Page Contents
Key contacts
Related areas
Ireland, and in particular the Dublin region, is one of the largest data centre hubs in Europe with over 80 data centres in operation. Growth in the sector has slowed in the recent years given the challenges associated with matching energy demand with the availability of energy production and grid connections. In this article we look at a number of recent policy developments which set out a roadmap for data centres in Ireland:
1. The Large Energy Users Connection Policy Decision Paper (the CRU Decision Paper) seeks to establish a pathway to allow for continued connection of data centres to Ireland’s electricity grid, while also balancing Ireland’s climate objectives, promoting renewable energy targets, maintaining security of supply and continued economic growth.
2. The Large Energy User Action Plan sets out the Government’s strategy to facilitate future investment in energy intensive sectors, including data centres, by introducing a plan-led approach to the location of such energy intensive development while unlocking Ireland’s renewable energy opportunity.
1 - Large Energy Users Connection Policy Decision Paper
On 12 December 2025, the Commission for Regulation of Utilities (CRU) published the long-awaited CRU Decision Paper.
The CRU Decision Paper comes after the CRU’s proposed decision paper was published in February 2025 and the consultation which followed. See our previous article on the proposed decision paper here.
The key features of the CRU’s Decision Paper are considered below.
Scope
The CRU Decision Paper applies exclusively to all data centres seeking to connect to the electricity network.
De-minimis level
The minimum project level in terms of Maximum Import Capacity (MIC), which is the limit on how much electricity a site is allowed to draw from the national grid at any one time, is set at 1 Megavolt-Amperes (MVA). The majority of the elements of the CRU Decision Paper (including generation and renewable energy obligations) do not apply to data centres that fall below this threshold.
Generation requirements
The CRU Decision Paper sets out a number of requirements for data centres dependent on their MIC and MVA and categorises data centres into three distinct thresholds:
Data centre thresholds |
Generation requirements |
|---|---|
Data centres under the de minimis threshold (MIC <1 MVA) |
Exempt from the majority of the CRU Decision Paper including from the generation requirements and renewable energy obligations. |
Data centres with MIC ≥ 1 MVA and < 10 MVA |
Must provide an auto-producer unit that, on a de-rated basis, can cover 100% of the site’s MIC. Auto-producer unit must participate in the wholesale electricity market. |
Data centres with MIC ≥ 10 MVA |
Must provide dispatchable onsite or proximate generation and/or storage capacity that can cover 100% of the site’s MIC. Generation and energy storage units must be separately connected and metered. Generation and storage assets must participate in the wholesale electricity market. |
Renewable electricity
Data centres above the de-minimis threshold will be required to meet at least 80% of their annual energy demand from renewable electricity generated in Ireland. Data centres have six years from the date of energisation to meet this requirement.
Location
EirGrid and ESB Networks (System Operators) will consider grid connection applications from data centres on a case-by-case basis and connection may be refused if sought in a constrained area of the grid. This also applies to data centres below the de minimis threshold.
Next steps
System Operators were due to publish an engagement and connection process for data centre connection applicants by 31 March 2026. System Operators were also required to provide initial proposals to CRU in relation to reporting on capacity availability and constraints on the network by 31 March 2026. As of today’s date, that information has not yet been published.
An environmental NGO has recently launched a judicial review challenge against the CRU Decision Paper, focusing on the new renewable electricity proposals which would allow operators to utilise onsite fossil fuels for up to 20% of energy demand. The challenge has not yet progressed past the preliminary leave to appeal stage. We will be monitoring this case closely as it progresses through the courts.
2 - Large Energy-User Action Plan
Another recent significant development for the sector was the publication of the Large Energy-User Action Plan (LEAP) in January 2026. LEAP is the Government’s strategy to facilitate future investment in energy intensive sectors, such as life sciences, AI and data centres, by pairing the energy demand of such sectors with Ireland’s renewable energy capacity.
The actions aim to address development barriers impacting large energy users (LEUs), in particular regarding energy infrastructure.
LEAP sets out 17 enabling actions to deliver the plan over the next five years. The actions are split out into five categories:
1. Energy infrastructure delivery
2. Providing regulatory certainty
3. Enhanced planning coordination
4. New routes to co-location
5. Preparing for strategic opportunities
Green Energy Parks and co‑location with renewables
A central pillar of LEAP is the promotion of Green Energy Parks, which will be designated locations for large energy users with close access to renewable electricity generation. LEAP aims to support the connection of Green Energy Parks to offshore wind via corporate power purchase agreements (CPPAs). Government departments and energy system operators are expected to begin direct engagement with proposers of developer-led green energy park projects.
Plan-led development and spatial coordination
LEAP seeks to move Ireland away from the current developer‑led approach towards a plan‑led model that aligns industrial development with national spatial and climate policy. A key commitment is the development of a National Planning Statement for Green Energy Parks by 2026, which will establish clear national policies on planning matters relating to sustainable energy parks and key enabling infrastructure. The National Planning Statement will guide regional and local plans on where the most energy‑intensive developments should be located.
Energy infrastructure and system flexibility
LEAP prioritises coordinated, forward‑planned grid investment, rather than reactive reinforcement driven by individual projects. Large energy users are expected to operate in a way that is system‑supportive, including through flexible or non‑firm connections, on‑site storage and the ability to reduce demand when the grid is constrained.
Private wires
LEAP commits to legislating for Ireland’s new private wires policy this year. The General Scheme of the Private Wires Bill 2025 is currently at the pre-legislative scrutiny stage and follows the Private Wires Policy Statement announced by the Government in July 2025. The General Scheme of the Bill sets out the legislative amendments to the Electricity Regulation Act 1999 to allow for private ownership of electricity wires in limited circumstances where public benefits to allowing such developments are clear. This is a significant reform of the rules on electricity infrastructure which we will closely monitor over the coming months as the legislation evolves through the legislative process.
IDA Next Generation Sites
IDA Next Generation Sites (NGSs) will be developed to accommodate large future investments, with the aim of enabling streamlined development and providing certainty to investors. It is envisaged that NGSs will provide pre-permitted, master-planned land banks with clear pathways to delivery of required utilities and transport. Sites will be chosen by the IDA based on their ability to connect efficiently to energy, transport and water networks, and for proximity to a workforce and supply chains. According to a Department of Enterprise, Tourism and Employment press release on 2 April 2026, Government approval for the development of NGSs has been obtained and it is anticipated that there will be 3 NGSs developed over the next 15 years, with each site ranging between 500 and 1,000 acres in size.
Next steps
Delivery of LEAP will be overseen on a cross-Government basis, ensuring that enterprise policy, energy regulation and spatial planning operate in a coordinated and predictable way. LEAP commits to significant next steps in 2026, including preparing a National Planning Statement on Green Energy Park development, modelling a range of plan-led LEU development scenarios and locations and progressing multi-annual investment in electricity infrastructure.
Conclusion
The CRU Decision Paper and LEAP are both welcome developments for data centre developers and stakeholders and set out a roadmap for future connections and a move to a plan led approach in a bid to balance the demands of Ireland’s climate objectives, renewable energy targets, security of supply and continued economic growth.
For more information, please contact Alan Roberts, Partner, Chris Stynes, Senior Associate, Kristen Read, Senior Associate, Rachel Kemp, Senior Practice Development Lawyer. John Dallas, Partner, Aisling O’Donoghue, Partner, Ross Moore, Partner, Lachlan Muir, Lawyer, or your usual contact in the Environmental & Planning or Energy, Infrastructure & Natural Resources teams.
Date published: 15 April 2026
