The Finnish Ministry of Economic Affairs and Employment has published a draft government proposal to establish a national data centre register and to introduce reporting obligations for data centre operators.
Finland proposes a new data centre register – draft legislation open for comments
Marius af Schultén, Antti Kaakkola, Samuli Tarkiainen, Mikko Alakare, Janne Juusela & Jerker Pitkänen
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The new register would improve the shared situational picture of data centre investments and operations, which was one of the objectives identified in Finland’s National Roadmap for Data Centres last year. The roadmap also formed the basis for preparing a dedicated tax support scheme for data centres; however, at its autumn 2026 budget session, the Government of Petteri Orpo stated that it would not proceed with the scheme.
Who would be required to register?
The obligation to register would apply to planned data centres with an expected installed IT power demand of at least 0.5 MW, including technically and functionally integrated buildings and known phased expansions. The obligation would fall primarily on the data centre operator or, if no operator has been appointed, the direct owner of the data centre or the property, building or other asset comprising it.
When would the notification need to be made?
For new projects, the notification would be required after the investment decision but before the start of the construction works. Data centres already under construction or in operation when the legislation enters into force – currently envisaged for the beginning of next year – would need to register by 30 June 2027.
What information would need to be reported?
The notification would require the following information on the data centre, its operations, energy use and infrastructure:
- the data centre’s name and location;
- information on the direct owner, operator and entities exercising control over the data centre;
- the intended use of the data centre;
- planned implementation schedule for the data centre or its expansions;
- estimates of annual electricity consumption and electricity demand for the following five years, as well as future electricity grid and infrastructure needs;
- estimated employment impacts during construction and operation;
- installed IT power demand and maximum electricity connection capacity;
- energy efficiency (PUE);
- the size of the property and the floor areas of the data centre and server rooms; and
- information on backup power, on-site energy production, energy storage, demand response and plans for the utilisation of waste heat.
Duty to provide updates
Material changes concerning ownership, control, operation, suspension or termination of the project, or the scale or nature of the data centre, would generally need to be reported within 30 days.
Supervision and enforcement
The National Emergency Supply Agency (Huoltovarmuuskeskus) would maintain the register and supervise compliance. It could impose a conditional fine for failure to submit a required notification or for submitting a materially deficient one.
Exchange of information between authorities
The Agency could obtain confidential information from certain authorities and would be required to share certain information with relevant governmental, municipal and wellbeing services county authorities in order to support the national situational picture of data centres.
Importantly, registration would not constitute an operating permit and could not, in itself, be used to approve or prevent a data centre project or to impose conditions on an investment.
Next steps
The proposed legislation is intended to enter into force on 1 January 2027. The draft proposal is open for comments until 2 October 2026, giving data centre operators an opportunity to consider the scope and detail of the proposed reporting requirements and to raise any relevant concerns.
With extensive experience in advising data centres, our team would be happy to discuss the proposal and the consultation process.