LEAP Forward in Clarity for Ireland’s Data Centre Sector and Large Energy Users

In a short period of just over 4 weeks the Irish Government and the Commission for the Regulation of Utilities (CRU) have sought to navigate the delicate balance between facilitating the development of the digital economy in Ireland, achieving energy infrastructure resilience and promoting positive climate change by publishing 2 key policy documents. The Large Energy User Action Plan (LEAP) and the Large Energy Users (LEUs) Connection Policy have come as a much-needed strategic relaxation of the 4 year moratorium on the development of data centres, particularly in the Greater Dublin Region. 

Key takeaways from the LEAP and updated LEU Connection Policies

• Renewable Power: Large Data Centre seeking connection must commit to placing themselves on a glide path to achieve 80% of utilised power from a renewable source within 6 years;  
• Private Wire: The Government is to legislate for private actors to install private electricity infrastructure;
• Green Energy Parks/Plan-led Model: System Operators and the CRU will facilitate plan-led demand locations, pre-determining where LEUs can locate through the establishment of green energy parks with the co-location of energy generation and/or storage onsite with the LEUs and 
• Electricity Infrastructure Investment and Delivery: EirGrid, ESB Networks, the Department of Climate, Energy and the Environment (DCEE), and the Commission for Regulation of Utilities (CRU) are tasked with progressing investment in electricity infrastructure in line with Ireland’s 80% renewable energy target. 

The Large Energy User Action Plan – January 2026

Introduction 

On 13 January 2025 the Government published the Large Energy User Action Plan. LEAP aligns the development of new energy-intensive industries, such as semiconductor manufacturers, data centres and life sciences or ‘large energy users’ (LEU), with new grid infrastructure and renewable energy projects.

The plan contains 17 key objectives with corresponding action items spilt across five themes aimed at addressing current barriers to LEU development. 

17 LEAP Objectives and Actions

Energy Infrastructure Delivery 

1. Investment and delivery: EirGrid, ESB Networks, the Department of Climate, Energy and the Environment (DCEE), and the Commission for Regulation of Utilities (CRU) are tasked with progressing investment in electricity infrastructure in line with Ireland’s 80% renewable energy target. 

2. Energy system plan: The creation of a centralised energy system plan with the capabilities of including new LEUs across electricity and gas System Operators (SOs). 

3. Flexible connections: Permit non-firm contracts and hybrid connections for LEUs to maximise grid utilisation extending to the connection type, scale demand, integration of storage and real-time reporting. 

Providing Regulatory Certainty 

4. Demand strategy: Incentivise demand flexibility from LEUs to encourage greater consumption during periods of abundance using Energy Network Tariffs, market operation and grid code redesign.  

5. Green energy parks: SOs and the CRU will facilitate plan-led demand locations, pre-determining where LEUs can locate through the establishment of green energy parks with the co-location of energy generation and/or storage onsite with the LEUs. 

6. Private wire policy: The Government is to legislate for private actors to install private electricity infrastructure. A new Private Wires policy was approved by Government in July 2025 which has been listed in the Government Legislation Programme Spring 2026. Our full analysis of the Government’s statement on private wires can be read here. 

Enhanced Planning Coordination

7. Model LEU energy needs: Modelled demand scenarios will be utilised to inform a more integrated approach to a plan-led energy system agreed across SOs, the regulator and Government, as described in Action 2.

8. LEAP within national planning: Alignment of strategies through the preparation of a National Planning Statement on Green Energy Park development. 

9. Establish Data Centre Sector Roundtable: An Annual Data Centre Sector Roundtable to be convened annually for greater sectoral and government engagement. 

New Routes to Co-Location 

10. ‘Single point of contact’ for Green Energy Parks: Design of a ‘single point of contact’ approach for potential developer-led green energy parks.

11. Direct supply from Offshore: Support the further development of a CPPA ‘Route to Market’ for offshore wind to supply Green Energy Parks in parallel to the Offshore Renewables Electricity Support Scheme (ORESS). 

12. Efficiency and Emissions Reporting: Establish and mandate LEU efficiency reporting in accordance with EU legislation including potential for  real-time emissions reporting. 

13. Energy market design:- Electricity tariff and system services markets to allow for co-location and incentivise demand-flexibility. 

Preparing for Strategic Opportunities

14. National policy: Facilitate direct engagement with regional “Green Energy Park” proposers. 

15. IDA Strategic site proposals: IDA will progress and assess how proposed development of Next Generation Sites can be achieved while utilising the strategy set forth in LEAP. 

16. Enterprise Support: Department of Enterprise, Tourism and Employment (DETE) will engage Enterprise Ireland and IDA on approaches to support the suppliers and service providers to LEU sectors and determine how the agencies can best assist innovation.

17. Sectors of the Future: Establishment of a LEU ‘Sectors of the Future’ council to inform industrial policy approach. DETE and its agencies will progress analysis on economy-wide return on infrastructure investment across multiple potential decarbonised LEU sectors.

CRU – Large Energy Users Connections Policy – December 2025

The recent publication the CRU’s new Large Energy Users Connections Policy CRU/2025236 (Decision) provided long-awaited clarity to data centre operators in relation to new grid connection and generation requirements. The Decision applies to data centres from the date of publication (12 December 2025) and any data centres seeking to expand their operations and/or increase their Maximum Import Capacity (MIC). Ongoing applications are not impacted. 

The Decision considered three ‘tiers’ of data centres ranked by the power demands of the facility and introduces a de minimis MIC of 1MVA.

First Tier >1 - 10MVA 

Data centres falling within the first tier are those consuming less than 1MVA and are exempt from the provisions of the decision, except for applications for expansion beyond 1MVA. They are not, however, entirely free from restriction. System Operators (“SOs”) are empowered to consider applications from such data centres on a case-by-case basis and connection may be refused if sought in a constrained area of the grid, particularly in the Dublin-Meath areas. The CRU considers additional requirements such as dispatchable generation or meeting renewable energy targets a disproportionate burden on first-tier data centres. 

Second Tier 1 - 10MVA 

Data centres consuming beyond the 1MVA de minimis will now be required to obtain a grid connection, and if granted, maintain an auto-producer meeting 100% of the data centre’s MIC on a de-rated basis. Data centres in compliance with this provision will be exempt from Mandatory Demand Curtailment (MDC). Data centres seeking connection within this tier must also commit to placing themselves on a glide path to achieve 80% of utilised power from a renewable source within 6 years.  The CRU is prudent in warning against ‘project splitting’ or any efforts to fit a larger facility into a lower tier. 

Third Tier <10MVA 

The third and final tier of the CRU’s Decision applies to the largest facilities using upwards of 10MVA. The 80% renewable energy requirement is maintained for this tier, as well as requiring the data centre to provide dispatchable onsite or proximate generation and/or storage capacity. This generation must be separately connected and metered, with de-rated capacity at least equal to the site’s MIC. Participation in the which participates in the Single Electricity Market is mandatory and compliance removes the need for separate MDCs. New data centres with a MIC equal to or above 10 MVA cannot be operational or ramp up their demand without achieving delivery of associated onsite or proximate generation. 

Next Steps 

SOs are expected to publish initial proposals in relation to the Decision on 31 March 2026 which should provide industry insight into the operation and application of the new CRU restrictions. The publication of LEAP and the CRU Decision provide a welcome level of transparency at a policy level for the future of Ireland’s digital industries and overall represents move away from the moratorium approach.

Links

Large Energy User Action Plan

LEAP – Large Energy User Action Plan - DETE

Large Energy Users Connection Policy

CRU2025236_Large_Energy_User_connection_policy_decision_paper.pdf

For further information on the new policies, or general legal advice on energy regulation and projects, please contact Fergal Ruane (Partner, Head of Projects and Infrastructure) or Megan Fennelly (Associate) in the Byrne Wallace Shields LLP Infrastructure, Construction and Energy Department.