New FIDIC Carbon Management Guide: How this could become a game-changer for data centre developments

Global demand for digital infrastructure is ever increasing. This also applies to the scrutiny for the data centre sector, considering energy & water consumption as well as carbon emissions. On 2 December 2025, FIDIC launched its Carbon Management (CM) Guide as well as its accompanying Carbon Emissions Management (CEM) Guidance. This set of documents provides for new tools to help improve & monitor the sustainability of the development & usage of new data centres. 

Understanding the FIDIC Carbon Management Framework

The FIDIC framework consists of the overarching CM Guide and the contract-specific CEM Guidance, that is tailored to individual FIDIC contracts. This tailoring consists of:

• Potential particular conditions to the relevant FIDIC general conditions
• Examples for a carbon balance sheet, scope of work/services, emissions calculation, formula for relevant damages and incentives
• Guidance on how to approach the relevant tender, including an example for tender evaluation.

This approach allows for a carbon emissions focused approach to be used more easily and frequently in practice. 

Within a FIDIC setting, it provides for the integration and alignment with existing FIDIC provisions on topics such as variations, claims and disputes.

The framework rests on six foundational principles that transform how carbon is managed in infrastructure projects, as phrased by FIDIC:

1. Making the carbon emissions budget a mandatory evaluation criterion transforms procurement into a driver of innovation
2. All stakeholders working together to improve the project's carbon balance sheet creates a common goal
3. Prioritising the reduction of greenhouse gas (GHG) emissions rather than the use of offsetting focuses on change now
4. Establishing unambiguous calculation methodologies delivers fair competition and contractual certainty
5. Maintaining employer responsibility for GHGs removal rather than transferring risks inappropriately ensures clarity and certainty
6. Recognising the need for continuous improvement helps drive industry transformation forward towards decarbonisation

Why data centres benefit from this approach?

Data centres have significant carbon emissions, following from for instance:

• Its concrete foundations and structural slabs
• Steel frameworks for racks and other equipment
• Specialised cooling infrastructure & water usage
• Redundant power systems
• Safety measures such as to deal with fire

Not only during construction but especially also during the operational phase, data centres present specific carbon management challenges. Considering the increased focus of users, developers and investors on sustainability, as well as increased scrutiny in this regard, data centres are a prime candidate to adopt such an integrated and sophisticated carbon emissions focus on.

The lifecycle approach for data centres

The CM Guide and the contract-specific CEM Guidance promote a lifecycle approach, depending on the typical scope of the underlying FIDIC model. In case of the involvement of advisors, through the Client/Consultant Model Services Agreement Fifth Editions 2017 (FIDIC White Book), the scope of works proposed for the consultant considers inception, pre-design, preliminary design, developed design, construction documentation, permit application, construction procurement, construction, DNP, operation service and end of operation as different phases. 

Carbon budgets

The carbon balance sheet tracks emissions during each of these phases. Carbon ambitions will be set, reflected in Carbon Emissions Budgets that limit the Carbon Emissions allowed. This allows to make more deliberate decisions during each of these phases, for instance to compare (design) proposals or decide on proposed variations. 

During the project, the actual ‘incurred’ Carbon Emissions will be monitored, and compared against this budget, through frequently updated Carbon Emissions Reports. This is not only relevant to the employer and the contractor, but also to lenders and investors providing ‘green’ funds. 

To enable the aforementioned, the CM Guide has a strong focus on ensuring the right and correct data is provided to the relevant parties. 

Stick and the carrot

To increase the chance of the Carbon Emissions Budgets being met, detailed approaches are provided on how to contractually and commercially incorporate both Carbon Emissions Incentives (in case the Carbon Emissions Budget is not entirely depleted) and Carbon Emissions Damages (if there this budget is exceeded). 

Additional tools

Furthermore, the CM Guide provides for a range of additional tools to achieve the carbon emissions goals, including the possibility to appoint a Carbon Emissions Manager Officer, to for instance provide climate risk assessments, organising Carbon Emissions focused meetings, introducing Carbon Emissions Milestones as progress-based checkpoints, and the development of a Carbon Emissions Risk Register and a Carbon Emissions Risk Management Plan.

The team behind the CM Guide

The CM Guide and CEM Guidance were (and continue to be) prepared by FIDIC Contracts Committee Task Group 23, comprising Hugo Fonseca (Task Group Chair), Jeremy Glover, Rami Ismail, Bipin Bahri, Edith Bustamante, and Idriss Kathrada, together with Adriana Spassova.

The author of this article is honoured to have contributed as a friendly reviewer to this important initiative. 

More information on the CM Guide and the other relevant carbon management documents can be found here: FIDIC | New FIDIC Carbon Management Guide launched at London contracts conference | International Federation of Consulting Engineers