How to Report Cloud Services and Data Centres in Your CSRD Disclosure

For small and medium-sized enterprises (SMEs) in professional and IT services, most of your energy use doesn’t come from offices — it comes from the digital infrastructure you rely on every day. Cloud computing, virtual servers, and data storage all consume significant energy through remote data centres.

Under the Corporate Sustainability Reporting Directive (CSRD) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), digital energy use should be disclosed as part of your Scope 2 or Scope 3 greenhouse gas (GHG) emissions, depending on whether you operate or outsource your infrastructure.

This guide explains how to identify, estimate, and report the environmental impact of cloud services and data centres using practical information available to most SMEs. For broader guidance, see what counts as Scope 1 vs Scope 2 and the CSRD guide for office SMEs.

Why Cloud and Data Centre Reporting Matters

Digital services may be “in the cloud,” but their energy demand is very real. Servers, cooling systems, and networks in data centres contribute to both energy consumption and carbon emissions.

The CSRD requires companies to disclose material environmental impacts, including those from digital operations. The VSME Standard (B3) includes:

• Total energy consumption (MWh)
• GHG emissions (Scope 1 and 2, and optional Scope 3)
• GHG intensity per turnover

For service-sector SMEs, cloud usage often represents a material part of Scope 2 or 3 emissions — especially if you operate data-heavy systems like SaaS, AI, or hosting services.

Step-by-Step: Reporting Cloud and Data Centre Use

Step 1 – Identify Your Cloud and IT Providers

List all external services that store or process data on your behalf, such as:

• Cloud platforms (e.g. Microsoft Azure, AWS, Google Cloud, OVH, Hetzner)
• Data hosting and storage providers
• Managed IT service providers
• External CRM, ERP, or file storage systems

Record what they provide (storage, compute, network services) and who manages them.

Step 2 – Determine What’s Under Your Control

Your reporting depends on who operates the servers:

For most SMEs using third-party cloud services, this impact falls under Scope 3 – purchased services. But it’s still relevant to disclose if significant.

Step 3 – Collect Available Energy and Emission Data

Cloud providers increasingly publish sustainability metrics you can use:

• AWS: reports average carbon intensity (gCO₂e per kWh) by region.
• Microsoft Azure: provides emissions dashboards in the Emissions Impact Dashboard (EID).
• Google Cloud: gives regional grid data and renewable energy use.

If your provider offers a customer-specific emissions report, download and include total annual tCO₂e. Otherwise, estimate based on:

• Number of users
• Storage (GB/month)
• Compute time (hours/month)

Example:

10 users × 100 GB cloud storage × 12 months × 2.5 kWh/GB-year = 3,000 kWh (3 MWh)

Using an EU average factor (0.25 kg CO₂e/kWh) → 0.75 tCO₂e

Step 4 – Include Data Centre Electricity in Energy Reporting

If you operate your own server room or equipment in a shared facility:

• Check your electricity invoices for total consumption (kWh).
• Estimate the share used by IT equipment (often 30–40% of office energy).

Include this under VSME B3 – Energy and GHG Emissions as part of your total energy use. If hosted externally, list it as a Scope 3 disclosure (optional but recommended for IT-heavy SMEs).

Step 5 – Report Under VSME B3 (Energy and GHG)

Create a disclosure table that captures your IT-related energy use and emissions:

Narrative:

“Cloud and hosting services account for ~8% of total energy-related emissions. We are migrating workloads to providers powered by 100% renewable energy by 2025.”

Step 6 – Explain Practices and Supplier Policies (VSME B2)

Under VSME B2 – Practices, Policies and Future Initiatives, briefly describe how you manage digital sustainability:

“We assess cloud providers based on their energy efficiency and renewable sourcing. Preference is given to ISO 14001-certified and carbon-neutral data centre operators. Internal data storage is being consolidated to reduce duplication and energy use.”

This shows awareness of Scope 3 environmental impacts — increasingly valued by clients in procurement and ESG scoring.

Aligning Cloud and Data Reporting with CSRD and ESRS

This approach keeps your disclosure aligned with large organisations’ CSRD-compatible reporting structures.

Optional: Estimating IT Equipment Lifecycle Emissions

If your firm replaces laptops or servers regularly, you may optionally disclose embodied emissions using manufacturer data (Scope 3 – purchased goods). Example:

10 laptops × 300 kg CO₂e = 3 tCO₂e (one-time impact, amortised over 3 years).

Including this information supports circular economy metrics (VSME B7).

Practical Tips for Office & IT Teams

• Use your cloud dashboard or billing reports — they often include sustainability metrics.
• Ask suppliers for “energy or carbon reports” (many provide them on request).
• Track progress: switch to low-carbon or renewable-powered data centres.
• Include IT hardware reuse or recycling under your waste disclosures.
• Keep your reporting simple and consistent — use the same method each year.

Key Terms

• CSRD: Corporate Sustainability Reporting Directive (EU 2022/2464)
• VSME: Voluntary Sustainability Reporting Standard for SMEs (EFRAG, 2024)
• Scope 2 emissions: Indirect GHG emissions from purchased electricity or heat
• Scope 3 emissions: Indirect emissions from supply chains or outsourced services
• Data centre: Facility used to house servers and networking equipment
• Cloud computing: On-demand digital storage and processing via remote servers
• MWh: Megawatt-hour, unit of energy
• tCO₂e: Tonnes of carbon dioxide equivalent

Cloud services and data centres often fall under Scope 3. Use our interactive selector to identify which Scope 3 categories apply to your IT operations:

This tool will help you determine which indirect emissions categories are relevant to your cloud and data centre usage.