blanket statement that no suitable off-takers are available is not sufficient.

PUE targets under Section 13(3) EnEfG

Section 13(3) EnEfG sets binding PUE targets that are staggered by year of construction and date of commissioning. New builds entering service from 1 July 2026 must achieve a PUE of no more than 1.2. Existing facilities have a longer transition period, but must demonstrate a PUE of 1.5 by the end of 2027 and a PUE of 1.3 by the end of 2030.

These values are to be understood as annual averages, not snapshots. A data centre that runs at PUE 1.8 in summer and PUE 1.1 in winter may still meet the requirement if its annual average falls below the threshold. The precise calculation methodology is described in the BAFA guidance document.

Waste heat utilisation under Section 17 EnEfG

Section 17 EnEfG supplements the PUE provisions with specific requirements for waste heat utilisation. Operators are required to assess the technical and economic feasibility of supplying waste heat to third parties and to document the outcome. This documentation obligation exists regardless of whether utilisation is ultimately realised.

The feasibility analysis must quantify the available waste heat potential, assess the temperature profile, identify potential off-takers in the surrounding area, and evaluate the economics taking into account both investment and operating costs. Operators who do not realise utilisation despite the analysis indicating an economic potential should expect authorities to require remedial action.

Consequences of non-compliance

The immediate regulatory sanctions for breaches of the EnEfG have not yet been fully defined, as enforcement practice is still evolving. However, the indirect risks are considerable and should not be underestimated.

Permitting risks arise when expansion or new-build projects are applied for: authorities may require fulfilment of existing reporting obligations as a precondition for new permits. This is not an unfamiliar pattern in Germany.

ESG and investor risks are directly relevant for listed or institutionally financed operators. Rating agencies and lenders are increasingly integrating regulatory compliance into their assessment models. An operator that demonstrably ignores reporting deadlines signals governance weaknesses that extend beyond the specific issue.

Practical preparation

Operators that have not yet established reporting processes should begin with a complete inventory: installed IT capacity, current PUE measurement, existing metering infrastructure. Many facilities lack the metering equipment required for an accurate BAFA report.

The timeline is tight. Experience shows that three to six months lie between the decision to pursue compliance and a complete, audit-ready report. Anyone who starts in January 2027 will miss the March deadline. The more conservative approach is to use the infrastructure for the 2026 BAFA report as a pilot and refine the processes for 2027.

Questions about implementation? Ardor helps operators with automated data capture, calculation, and BAFA-compliant preparation of their waste heat data. contact@ardor.institute