The Finnish Government’s proposal (HE 282/2026 vp) on 29 October 2026 introduces mandatory notifications for data centres to the National Emergency Supply Agency (NESA, Fin. Huoltovarmuuskeskus). The aim is to contribute to a more comprehensive and anticipatory situational picture of the data centre investments, intended use and ownership of data centres, electricity demand and infrastructure needs in Finland. The proposed entry into force is 1 April 2027.
Key proposed changes
Broad scope and early notification. The register would cover planned, under-construction and operational data centres in Finland with planned or actual installed IT power demand of at least 0.5 MW. This refers to IT equipment threshold, not total grid connection capacity. Notifications would be due within 30 days of signing a grid connection agreement and, in all cases, before construction starts. Data centres within the scope of the act that have already concluded an electricity network agreement, are under construction, or are in operation would be required to submit a notification by 30 June 2027.
Extensive reporting requirements. Notifications would cover, inter alia, information on the entity implementing the data centre project and on the data centre’s control, location, intended use, timetable, capacity, electricity consumption, water consumption, backup power, demand response, waste heat, NIS2 status, countries from which technical maintenance and remote administration are performed, and third-country disclosure obligations. Operators would also need to report development schedules, five-year electricity demand forecasts, infrastructure needs and technical and environmental metrics, including energy efficiency, water use, backup generation and waste heat plans.
Ongoing updates and transitional deadlines. Ownership, control and operator changes would be reportable within 60 days; project or operational starts, suspensions, restarts and endings within 30 days. Significant changes to scale or nature would generally require advance notification, subject to specified IT-power change exemptions.
What this means for developers and operators?
The proposal creates a reporting regime, not a new operating licence: it would not empower NESA to prohibit construction or operations. Nevertheless, providers will face additional administrative work and fees for initial notifications and certain updates. NESA would be empowered to order compliance and reinforce its orders with a conditional fine.
Protection of commercially sensitive information also deserves attention. NESA would publish quarterly aggregate summaries excluding confidential information. However, necessary facility-specific information could be shared with designated public bodies and transmission and distribution system operators for their statutory tasks, notwithstanding confidentiality rules.
Practical steps
- Map your portfolio. Assess the IT-power threshold across operating sites and development pipelines, including phased projects, and identify the responsible operator or owner.
- Build reporting into project and transaction processes. Track connection agreements, construction milestones and ownership changes; assign responsibility for filings and deadlines.
- Prepare a consistent data pack. Document forecast assumptions and reconcile figures with existing annual reporting to the EU database on data centre energy efficiency and sustainability.
- Review sensitive information. Identify trade secrets and their confidentiality grounds, and verify remote administration arrangements and relevant foreign disclosure obligations.
- Monitor implementation. Follow the legislative process in the Parliament, implementing rules, notification procedures and fees.
Dittmar & Indrenius continues to monitor processing of the proposal and its potential implications for data centre businesses. Our team is happy to advise in any questions you may have on the proposal or data centre regulation in Finland.
