Key Contacts: Niall Donnelly – Partner |
Ireland’s Large Energy-User Action Plan (“LEAP”) sets out a new, plan led framework for accommodating large energy users, with a particular focus on co locating data centres, semiconductors, life sciences and other energy intensive industry with indigenous renewable generation in green energy parks beyond 2030.
Purpose and Overall Direction
LEAP is framed as a strategic industrial and energy policy intended to align future large energy user investment with Ireland’s decarbonisation, security of supply and competitiveness objectives. It responds to sharp growth in global and domestic demand for digital infrastructure and other high energy sectors, including the fact that data centres accounted for 22 percent of metered electricity demand in Ireland in 2024 and that global data centre electricity use is expected to more than double by 2030. LEAP prepares for a plan-led approach to the location of the large energy user sectors, especially in the period beyond 2030.
LEAP aims to enable Ireland to attract the next generation of energy intensive investment while ensuring that associated demand is met, as far as possible, from renewable sources and that network costs and system risks are managed in a way that is fair for all consumers. It is designed to complement existing frameworks including the National Planning Framework, the Climate Action Plan, “Powering Prosperity – Ireland’s Offshore Wind Industrial Strategy”, the revised National Energy Demand Strategy and the Government’s 2022 Statement on the Role of Data Centres.
Green Energy Parks and Spatial Planning
A central concept is the creation of strategic green energy parks, which are areas where large energy users, renewable generation (onshore and offshore), storage and dispatchable plant are co-located to maximise use of existing and new infrastructure. These parks are envisaged for the period after 2030, at scales of hundreds of megawatts, focused on the most energy intensive sectors including data centres, semiconductors, life sciences and chemicals. Green energy parks may be led by private developers or coordinated by State agencies and are expected to support regional economic development as well as national energy and climate objectives.
LEAP does not prohibit large energy user projects outside designated parks but anticipates that the largest, most energy intensive projects will be most efficiently accommodated in plan-led locations. The plan therefore commits to a National Planning Statement on green energy parks by 2026, intended to embed the LEAP strategy in national spatial planning policy and give clear guidance to regional and local plans on the identification and treatment of such sites. This will consider both developer-led and plan-led strategic energy park developments and provide greater clarity to investors.
A technical working group will be established between the enterprise, energy and housing departments to develop this statement and align it with the revised National Planning Framework and the 2022 data centre policy.
Key Actions on Infrastructure, Markets and Regulation
LEAP sets out seventeen enabling actions grouped under five themes covering energy infrastructure delivery, regulatory certainty, planning coordination, new routes to co-location and preparation for strategic opportunities.
On infrastructure, electricity and gas system operators are expected to deliver unprecedented levels of grid investment during the PR6 period to 2030 in line with “Shaping Our Electricity Future” and the 80 percent renewable electricity target, with a view to housing, decarbonisation and economic growth rather than additional data centre specific capacity. Beyond PR6 the plan envisages assessing pre-emptive, anticipatory investments to support green energy parks in specific locations, including potential new funding models that do not unfairly burden general consumers. A new integrated energy system planning process is to be created by 2027, bringing electricity and gas system operators together around common spatial assumptions and explicit Government policy on green energy parks, and satisfying forthcoming EU requirements on joint scenario planning across electricity, gas, renewable gases, hydrogen and district heating.
The Commission for Regulation of Utilities (“CRU”) and system operators are tasked with designing flexible or “non-firm” connection agreements and hybrid connections for large energy users so that demand can increase when renewable output is high and decrease when the system is constrained (i.e., operate flexibly), thereby lowering carbon intensity and improving utilisation of grid assets. The need to unlock greater LEU demand side flexibility through “connection requirements and market mechanisms such as incentives for workload shifting, onsite storage and operational optimisation” is a recommendation of the IEA Energy Security Report, 2025.
A revised National Energy Demand Strategy, due in 2026, will be the vehicle for reforms to network tariffs, wholesale market design, grid code and flexibility and storage procurement, with the specific intention of unlocking large energy user demand flexibility and supporting new business models in green energy parks. It states that prospective green energy park developments should have access to a “package” of ‘stackable’ revenue-making opportunities and grid connections that appropriately reflect their efficient use of grid infrastructure, including storage and provision of demand flexibility. LEAP also calls for a review of system operator and regulatory powers, and new legislation if needed, so that connections and investments can support plan-led demand locations rather than relying solely on the existing developer led model.
LEAP also discusses developing legislation regarding Ireland’s Private Wires Policy to enable private actors to expedite the delivery of electricity infrastructure. We previously looked at the General Scheme of the Private Wires Bill 2025 published on 16 December 2025 here.
Co-location routes, Offshore Wind and Data Centres
To operationalise co-location, LEAP envisages a number of new mechanisms and forums. These include work by the Department of Enterprise to explore a single point of contact for green energy park permitting, drawing on the Renewable Energy Directive and the Net Zero Industry Act, which could allow consolidation and prioritisation of projects within designated parks. DCEE, the CRU and EirGrid will further develop route to market options for offshore wind into green energy parks through corporate power purchase agreements (“CPPAs”), potentially in combination with support under the Offshore Renewable Electricity Support Scheme or its successors.
On reporting and performance, large energy user efficiency reporting is to be mandated in line with EU legislation, with a review of opportunities for near real time emissions reporting that reflects the actual generation mix at the time and location of consumption. This is tied to obligations and incentives under the Energy Efficiency Directive for data centres, including increased transparency, waste heat utilisation, EU performance ratings and the European code of conduct on data centre energy efficiency.
Data centres are treated as both a key beneficiary and a key constraint within LEAP. The plan reiterates that data centres underpinned approximately €95 billion, or 20 percent, of gross value added in 2023 and supported about 21,000 direct employees, but also stresses that their electricity usage reached 22 percent of metered demand in 2024 and has grown faster than grid and renewable build out. Government policy continues to prefer data centre projects that bring strong economic activity and employment, use renewable energy efficiently, make efficient use of grid infrastructure and co-locate renewable generation or advanced storage, typically via CPPAs or private wires.
Within the Dublin region, LEAP acknowledges that the grid is highly constrained and that short and medium term opportunities for additional large energy users will be very limited, though the plan commits to enhanced engagement between Government, system operators and industry to explore any potential capacity unlocked through demand side flexibility. The revised large energy user connection policy adopted by the CRU in December 2025 (which we looked at here), which requires additional dispatchable generation and rules out fossil fuel dominated islanded data centres, is presented as a key instrument in steering the sector towards low carbon, system supporting models, including possible use of indigenous biogas under the National Biomethane Strategy.
Governance, Timelines and Strategic Opportunities
Implementation of LEAP is to be overseen on a cross Government basis, with regular reporting to a Senior Officials Group and the Cabinet Committee on Economy, Trade and Competitiveness. Oversight structures will include the revised National Energy Demand Strategy implementation group, the technical working group on the National Planning Statement, an annual data centre sector roundtable, a “Sectors of the Future” expert council and a structured engagement process with proposers of developer led green energy parks.
The seventeen actions are grouped into three overlapping workstreams: expediting delivery of infrastructure and unlocking innovation; informing a plan-led approach; and embedding that approach in planning, markets and governance. Early actions include modelling large energy user scenarios by mid-2026 within existing planning exercises such as Tomorrow’s Energy Scenarios and the Network Development Plan, progressing IDA “Next Generation Sites” that can operate as pre serviced strategic locations and developing enterprise supports and possible regulatory sandboxes for innovation in energy management, storage and renewables integration.
For developers and investors, LEAP signals that large energy user projects will increasingly be assessed in terms of their location relative to renewable resources and grid capacity, their ability to operate flexibly and their contribution to wider system objectives. For owners and operators of existing or proposed data centres and other large users, the plan indicates closer scrutiny of efficiency, emissions and flexibility performance, but also outlines new opportunities to partner with offshore wind, storage providers and State agencies in designated green energy parks and strategic sites. Sponsors should therefore factor LEAP into site selection, connection strategies, corporate power purchase and gas purchase structures, and planning and consenting risk assessments, particularly for projects targeting operation in the next decade and beyond.
