Hong Kong’s New Data Centre Energy Efficiency Rules: What Operators Need to Know
In This Article
Hong Kong is expanding its data centre energy efficiency requirements under the Buildings Energy Efficiency Ordinance (BEEO), bringing qualifying facilities within the existing regulatory framework. From 20 September 2026, two new building types will be brought within the existing Building Energy Code (BEC) and Energy Audit Code (EAC) framework:
- buildings occupied principally as data centres; and
- portions of industrial buildings occupied principally as data centres.
Introduced under the Buildings Energy Efficiency (Amendment) Ordinance 2025, the changes do not create a separate regime for data centres. Instead, qualifying facilities will be subject to Hong Kong’s existing requirements for building services installations and energy audits. For owners and operators, the first step is to determine whether their facility falls within the new definitions.
Which data centres are covered?
Not every server room or IT space qualifies. A standalone building is considered occupied principally as a data centre when more than half of its gross floor area is used for data-centre purposes.
A data-centre portion within an industrial building is assessed differently. EMSD guidance indicates that a server room supporting the normal operations of an industrial or office building would generally not qualify.
The usual 7,000 m² gross floor area exemption for smaller buildings also does not apply to these new data-centre building types.
How do the BEC and EAC apply?
The amendment affects both of Hong Kong’s existing energy-efficiency frameworks.
The BEC sets energy-efficiency requirements for relevant building services installations in applicable new buildings and major retrofits.
The EAC requires prescribed building types to undergo periodic energy audits, including qualifying facilities brought into the framework under the new Hong Kong data centre energy audit requirements. Under the amendment, the scope of the energy audit requirements expands across 11 distinct building categories, while the statutory audit interval is halved from 10 years down to five years.
The BEC and EAC have different triggers, so organisations should assess their BEEO compliance obligations separately.
Which systems are covered?
The BEEO regulates four categories of building services installations:
- air-conditioning;
- electrical;
- lift and escalator; and
- lighting installations.
For data centres, cooling and relevant electrical infrastructure may fall within these categories. Whether individual systems are covered depends on the applicable requirements and the facility’s configuration.
When is the first energy audit due?
The timing of the first audit depends on the type and status of the data centre.
For a standalone building occupied principally as a data centre, the compliance date is determined by its Certificate of Compliance Registration or occupation approval, depending on the circumstances.
For a qualifying data-centre portion within an industrial building, the timing is linked to when it starts operating.
This has a specific meaning. The relevant date is when the central building services installations serving the data-centre portion begin consuming electricity, rather than when the first server rack becomes operational.
Transitional provisions may also allow a qualifying earlier energy audit to count as the first audit. Organisations should therefore review their audit history before assuming a new audit is required.
What must be submitted?
The energy-audit process includes submitting the required audit documentation to the Electrical and Mechanical Services Department (EMSD), together with the applicable data disclosure requirements.
The framework includes Form EE-D, the Data Disclosure Form, which requires specified information from the energy audit to be disclosed. Organisations should check the current form and EMSD guidance when preparing their submission.
What should operators do now?
With the new provisions taking effect on 20 September 2026, organisations should:
- Confirm their facility’s classification and whether it falls within the new data-centre building types.
- Identify relevant building services installations under the four statutory categories.
- Determine whether BEC, EAC or both frameworks apply.
- Review previous energy audits and any applicable transitional provisions.
- Clarify responsibilities between building owners, operators and tenants.
- Check EMSD’s current guidance and submission requirements before the relevant compliance date.
The statutory responsibility for arranging an energy audit rests with the building owner. Where operational responsibility sits with a tenant or data-centre operator, arrangements for access, energy data and audit coordination should be clearly agreed.
Stay ahead of Hong Kong’s data-centre requirements
The new rules bring qualifying data centres into Hong Kong’s existing energy-efficiency regime from 20 September 2026. Whether and when specific obligations apply will depend on the facility’s classification, building services and operational status.
The SimplyEHS Legal Register helps organisations track applicable regulatory requirements and stay informed when obligations change.
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