The Dutch agency collecting mandatory data-centre reports lists 104 facilities, while the national industry association counts 186 commercial sites large enough to report.
The gap comes from a year-long investigation by Lighthouse Reports and European media partners into energy and water disclosure. It shows that a legal reporting system can exist without giving the public a complete facility list or usable environmental data.
Why it matters
A city planner deciding whether the grid can support housing, industry and a new AI facility needs actual consumption records, not an estimate built from an incomplete registry. Missing sites make regional planning and public comparison less reliable.
EU rules require data centres with at least 500 kilowatts of installed computing capacity to submit energy and water indicators. The Netherlands Enterprise Agency, known as RVO, says owners must report annually and acknowledges that the quality and completeness of the European dataset need improvement.
Lighthouse reporters filed information requests in all 27 EU member states for the indicators collected under the Energy Efficiency Directive. Ten countries said they did not hold their own facility-level figures. Another group argued that commercial confidentiality justified withholding them, and the European Commission declined to release the full data it uses for aggregated statistics.
The Dutch numbers expose the practical result. The Dutch Datacenter Association counted 186 qualifying commercial facilities at the end of 2025, while the RVO disclosure covered 104. NL Times reported that public electricity figures were available for 44 sites and water figures for 47, both less than a quarter of the industry’s qualifying-site count.
The reporting gap is not the same as proof that every absent operator broke the law. The two lists may use different definitions, ownership records or cut-off dates, and RVO told Trouw that it holds additional information it did not provide. The mismatch is still large enough that the agency’s public picture cannot be treated as a census.
That uncertainty is itself a policy problem: officials cannot readily distinguish non-reporting from differences in classification.
The scale matters because Dutch data centres used 5.1 billion kilowatt-hours of electricity in 2024, according to Statistics Netherlands figures cited by NL Times. That was 4.6% of national electricity use. Grid operator TenneT projects a much larger share by 2030 while businesses and housing projects already wait for connections.
The European Commission says transparency is necessary as Europe expands computing capacity. It proposed a common rating scheme in September and is preparing minimum performance standards, with a legislative proposal planned for the second quarter of 2027. Yet a rating can compare only the facilities that appear in the system and report comparable data.
Lighthouse has taken the dispute to the Aarhus Convention Compliance Committee, arguing that environmental-information rights outweigh blanket commercial secrecy. That filing turns the investigation into a test of the EU’s disclosure obligations, not merely a request for voluntary corporate reporting.
The next formal step is the committee’s response and the Commission’s planned 2027 proposal. Both will show whether Europe’s data-centre transparency system gains an enforcement path or remains an incomplete database with a public dashboard.
Verification
| Claim | Label | Primary source | Independent check |
|---|---|---|---|
| RVO records list 104 Dutch facilities while the industry association counts 186 commercial sites above the reporting threshold. | VERIFIED | https://www.lighthousereports.com/investigation/data-centre-silence/ | https://nltimes.nl/2026/09/30/data-centers-refusing-say-much-water-electricity-use |
| EU reporting covers data centres with at least 500 kW of installed computing capacity. | VERIFIED | https://www.rvo.nl/onderwerpen/energiebesparingsplicht/eed-auditplicht/rapportageplicht-datacentra | https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-rules/energy-efficiency-directive/energy-performance-data-centres_en |
| Lighthouse filed information requests in all 27 EU member states; 10 said they did not hold their own facility-level figures. | VERIFIED | https://www.lighthousereports.com/methodology/data-centre-silence/ | none |
| Public Dutch records contained electricity data for 44 sites and water data for 47. | VERIFIED | Lighthouse investigation and RVO disclosure | https://nltimes.nl/2026/09/30/data-centers-refusing-say-much-water-electricity-use |
| Dutch data centres used 5.1 billion kWh, or 4.6% of national electricity, in 2024. | VERIFIED | Statistics Netherlands figures linked by NL Times | https://nltimes.nl/2026/09/30/data-centers-refusing-say-much-water-electricity-use |
| The European Commission is developing a rating scheme and plans a minimum-performance proposal for the second quarter of 2027. | VERIFIED | https://energy.ec.europa.eu/topics/energy-efficiency/energy-efficiency-targets-directive-and-rules/energy-efficiency-directive/energy-performance-data-centres_en | none |
| The list mismatch makes regional planning and comparison less reliable. | ANALYSIS | Reported registry gaps and grid constraints | none |