Key Contacts: Niall Donnelly – Partner | Alice Whittaker – Partner | Alison Hardiman – Consultant | Eoghan Doyle – Partner | Simon O’Neill – Partner | John O Donoghue – Partner | Angelyn Rowan – Partner | Kerri Crossen – Partner | Max Loughrey – Senior Associate |
EirGrid published the Data Centre Connection Offer Process and Policy Version 3 (“DCCOPP Version 3”) on 20 May 2026, implementing the CRU’s Large Energy Users Connection Policy decision (CRU/2025236) of 12 December 2025. The new policy replaces the existing data centre connection framework, both the operational provisions of DCCOPP V2 (July 2020) and the assessment criteria imposed by CRU Direction CRU/21/124 (November 2021), with a new connection regime. We previously considered the CRU’s Large Energy Users Connection Policy decision here.
For data centre developers and operators, this is the most consequential change to grid access rules in recent years. DCCOPP V3 provides a defined, structured pathway to connection. However, it imposes binding obligations on generation self-sufficiency, renewable electricity procurement, and locational eligibility that will reshape how, where, and when data centre projects are developed.
In this briefing, we consider some of the key aspects of DCCOPP Version 3 and their implications for data centre developments.
The Existing Framework
DCCOPP Version 2, published in July 2020, introduced a two-stage connection offer process and offered flexible demand arrangements for data centres located in network-constrained areas, most acutely Greater Dublin. Version 2 imposed no mandatory generation or renewable electricity requirements on data centre operators as a condition of connection. Voluntary on-site generation could be offered by an applicant to strengthen its case in a constrained area, but this was permissive rather than obligatory. There was no cap on where data centres could connect, and no post-connection compliance regime.
By mid-2021 it was clear that the Version 2 framework was insufficient to manage the pace and scale of data centre demand growth. Data centres were already consuming approximately 14% of Ireland’s total electricity and EirGrid had raised system security concerns. In June 2021 the CRU published a Consultation (CRU/21/060) on potential limiting measures. Having rejected a formal moratorium as contrary to government policy, the CRU issued Direction CRU/21/124 in November 2021, requiring EirGrid and ESB Networks (the “System Operators”) to apply the following assessment criteria before processing any data centre connection application.
| CRU/21/124 Assessment Criteria (November 2021) |
| Location: Whether the data centre is located in a “constrained” or “unconstrained” region of the electricity system. |
| Dispatchable generation / storage: The ability of the data centre to provide on-site or proximate dispatchable generation and/or storage equivalent to or greater than its demand, meeting appropriate availability and technical requirements. |
| Demand flexibility: The ability of the data centre to reduce its consumption when requested by the relevant System Operator — both with and without the use of on-site generation or storage assets. |
Where a System Operator was not satisfied that a connection offer could be made consistent with the needs of the electricity system by reference to these criteria, it was directed not to process the application. No weighting or prioritisation was assigned to the criteria, affording the System Operators considerable discretion on a case-by-case basis. The onerous and discretionary nature of these requirements had the practical effect of a de facto moratorium in the Greater Dublin region. By 2025, data centres accounted for over 22% of Ireland’s total electricity consumption.
DCCOPP V3 supersedes both Version 2 and CRU/21/124 in their entirety and implements CRU/2025/236. For applications received from the date on which CRU/2025/236 was published, the Version 2 process and the CRU/21/124 criteria no longer apply. Applications submitted before 12 December 2025 continue to be assessed under the CRU/21/124 framework.
02. Comparison : V2/CRU/21/124 vs. DCCOPP V3
The table below sets out the principal differences between (i) the existing framework, comprising the operational process under DCCOPP V2 and the assessment criteria imposed by CRU Direction CRU/21/124; and (ii) the new DCCOPP V3 regime.
| Feature | DCCOPP V2 (July 2020) | CRU/21/124 Direction (Nov 2021) | DCCOPP V3 (May 2026) |
| Legal / regulatory basis | EirGrid policy | CRU Direction to System Operators | CRU Decision CRU/2025/236 |
| Purpose | Set out the two-stage application process for data centre connections | Impose assessment criteria to manage system security risk | Replace both frameworks with a unified conditions-based connection policy |
| Generation requirement | Voluntary — on-site generation could strengthen an application in constrained areas; no mandatory requirement | Ability to provide on-site/proximate dispatchable generation ≥ demand, assessed as one of three criteria; no hard obligation | Mandatory new dispatchable generation or storage equal to 100% of MIC (de-rated) required before connection offer can issue |
| Renewable electricity requirement | None | None | 80% of annual demand from new, additional, indigenous Irish renewables within 6 years of energisation |
| Tiered / size-based framework | Single regime — no size-based differentiation | Criteria applied uniformly regardless of size | Three tiers: <1 MVA (de minimis); 1–10 MVA (autoproducer); ≥10 MVA (separately connected generation) |
| Constrained area approach | Connection possible subject to flexible demand arrangements; annual capacity review mechanism | Location in a constrained vs. unconstrained area assessed as one of three criteria; affects likelihood of offer but not automatic bar | Categorical prohibition — application terminated on receipt if site is in a constrained area |
| Demand flexibility obligation | Flexible demand required in constrained areas under V2 arrangements | Explicit criterion: ability to reduce consumption on System Operator request, with and without on-site generation | Demand flexibility not retained as a standalone obligation; case by case assessment on demand flexibility |
| Mandatory Demand Curtailment (MDC) | Data centres in constrained areas subject to MDC | Not specifically addressed — flexibility criterion partially overlaps | MDC disapplied for compliant data centres; reinstatement risk if nominated generation underperforms |
| Application structure | Single data centre application; two-stage process (Stage 1 offer; Stage 2 detailed design) | Application assessed against criteria by System Operators before offer progresses | Three linked applications: (1) data centre; (2) nominated generation (ECP-GSS); (3) nominated renewables (ECP-GSS) |
| Pre-application requirements | No mandatory pre-application meeting | No formal pre-application requirement under the Direction itself | Mandatory pre-application meeting required; validated planning application must be in place before meeting |
| Processing timeline | ~3 months Stage 1; variable thereafter | No fixed timeline; criteria assessed on case-by-case basis with considerable SO discretion | 7.5 months (generation holds ECP-GSS offer); up to 18 months (generation applies in parallel) |
| Capacity market (CRM) | Not addressed | Not addressed | Nominated generation limited to 1-year CRM contracts; offer volume capped at data centre MIC |
| Offer validity | 90 business days | N/A — Direction governed criteria, not offer terms | 2 calendar months |
| Post-connection compliance | No ongoing obligations beyond standard connection agreement | Bi-annual SO reporting to CRU on criteria effectiveness; no operator obligations | Annual operator reporting on renewable compliance from Year 7; MIC reduction or termination for persistent non-compliance |
| Practical outcome | Operational but increasingly inadequate framework as demand grew | De facto moratorium — virtually no new connection offers issued post-November 2021 | Defined conditions-based pathway to connection — legally complex but provides route to market for compliant projects |
03. The New Framework in Detail
Three-Tier Size Classification
| Below 1 MVA De Minimis Standard connection process. No generation or renewable obligations, though a locational assessment still applies. Anti-splitting provisions prevent fragmentation of larger projects. | 1 MVA – <10 MVA Autoproducer Tier New behind-the-meter autoproducer unit meeting 100% of MIC (de-rated) with mandatory SEM participation. Exempt from MDC if compliant. | ≥10 MVA Separately Connected Generation New, separately metered dispatchable generation or storage equal to 100% of MIC (de-rated), mandatory SEM participation. Captures virtually all hyperscale and co-location operations. |
The Three-Application Structure & Timelines
Every DCCOPP V3 application comprises three linked submissions: the data centre application, nominated generation application(s) via ECP-GSS, and nominated renewable generation application(s) also via ECP-GSS. A data centre application can be submitted by the data centre customer at any time. However, any associated Nominated Generation and Nominated Renewables must be in, or already have been processed through, the ECP-GSS connection offer process.
A mandatory pre-application meeting is required before formal submission, and a validated planning application for the data centre must already be in place before that meeting. Where nominated generation already holds an ECP-GSS offer, it may take approximately 7.5 calendar months for offer issuance. Where generation applies simultaneously, the offer could be issued within 18 calendar months (in line with ECP-GSS timelines for generator projects).
Mandatory Nominated Dispatchable Generation or Storage
The application must provide full details of its nominated dispatchable onsite or proximate generation and/or storage in its data centre application. For data centres at or above 10 MVA, nominated generation must be genuinely new and additional. It cannot hold an existing Capacity Market contract and cannot be existing operational capacity. It must have applied for, or hold a connection offer under, ECP-GSS at the time of submission of the data centre grid connection application. It must be located at the same node (onsite) or within the same local meshed network (proximate) and must be operational at or before the data centre energises. No phased ramp-up is permitted. Multiple data centres may share a single proximate generator provided combined de-rated capacity covers their aggregate MIC. Generation and/or storage must meet minimum performance and availability requirements to be specified by EirGrid. Failure to maintain required performance may result in MIC reduction.
The 80% Renewable Electricity Obligation
Data centres at or above 1 MVA must source at least 80% of annual electricity demand from new, additional, indigenous Irish renewable electricity that feeds into the Irish grid. REFIT, RESS, and ORESS-supported projects are explicitly excluded. Compliance is achieved via CPPAs or direct renewable development by the data centre operator. A six-year glide path runs from energisation and from Year 7, annual reporting is mandatory. The applicant must submit a credible plan to satisfy the renewable energy requirement as part of its application, including confirmation of a commercial relationship with the renewable energy developer. Non-compliance may result in MIC reduction or Connection Agreement termination. Renewable output (up to the 80% cap) may be credited on a de-rated basis against the dispatchable generation obligation, reducing separately connected capacity needed. The data centre applicant must provide full details of its nominated renewable generation project(s) at the application stage. The associated renewable energy project(s) must have applied for, or hold a connection offer under, ECP-GSS at the time of submission of the data centre grid connection application. The data centre customer may nominate several different projects for its nominated renewable requirement and can subsequently elect which projects to proceed with.
Constrained Area Hard Stop
Under CRU/21/124, being in a constrained area was one of three assessment criteria that reduced the likelihood of an offer but did not automatically bar an application. Under DCCOPP V3, connection in a constrained area is categorically prohibited and the application is terminated on receipt. EirGrid is publishing an interim Constrained Area Overview Document, which is a detailed heat-map layer to be made available in the 2027 Ten-Year Transmission Forecast Statement. With approximately 97% of Ireland’s data centre capacity concentrated in Greater Dublin, this hard stop will materially reshape the industry’s site selection geography.
Capacity Market Restrictions
Nominated generation must participate in the Capacity Remuneration Mechanism but is limited to one-year CRM contracts only. The maximum offer volume is capped at the data centre’s MIC for the relevant delivery year. Excess generation may participate on normal terms but cannot count toward the generation obligation in future years.
Planning Permission
When applying to EirGrid for a connection, the customer must submit full supporting documentation. This explicitly includes the relevant planning permissions for both the data centre facility and the associated generation and/or storage assets.
| Category | Requirement |
| Data Centre (demand) | Validated planning application, confirmed by the relevant planning authority, must be in place prior to the pre-application meeting. Full planning permission, confirmed by the relevant planning authority, and free of any periods of judicial review is required before Offer acceptance. |
| Nominated Generation | Full planning permission is required before entering ECP‑GSS. In line with ECP-GSS ruleset. |
| Nominated Renewable Generation | Evidence that planning application has been submitted and acknowledged as ‘complete’ is required at ECP‑GSS entry; full planning permission required free of any periods of judicial review before Offer acceptance. In line with ECP-GSS ruleset. |
04. Implications for data centre operators
| 1. Generation Procurement is Now a Prerequisite Under both Version 2 and CRU/21/124, generation was a factor that improved an application’s prospects but was not mandated. Under DCCOPP V3, a commercial relationship with a nominated generator is required before a formal application can be lodged. Advice on co-development structuring and ECP-GSS status diligence must be obtained at a much earlier project stage than previously. |
| 2. Renewable Strategy Must Be Embedded from Day One There was no renewable electricity obligation under either Version 2 or CRU/21/124. DCCOPP V3 introduces an 80% renewable requirement with no precedent in the existing framework. CPPA or direct development arrangements must be scoped, and a credible glidepath demonstrable, at application stage. RESS, REFIT, and ORESS-backed projects are excluded, creating material new demand pressure on new-build Irish renewable capacity. |
| 3. Site Selection is Critical CRU/21/124 treated location as one of three criteria affording discretion to the System Operators. DCCOPP V3 converts a constrained-area location into a hard bar on connection. With Dublin heavily constrained, developers must conduct rigorous locational pre-assessment using EirGrid’s Constrained Area Overview Document before committing capital. Regional sites near planned renewables now carry a structural competitive advantage. |
| 4. Extended Timelines Require Parallel Workstreams The up-to-18-month processing timeline (where generation applies to ECP-GSS in parallel) is significantly longer than the ~3-month Stage 1 target under Version 2. Project programmes must now be built around the generation connection timeline, with all three application workstreams advancing in parallel from the earliest possible stage. |
| 5. Post-Connection Compliance is Continuous DCCOPP V3 introduces annual reporting on renewable compliance from Year 7, mandatory performance standards for nominated generation, and the obligation to replace a withdrawing generator immediately. Non-compliance risks MIC reduction or Agreement termination. This represents a fundamental shift in the risk profile of holding a data centre Connection Agreement. |
| 6. MDC Relief is Conditional The disapplying of Mandatory Demand Curtailment for compliant data centres is a significant commercial benefit. However, the exemption is conditional on nominated generation meeting availability and performance benchmarks. Under-performing nominated generation will expose the data centre to MDC reinstatement or MIC reduction, creating a direct operational dependency on the performance of a potential third-party generation asset. |
| 7. The Demand Flexibility Obligation Has Been Removed — but Read Carefully Under CRU/21/124, demonstrated demand flexibility was an explicit assessment criterion. DCCOPP V3 does not carry this forward as a standalone obligation. However, the MDC exposure for non-compliant data centres effectively preserves a compelled demand reduction mechanism. Operators should not interpret the removal of the formal flexibility criterion as a reduction in their exposure to curtailment risk. |
| 8. MIC Expansion Triggers V3 in Full for the Increment Applications submitted before 12 December 2025 continue under CRU/21/124. Existing connected data centres are not retroactively affected. However, any request to increase MIC triggers V3 requirements for the incremental capacity sought, generation procurement, renewable strategy, and constrained area assessment, regardless of when the original connection was established. This must be modelled from the outset of any expansion business case. |
05. Litigation Risk – Active Judicial Review
EirGrid notes that judicial review proceedings have been initiated against CRU/2025236 by Friends of the Irish Environment, Friends of the Earth Ireland, and ClientEarth. Filed in the High Court in March 2026, these proceedings challenge whether the CRU’s decision adequately reflects Ireland’s obligations under Irish and EU climate and energy law, including whether the 20% non-renewable allowance is consistent with the Climate Action and Low Carbon Development Act 2015. A hearing is scheduled for May 2027. Applicants under DCCOPP V3 should be aware that depending on the outcome of the proceedings, the connection policy may be subject to change.
Capital committed to projects relying on DCCOPP V3 connections carries a litigation contingency that should be reflected in investment decisions, financing structures, and contractual risk allocation. Co-development and offtake agreements should contain regulatory change provisions, extended longstop dates, and force majeure protections addressing the consequences of a successful challenge requiring changes to the connection framework that impact the project.
06. Transitional Provisions
| Applications received before 12 December 2025 Continue to be assessed under the criteria set out in CRU/21/124 and the earlier DCCOPP process regime. Unaffected by DCCOPP V3. |
| Existing connected data centres Not retroactively required to comply with Version 3 obligations. Existing Connection Agreements remain in force on their current terms; the renewable and generation requirements do not apply retrospectively. |
| Requests to increase MIC by existing connected operators Trigger Version 3 requirements for the incremental capacity sought, regardless of when the original connection was established. |
| DCCOPP V3 applies in full To all applications received on or after 12 December 2025. |
07. Action Points for Data Centre Operators
Active or prospective data centre developers should consider the following steps as a matter of priority.
1. Commission a locational feasibility assessment
Use EirGrid’s Constrained Area Overview Document before committing capital to a site. From 2027, the TYTFS heat-map will provide greater granularity. Regional locations near planned renewables carry a structural competitive advantage over Dublin-centric sites under the new regime.
2. Identify and progress a generation partner early
The nominated generation must have, or be entering, an ECP-GSS application. Advice on co-development structuring, commercial terms, risk allocation, and ECP-GSS status diligence, should be obtained before the relationship is formalised.
3. Develop a renewable procurement strategy for application stage
An 80% renewable glidepath must be credibly demonstrable when the application is submitted — a requirement entirely absent from the V2/CRU/21/124 framework. Detailed review of available CPPA counterparties, explicit exclusion of RESS/REFIT/ORESS-backed projects, and early engagement with new-build developers is essential. Counterparty/project scarcity risk is real.
4. Progress planning permission as an immediate priority
A validated planning application for the data centre must be in place before the mandatory pre-application meeting with EirGrid can be scheduled. This is on the critical path to application submission.
5. Monitor the judicial review and embed contingency provisions
Track the High Court proceedings through to the May 2027 hearing. Co-development agreements, project finance documentation, and offtake arrangements should contain regulatory change provisions, force majeure-style protections, and extended longstop dates addressing the risk of a successful challenge.
6. Review existing Connection Agreements for MIC expansion triggers
Any existing connected operator contemplating expansion should review their Connection Agreement now. V3 obligations apply to incremental MIC increases and must be factored into the expansion business case from the outset.
