Finland Prepares Mandatory Data Centre Register

A draft government proposal for a new Finnish data centre register is currently under consultation, with comments due by 2 October 2026. The proposal would require data centres above a certain size to notify a national register maintained by the National Emergency Supply Agency, giving authorities a consolidated view of planned and existing data centre capacity, electricity demand and ownership. The Act is intended to enter into force on 1 January 2027, with a six-month transitional window for data centres already under construction or in operation.

The registration obligation traces back to the national roadmap for data centres, commissioned by the Prime Minister and prepared by an appointed rapporteur in late 2025, which proposed registration as one of three immediate measures to help Finland attract high-value-added data centre investment, alongside a proposed electricity tax subsidy and a fossil-free flexibility scheme for the grid. Registration was framed there partly as a marker of a high value-added data centre, and partly as a practical solution to the difficulty authorities otherwise face in identifying who controls a data centre and what it is used for.

The Government subsequently linked registration to eligibility for the tax subsidy, before shelving the subsidy altogether as part of the 2027 budget negotiations. The registration obligation has nonetheless proceeded as a standalone measure. Its stated rationale has shifted accordingly: the current proposal emphasises giving authorities a situational overview of the sector for electricity system and infrastructure planning and security-of-supply purposes, rather than serving as part of an investment incentive package.

The notification requirement would apply to data centres with a planned installed IT power demand of at least 0.5 MW – the same numerical threshold used under the EU's data centre reporting regime, discussed further below.

The threshold is assessed by aggregating technically and operationally connected buildings together with any phased expansions for which an investment decision has already been made. This aggregation rule is one to watch closely for large, multi-phase campus developments: it is designed to prevent the threshold being avoided by splitting a project into smaller buildings or stages, but it also means that a first-phase notification may need to reflect the scale of the wider campus once later phases are committed. The obligation to notify sits primarily with the data centre operator, or the owner if no operator has yet been appointed and must be made after the investment decision is taken but before construction starts.

The information to be notified is fairly extensive, covering ownership and control, intended use, implementation timetable, projected electricity consumption and grid needs, employment impact, capacity and energy efficiency, and plans for backup power and waste heat use. Operators must also notify certain subsequent changes, generally within 30 days, including changes in ownership, control or operator, and any change in installed IT power demand of at least 10% and 100 kW. Both the initial notification and any change notification will carry a fee, with the proposal estimating total costs to a notifier at slightly over EUR 10,000, combining administrative burden and notification fees.

The proposed regime overlaps to a significant degree with the annual reporting obligation already owed to the EU data centre database under Article 12 of the EU Energy Efficiency Directive (EU) 2023/1791 and Commission Delegated Regulation (EU) 2024/1364 on the first phase of the establishment of a common Union rating scheme for data centres. The proposal tries to avoid duplicate reporting by allowing the Agency to obtain data centres' EU filings directly from the Energy Authority. The two regimes are not, however, fully aligned: the EU obligation attaches to installed IT power demand in an operating data centre and is reported annually by reference to the preceding year, whereas the Finnish obligation attaches to planned IT power demand and is triggered at the project stage, before construction begins. Operators will therefore still need a separate process for the earlier-stage Finnish notification and for tracking the 10%/100 kW change threshold going forward.

Importantly, the notification is not a permit: the Agency would have no power to approve, reject or impose conditions on a data centre project, and failure to notify would not entitle any authority to halt construction or operations. The available enforcement tool is limited to a request for corrective action, backed if necessary by a conditional fine. For developers, the practical impact of the proposal in its current form is administrative rather than substantive: an early filing obligation and an ongoing monitoring duty, not a new approval gate.

The proposal remains subject to consultation and may change before it is submitted to Parliament.

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