Ireland’s Large Energy-User Action Plan marks a major policy reset for data centres and other energy-intensive users. With Green Energy Parks, grid investment, private wires and clearer planning pathways, our Construction Infrastructure & Utilities team explores how LEAP aims to unlock renewable-led growth while delivering long-term regulatory and investment certainty for large energy users.
What you need to know
Policy reset for Large Energy Users – LEAP resets policy following the CRU decision, enabling new large energy users subject to renewable energy thresholds.
Plan-led Green Energy Parks – The Plan introduces Green Energy Parks co-locating energy intensive users with renewable electricity generation.
Grid Investment and flexibility – significant grid investment and market reform will incentivise flexible demand and efficient renewable energy utilisation.
Regulatory planning certainty – Legislative reform, private wires and national planning aim to deliver greater regulatory and investment certainty.
Strategic industrial alignment – Coordinated government oversight positions Large Energy Users as central to Ireland’s long-term strategy.
The Irish Government recently published the Large Energy-User Action Plan (LEAP). LEAP is a strategy to facilitate future investment in energy intensive sectors, while unlocking Ireland’s renewable energy opportunity, including data centres. The Plan is available online. It follows the announcement of the Large Energy User connection policy announced in late 2025, which we discussed in our previous article.
Overview of LEAP
LEAP comprises 17 actions to be delivered over the next five years. Its stated objective is to remove barriers to investment from the perspective of large energy users, including industrial and data centre energy users (LEU), while aligning development with Ireland’s climate and energy targets.
Central to the Plan is the introduction of Green Energy Parks. These Green Energy Parks will be designated locations for data centres co-located with close access to renewable electricity generation, such as offshore wind. The aim of these Green Energy Parks is to ensure that the data centres are not an onerous burden on the electricity grid. It is intended that these will be developer-led, initially, but various actions under the LEAP will ultimately facilitate a plan-led approach beyond 2030.
The actions are structured under five pillars:
Energy Infrastructure Delivery
Regulatory Certainty
Enhanced Planning Coordination
New Routes to Co-location
Preparing for Strategic Opportunities
Set out below is a high-level summary table which outlines the actions indicated.
Energy Infrastructure Delivery
Objective
Summary/Commentary
Timeframe
1. Deliver electricity grid investment
Action: Progress multi-annual investment in electricity infrastructure
Electricity System Operators (SOs) will invest heavily in grid infrastructure in the Price Review 6 (PR6) period up to 2030, which is in line with Ireland’s 80% renewable energy target.
The Accelerating Renewable Electricity Taskforce will get quarterly updates on the key PR6 projects.
From 2026
2. Energy system planning
Action:Create an energy system plan with centralised spatial demand and generation projections, including new LEUs, across electricity and gas SOs.
The Department of Climate Energy and the Environment (DCEE) will ensure that electricity/gas SOs develop, plan and operate with a set of shared objectives in mind. The Government will be directly involved in this process and policy will outline the national ambition for Green Energy Parks.
This process is intended to meet the requirements for joint scenario development across electricity, gas, renewable gas, hydrogen and district heating as set out in the revised EU Gas Package measures.
This new process does not replace the existing planning functions and responsibilities of SOs, and builds on existing processes such as the All-island Resource Adequacy Assessment.
2027
3. Demand flexibility
Action: Design flexible or ‘non-firm’ contracts and hybrid connections for LEUs that maximise utilisation of available grid and renewable electricity use.
It is assumed that existing and new infrastructure will be more efficient, cheaper and lower carbon intensity if LEUs, including data centres, can use grid power when renewables are plentiful and reduce grid demand when they are not, and/or when the grid is constrained.
This should include consideration of opportunities for cost effective flexible LEU demand connections, and/or hybrid connections.
The CRU is required to implement measures that incentivise SOs to deliver flexible demand connections for LEUs. This will include consideration of opportunities for flexible LEU demand connections / hybrid connections for grid infrastructure.
EU Directive 2024/1711 requires SOs to offer the possibility of flexible connection agreements in areas of limited network capacity.
2027
Providing Regulatory Certainty
Objective
Summary/Commentary
Timeframe
4. Markets and Tariffs that unlock demand flexibility
Action:Energy Network Tariffs, market operation and grid code redesign to deliver LEU demand flexibility.
Due to the intermittency of renewables and network constraints, market design and tariff structures which incentivise demand flexibility by LEUs is essential. By implementing these incentives, it is expected there will be greater consumption of electricity at times when there is an abundance of renewable energy available and reduced consumption during peak demand periods. This will lower carbon emissions, reduce the cost of electricity and make efficient use of the grid.
The National Energy Demand Strategy sets out a series of further actions required to achieve this, with a revised demand strategy due in 2026.
As per a revised and expedited National Energy Demand Strategy (publication 2026)
5. System Operators empowered to facilitate plan-led approach
Action: Assess powers of System Operators and the CRU to facilitate plan-led demand locations, and associated enhanced anticipatory infrastructure investments and/or prioritised connection types
A strategic approach is to be taken in facilitating the co-location of demand load, generation and storage. This would be a marked change from the current ‘developer led’ system of grid planning.
To provide for a plan-led approach in establishing Green Energy Parks, an assessment of legal powers and responsibilities of SOs is required.
The Government will consider the appropriate funding mechanisms to enable this investment.
2027 – position paper, followed by new legislation if required
6. Legislate Government Private Wires Policy
Action:Legislate for Ireland’s new Private Wire Policy.
By allowing for the installation of private electricity infrastructure that is consistent with national infrastructure, this will enable expedited infrastructure delivery.
This policy will result in innovative energy parks systems in certain locations. The new General Scheme for the Private Wires Bill was approved in 2025. It will be legislated for in 2026. We discuss this General Scheme in a previous article
2026
Enhanced Planning Coordination
Objective
Summary/Commentary
Timeframe
7. Model LEU demand scenarios
Action:Model a range of plan-led LEU development scenarios and locations to inform policy choices
A set of scenarios relating to LEU development will be modelled and considered.
The modelling will provide an opportunity to consider plan-led industrial development opportunities and interdependencies within Transmission System Operator (TSO) and Distribution System Operators (DSO) grid planning. This will inform a more integrated approach across SOs, the regulator and Government, as outlined in point 2 of the Action Plan.
Q2 2026
8. Embed LEAP strategy in national spatial planning policy
Action: Prepare a National Planning Statement on Green Energy Park development.
The preparation of a National Planning statement for Green Energy Parks should provide more clarity on large energy intensive sectors in green energy park developments, but will not be sector prescriptive.
This will give further effect to existing Government policy regarding data centre development. It should hopefully help facilitate larger data centre facilities that have more locational flexibility and provide for an efficient use of grid resources.
A technical working group to progress analysis and drafting of the National Planning Statement will be established.
2026
9. Establish Data Centre Sector Roundtable
Action:Convene Annual Data Centre Sector Roundtable for greater sectoral and government engagement.
The Government and Energy SOs will engage annually with representatives of the data centre sector for feedback on the implementation of LEAP.
2026 & onwards
New Routes to Co-location
Objective
Summary/Commentary
Timeframe
10. ‘Single point of contact’ for Green Energy Parks
Action: Consider development of a ‘Single Point of Contact’ mechanism for plan-led Green Energy Park developments.
Development of a 'Single Point of Contact' (SPC) mechanism for developer-led and plan-led Green Energy Park development for coordination and permit granting procedures.
This SPC, envisaged under the Renewable Energy Directive III and the Net Zero Industry Act, will facilitate prioritisation of development within a green energy park to maximise environmental benefits for the State.
2027
11. Connect Offshore Wind to Green Energy Parks
Action:Support the further development of a CPPA ‘Route to Market’ for offshore wind to supply Green Energy Parks.
The plan-led approach should ensure that new developments are powered primarily by renewable energy. The LEAP notes that it may be necessary for some developers to contract with ‘merchant’ offshore wind development through Corporate Power Purchase agreements (CPPAs).
This action will create opportunities for private procurement of renewable energy through CPPAs alongside the generation supported by the Offshore Renewable Electricity Support Scheme (ORESS) to secure cheaper energy for all electricity customers.
Interestingly this “hybrid” approach was noted by DCEE as a potential option for the next ORESS. With the requirements set out in the LEU connection policy regarding renewable electricity procurement for all new LEU connections, this should further drive large off-taker appetite for CPPAs in the Irish market.
2027
12. LEU Efficiency and Emissions Reporting
Action: Establish and mandate LEU efficiency reporting aligned with EU legislation, and review opportunity for real-time emissions reporting framework.
This action aims to ensure that decarbonisation ‘real-time’ emissions measurements will be introduced. It also aims to support measures in-line with EU legislation to drive energy efficiency improvements, demand-side flexibility and emissions reporting, including:
Article 12 of the Energy Efficiency Directive (EED) to increase transparency and drive energy efficiency in the data centre industry
EED Article 26 to promote utilisation of waste heat from data centres in nearby facilities
EU commission rating scheme and minimum performance standards
Opportunity for real-time emissions reporting infrastructure to enable accurate emissions data, aggregation and reporting by LEUs.
The hope for LEUs is that, to the extent national level reporting requirements are introduced, these are consistent and dovetail efficiently with EU level reporting to avoid burdensome reporting obligations.
2026
13. Market design to support co-location
Action: Electricity tariff and system services markets that enable co-location and incentivise demand-flexibility.
Implementation of revised National Energy Demand Strategy will consider new tariff and market structures to help with demand flexibility and efficient use of grid infrastructure, enhancing economic incentives for green energy developments.
Prospective Green Energy Park development will have access to ‘stackable’ revenue-making opportunities and grid connections to reflect their efficient use of grid infrastructure and provision of additional services which benefit the national energy system operation.
2028 and ongoing
Preparing for Strategic Opportunities
Objective
Summary/Commentary
Timeframe
14. Support opportunities aligned with national policy
Action: Facilitate Direct Engagement with Regional “Green Energy Park” Proposers.
Government departments and energy SOs will engage directly with proposers of developer-led green energy park projects.
2026 & onwards
15. Develop IDA Strategic site proposals
Action: Progress IDA Ireland ‘Next Generation Sites’
IDA will assess how the development of Next Generation Sites can complement the plan-led approach to Green Energy Park concepts set out in this strategy.
IDA’s Regional Property Programme seeks to provide land and advanced infrastructure solutions to both IDA and Enterprise Ireland (EI) client companies. These agencies will play a key role in energy park instigation subject to Government approval.
Proposals 2025; investments from 2030
16. Enterprise support for innovation in energy management
Action:Support innovation in the areas of energy management and storage for LEUs, and consider use of regulatory sandbox.
The Department of Enterprise, Tourism and Employment (DETE) will engage EI and IDA on how to support expert suppliers and service providers to LEU sectors to determine how the agencies can drive innovation in the areas of energy management, efficiency and storage.
The use of a regulatory sandbox to facilitate innovation in energy management will be considered.
2025 Workplan; 2026 implementation
17. Establish ‘Sectors of the Future’ Council
Action: Establish an LEU ‘Sectors of the Future’ expert Council to inform industrial policy approach to Energy Parks.
The plan-led approach outlined will allow for policy considerations regarding what type of LEU would provide the most advantageous broad economic and social return of Ireland. DETE and its agencies will establish an expert advisory panel.
DETE will assess whether EU or international regional designations such as ‘hydrogen valleys’ / ‘innovation valleys’ offer opportunities to enhance Green Energy Parks.
This will include an assessment of whether this will facilitate access to EU funding initiatives, such as the Innovation Fund, Competitiveness Fund, Hydrogen Bank or other EU/global research funds.
2026
Implementation and timeline
LEAP will be progressed on a cross-Government basis. The coordinated governmental effort to implement the Plan will mean regular monitoring, review and updates to ensure actions are being implemented. Oversight of these actions will be monitored by:
Revised National Energy Demand Strategy implementation group
Technical Working Group to support the preparation of a National Planning Statement (Action 8)
Annual Data Centre sector Roundtable (Action 9)
Engagement with Developer-led green energy park proposals by Departments, State Agencies and System Operators (Action 14)
‘Sectors of the Future’ Council (Action 17)
The actions described will be progressed concurrently under three key areas of activity:
Expediting delivery of infrastructure and unlocking innovation
Informing a Plan-Led approach
Embedding a Plan-led approach
Some actions are already underway, and others will start imminently. This Plan was an important announcement in a string of very positive developments in the Irish data centre and energy sector since December 2025.