Energy-reporting obligations — company EKL is not hall EED

Reading order

Name the reporting person before you name the report. Act (2014:266) binds a large enterprise. Act (2025:570) binds the owner or manager of a data centre with an installed IT power demand of at least 500 kW. A Swedish parent that meets the and-test can sit in EKL even if every Swedish hall stays under 500 kW. A hall at or above 500 kW can sit in the EED file even if the operating company is not a large enterprise. Do not collapse the two letterheads.

Then name the clock. EKL’s first statutory date is 5 December 2015, then at least every four years after the previous audit. Energimyndigheten’s follow-up page says the Agency sends a questionnaire every four years to the companies covered by the Act, and that the latest questionnaire went out in 2024. Those are company-evaluation clocks. They are not the 27 April 2026 notification or the 15 May 2026 Union-database clocks for year 2025. The performance-reporting page already owns those hall dates.

Then name what becomes public. An EKL report is saved by the company for seven years and produced on the Agency’s request. Energimyndigheten’s follow-up page describes an e-service and a questionnaire used for evaluation. The EED public database, the delegated regulation says, publishes aggregated Member State and Union averages. A questionnaire answer is not a published Swedish hall PUE.

• Company EKL versus hall EED before a reporting slogan.
• And-test headcount and money, not a campus megawatt.
• Four-year audit clock versus the 2026 hall clocks.
• The performance-reporting page already owns the 500 kW file.

What each duty actually measures

Act (2014:266) section 1 says the Act aims to promote improved energy efficiency in large enterprises. Section 2 defines an energy audit as a systematic procedure to obtain knowledge of existing energy use in a building or group of buildings, an industrial process, a commercial activity, an industrial or commercial installation, or private or public services, and to identify cost-effective measures and report the results. That scope can include a data hall. It does not turn the hall into the reporting person. The reporting person is the large enterprise.

The and-test must stay attached. At least 250 persons and either turnover above 50 million euro or a balance-sheet total above 43 million euro. Recommendation 2003/361/EC is the undertaking definition, not a spare Swedish employee count. Do not rewrite the and as an or. Do not treat a 500 kW IT envelope as a substitute for the and-test.

Section 4 is a substitute, not a waiver of substance. A certified energy- or environmental-management system can replace the section 3 audit only if the system requires an audit equivalent to section 6 and the connected regulations. Section 5 says the section 3 audit must be done by a person who meets the competence and independence rules. Section 6 requires an in-depth review of the company’s energy use and proposals for cost-effective measures. Those are quality sentences. They are not a published Falun PUE.

Supervision stays on the company row. Sections 8 to 10 give the government-designated authority supervision, a duty to produce documents, and the power to issue injunctions that may be combined with a fine. Section 12 lets an injunction be appealed to the administrative court. Energimyndigheten’s follow-up page is the Agency process colour used here: save seven years, use the e-service when asked, and expect a questionnaire every four years. This page does not treat a later political paper about replacing EKL as enacted law. Until a later statute is in force and cited here, Act (2014:266) remains the live company Act.

What named primary sources show

Act (2014:266), issued 30 April 2014, remains the dated company statute. Keep the and-test, the 5 December 2015 first date, the four-year repeat, the certified-system substitute, the seven-year save and the supervision-and-fine sentences attached to that Act. Do not move them onto a hall marketing page.

Energimyndigheten’s follow-up page is the dated Agency process source for the questionnaire every four years and the 2024 dispatch. It is not a hall EED upload. The Agency’s data-centre pages, Act (2025:570), Directive (EU) 2023/1791 and Delegated Regulation (EU) 2024/1364 remain the hall stack already owned by the performance-reporting and reporting-and-regulation pages.

Named Swedish halls stay on their own papers. No cited source here publishes an EKL report for Meta Luleå, Microsoft’s Sweden region, EcoDataCenter Falun or atNorth SWE04. A 500 kW notification is still not that report.

A matrix instead of a single report slogan

Draw one page with person rows and clock columns. Large enterprise, hall owner at 500 kW and certified-system substitute are different rows. First due date, repeat year, Agency questionnaire, Union-database upload and public aggregate are different columns. Empty cells stay empty. A 2024 questionnaire is a company-evaluation footnote, not a hall PUE column.

Do not invent a Swedish reporting league table from the and-test, the 500 kW threshold or the 15 May 2026 clock. Those remain different objects from different years and methods.

Common misreads

The first misread is to treat an EED upload as proof that EKL is done. A hall database row is not a company audit. The second is to treat an EKL report as proof that the 500 kW hall duty is done. A company folder is not a Union-database clock. The third is to rewrite the and-test as an or, or to treat 500 kW as the employee count.

The fourth is to treat a certified ISO badge as a waiver without the equivalent-audit sentence in section 4. The fifth is to treat the 2024 questionnaire as a published hall score. The sixth is to treat a later political paper about replacing EKL as already being the live Act. The seventh is to use a groundbreaking slogan as proof that either report exists.

What to ask next

Ask which legal person meets the and-test, which legal person owns or manages the hall, and which paper — EKL report, certified-system substitute, Agency questionnaire or EED upload — is actually on the file. Ask the last audit year and the next due year. Ask whether anyone has treated a 500 kW envelope as a company audit.

Then open the energy-performance-reporting page and the reporting-and-regulation page. If the operator will not name the person and the clock, record the gap. Do not fill it from a sustainability slide.

1. Is the live paper a company EKL or a hall EED?
2. Has the and-test been rewritten as an or?
3. Has a 2024 questionnaire been treated as a hall PUE?
4. Has a certified badge been treated as a waiver without section 4?
5. Has a data-hall reporting chapter been invented?

What this does and does not prove

This page proves that Sweden already publishes a company energy-audit duty under Act (2014:266) that is not the 500 kW hall duty under Act (2025:570), and that Energimyndigheten already publishes a four-year questionnaire clock whose latest dispatch in the cited page is 2024.

It does not prove that a named Swedish hall has filed either paper. It does not invent a PUE. It does not treat a later replacement proposal as live law.

Empty cells stay empty. Until a later primary source names a Swedish company’s EKL year or a hall’s EED upload with a dated letterhead, the two-duty clock stays a method, not a census.