Turning planned capacity into operational infrastructure depends increasingly on electricity connections, permits, connectivity and the dependencies that govern day-to-day resilience.
Grid requests are not operational data centre capacity
Demand for cloud services, digital infrastructure and compute-intensive applications is driving Italy's data centre market. The scale of interest is visible in figures from transmission system operator Terna: at the end of January 2026, it reported 449 data centre grid-connection requests with a combined requested capacity of 78.79 gigawatts. These figures describe requests, not operating IT capacity or guaranteed grid connections. [1]
For developers and operators, the distinction matters. A prospective site is viable only when grid access, the timing of power availability, an approvable facility design and the future security operating model align. Italy introduced a single authorisation procedure for the construction, expansion and operation of certain data centres under Decree-Law 21/2026, as amended by Law 49/2026. Bringing environmental, water, emissions and planning considerations into the procedure does not remove the underlying requirements. [4]
Why Lombardy deserves particular attention
Milan is a major Italian interconnection location, anchored by the Milan Internet Exchange (MIX). Demand, networks and data centre services converge in this market. [2] In June 2026, Lombardy also adopted its own legislation on data centre development, addressing issues including land use, energy supply, water consumption and waste heat. Further implementing administrative rules followed in August 2026. [5]
One issue is easy to overlook: large standby generation installations can affect the environmental authorisation route and the competent authority. Lombardy's guidance distinguishes installations by the thermal input of combustion equipment. That is not the same as IT electrical load or the grid connection rating. The requirements must be assessed against the actual project. [5]
Milan, Rome and Palermo have different network roles
Milan's established position makes it attractive for connectivity. However, operators should distinguish logical redundancy from genuine independence of network routes. Different carriers and contracts do not by themselves prove separate cable ducts, handover points or failure domains.
Other parts of Italy provide complementary network functions. MIX operates regional interconnection services, including in Rome. Around Palermo, the Open Hub Med ecosystem is being developed for traffic exchanged between Europe, Africa, the Middle East and Asia, with participants highlighting the area's submarine cable links. [3] A geographically distributed design can strengthen resilience, but only where transport paths, network operators and operational dependencies are sufficiently independent in practice.
Availability depends on facilities, remote access and local hazards
Electricity and cooling are the technical foundations of a data centre. Their dependability also rests on building management systems, access control, maintenance contractors, remote connectivity and the ability to respond. An isolated IT network, for example, provides limited reassurance if critical building controls can be accessed remotely without appropriate safeguards or several redundant services depend on the same switching or control function.
Natural hazards also require a site-specific assessment in Italy. ISPRA publishes national evidence on flooding and landslides, while the INGV provides seismic hazard information. [11][12] National hazard maps cannot, however, determine the risk of an individual plot on their own. What matters is the local exposure, facility design and the resilience of supply and recovery arrangements.
Assign Italian regulatory obligations to the right operator
Italy transposed the NIS2 Directive (EU) 2022/2555 through Legislative Decree 138/2024. Depending on the circumstances, it covers providers of data centre and cloud services as well as telecommunications undertakings. The actual services, legal entity, size and special rules, and the competent authority determine how the regime applies. National registration and implementation of security requirements operate within the framework administered by the Agenzia per la Cybersicurezza Nazionale (ACN). [6]
Separately, Commission Implementing Regulation (EU) 2024/2690 specifies technical measures and significant incidents for certain digital providers. [7] Italy's Legislative Decree 134/2024 transposes the Critical Entities Resilience Directive (EU) 2022/2557. This does not automatically designate every data centre as a critical entity; the national identification process is decisive. [8]
Energy and sustainability information is another distinct obligation. Under Article 16 of Decree-Law 131/2024, as amended by Law 166/2024, Italy requires operators with installed IT power demand of at least 500 kW to publish specified information. Exceptions cover certain data centres serving defence and civil protection exclusively, and information protected by confidentiality and trade-secret rules. This 500 kW threshold belongs to this publication requirement; it must not be used as a threshold for NIS2 or planning permission. [9][10]
Decisions that now matter to operators
For new developments, credible assumptions on grid connections and permissions should inform the final security architecture. For existing facilities, the priority is to identify common-mode dependencies in power, cooling and connectivity, govern third-party remote access, and coordinate security, facilities, IT and service providers. Compliance evidence must match the operator's actual role and services. Regulated customers may also introduce contractual requirements, including those associated with DORA (Regulation (EU) 2022/2554) in financial services. [13]
An integrated security architecture from Concepture
Some of a data centre's most significant attack paths lie at its boundaries: between customer and operator networks, administration and production environments, building automation and IT, and external maintenance connections. A sound security architecture therefore requires documented network and system structures, risk-based segmentation, restricted communication paths and accountable access control. Responsibilities for customer environments and operator infrastructure must be clearly distinguished. [7]
Concepture integrates network, IT and OT security with physical protection, governance and operational resilience. Within an agreed scope, we identify the relevant systems, network zones, data flows and dependencies. We then develop and assess segmentation and network access concepts, secure administrative and remote access, and requirements for logging, threat detection and incident response. We connect these measures with building automation, cooling, power and emergency supply, physical access and perimeter security, as well as supplier governance, crisis management and recovery. [14][15][16]
For operators in Italy, we align these measures with the actual operating model and the requirements that apply under Legislative Decree 138/2024, Commission Implementing Regulation (EU) 2024/2690 and the rules issued by the Agenzia per la Cybersicurezza Nazionale (ACN). The aim is a practical security architecture, clear accountability, prioritised actions and auditable evidence. The Data Centre Resilience Check can provide an initial assessment; deeper IT/OT assessments, architecture development and implementation support are scoped separately as needed. The check itself is not certification, legal advice or a comprehensive technical inspection of installations. [6][7][14][15][17]
Next step: When developing, expanding or operating a site in Italy, start by clarifying the most critical dependencies and accountabilities. Discuss your specific situation with Concepture.
Sources
[1] Terna, “Da rifiuto a risorsa: la nuova sfida della transizione ecologica e digitale”, 16 February 2026, Il contesto italiano: https://lightbox.terna.it/it/sfide/data-center-green
[2] MIX, “MIX Milano”, accessed 15 November 2026: https://www.mix-it.net/exchange/milano/
[3] MIX, “OHM acquired by Mediterra DataCenters”, 30 March 2026: https://www.mix-it.net/en/ohm-acquired-by-mediterra-datacenters-mix-confirms-support-for-the-development-of-the-palermo-hub/
[4] Italian Official Gazette, Decree-Law 21 of 20 February 2026, Article 8, coordinated with Law 49 of 10 April 2026, published 18 April 2026: https://www.gazzettaufficiale.it/eli/gu/2026/04/18/90/sg/pdf
[5] Regione Lombardia, “Procedimento Unico Centri Dati”, updated 12 October 2026, referring to Regional Law 11/2026 and regional resolutions 6645/6646: https://www.regione.lombardia.it/ambiente-e-territorio/autorizzazione-ambientali/autorizzazione-integrata-ambientale-aia/procedimento-unico-centri-dati ; official statute contents: https://normelombardia.consiglio.regione.lombardia.it/Accessibile/main.aspx?exp_coll=3851987&iddoc=lr002026060300011&selnode=3851987&view=showsum
[6] Italian Official Gazette, Legislative Decree 138 of 4 September 2024, particularly Article 3 and Annex I (NIS2 transposition): https://www.gazzettaufficiale.it/eli/id/2024/10/01/24G00155/sg
[7] European Commission, Implementing Regulation (EU) 2024/2690, Article 8 and Annex sections 3.2, 6.7, 6.8 and 11: https://eur-lex.europa.eu/eli/reg_impl/2024/2690/oj
[8] Italian Official Gazette, Legislative Decree 134 of 4 September 2024, particularly Articles 8 and 13–14 and Annex A (CER transposition): https://www.gazzettaufficiale.it/eli/id/2024/09/23/24G00150/sg
[9] Italian Official Gazette, Decree-Law 131 of 16 September 2024, Article 16, as amended by Law 166 of 14 November 2024: https://www.gazzettaufficiale.it/eli/id/2024/09/16/24G00149/sg ; conversion law: https://www.gazzettaufficiale.it/eli/id/2024/11/14/24G00184/sg
[10] European Commission, Delegated Regulation (EU) 2024/1364, Articles 1–2: https://eur-lex.europa.eu/eli/reg_del/2024/1364/oj
[11] ISPRA, “Dissesto idrogeologico in Italia”, 2024 edition, report 415/2025: https://www.isprambiente.gov.it/it/pubblicazioni/rapporti/dissesto-idrogeologico-in-italia-pericolosita-e-indicatori-di-rischio-edizione-2024
[12] INGV, Seismic Hazard Centre: https://cps.ingv.it/it
[13] European Union, DORA, Regulation (EU) 2022/2554: https://eur-lex.europa.eu/eli/reg/2022/2554/oj
[14] Concepture, “Resilience for data centres”, scope and limitations of the service, online review 15 November 2026: https://concepturegroup.com/en/offers/dc-resilience-check
[15] Concepture, “OT & Site Resilience”, 2026, published service scope including OT/ICS assessment, network segmentation and remote-access governance: https://concepturegroup.com/en/services/governance-risk-and-compliance/ot-site-resilience
[16] Concepture, “Cybersecurity”, 2026, security architecture, threat detection and incident response: https://concepturegroup.com/en/services/cyber-forensics
[17] Agenzia per la Cybersicurezza Nazionale, Determination 379907 of 19 December 2025, listed on the Italian Ministry of University and Research transparency portal; replaces Determination 164179/2025. Determination 127434/2026 also applies to certain entities first listed in 2026: https://trasparenza.mur.gov.it/pagina939_avvisi-e-news.html


