Companies renewing colocation or cloud capacity in Germany this fall are signing against a renewable electricity mandate that takes effect January 1 under current law and may be pushed back three years before it ever bites. Contracts signed this quarter will have to work under either outcome.
Germany's Energy Efficiency Act (EnEfG) covers data centers with a non-redundant nominal connected load of 300 kilowatts (kW) or more. Since January 1, 2024, those operators have had to cover half their electricity use with renewable power on a balance-sheet basis, and the share rises to 100% on January 1, 2027. Because the test is a balance and not a physical flow, guarantees of origin count toward it, alongside power purchase agreements for unsubsidized renewables and on-site generation. The law also caps power usage effectiveness (PUE) for existing sites at 1.5 from July 2027 and 1.3 from July 2030, and violations carry fines of up to $56,775 (€50,000) or $113,550 (€100,000).
Germany's federal cabinet approved an amendment on June 24, and the Bundestag held its first reading on September 24 before sending the bill to its Committee on Economy and Energy. The bill text, Drucksache 21/8027, moves the 100% requirement to January 1, 2030 and narrows coverage to sites with at least 500 kW of installed information technology (IT) capacity. Existing facilities would face PUE caps of 1.6 from July 2027 and 1.4 from July 2030. The section requiring operators to tell customers how much energy they use would be repealed, and new data centers would get four years in place of two to reach their efficiency target.
Berlin has reason to move quickly. The amendment carries the European Union's (EU) Energy Efficiency Directive into German law, a transposition that was due by October 11, 2025, and the European Commission has since opened infringement proceedings. Advisers at Grant Thornton expect the bill to clear parliament promptly as a result. Until it does, the current text governs.
Price is where tenants will feel the gap first. If operators must cover every kilowatt-hour with certificates from January, the cost of guarantees of origin can reach customers through pass-through charges, and a contract drafted before the vote may say nothing about who absorbs it. Energy data is the next concern. Since January 1, 2024, operators serving third parties have had to give each customer its attributable annual energy use, and many tenants feed that figure into their Scope 2 inventories. Once the repeal takes effect, the data keeps flowing only where a contract requires it.
A softer PUE path eases pressure on landlords to upgrade cooling at existing sites. Tenants with their own efficiency targets will notice, especially as AI workloads strain corporate efficiency programs. Contract language can close most of these gaps by specifying renewable sourcing by volume and certificate type and tying price adjustments to whichever legal requirement is in force. A separate clause can keep energy data arriving no matter what the statute ends up saying. Companies already reworking capital plans around AI infrastructure may find colocation terms the cheaper place to secure what they need.
If the committee and both chambers have not finished before January 1, the 2027 mandate takes effect, at least for a while. Operators would then have to decide whether to buy certificates for an obligation that may soon be deferred. Committee members could still amend the bill, and one earlier debate may resurface, since the cabinet declined to raise the PUE limit for new builds from 1.2 to 1.3. Tenants with German loads, particularly those already watching grid congestion erode the value of power contracts, will want the committee report in hand before signing. It will show which version of the law they are contracting against and whether certificates bought this winter will count in 2027.
