Sectors / 05
Data centres & robotics
Hyperscale builds and humanoid robotics draw on the same scarce components and materials. We test the suppliers behind them, and trace the materials back to source.
Three questions, answered with evidence.
010203What we read.
- PowerTransformer and switchgear metals: copper and aluminium origin under the UFLPA.
- CoolingChiller components and F-gas compliance.
- Compute hallsEAR advanced-computing rules on the hardware and its end user.
Standards & regulation.
The frameworks we work to in this sector.
Cyber risk and incident reporting.
Resilience of critical entities.
UK essential and digital services.
ICT third-party risk for financial clients.
Information security management.
Business continuity.
Energy management.
Controls on advanced computing and dual-use items.
Due diligence on battery materials.
Strategic materials and supply concentration.
Conflict minerals in electronics.
Responsible minerals benchmark.
Smelter and refiner assurance.
Forced-labour presumption on imports.
EU ban on forced-labour products.
Embedded emissions in steel and aluminium.
Supply chain security.
Personal data and breach reporting.
Where we look.
The official procurement and trade sources we draw on.
UK above-threshold notices.
Central government, above £12k.
EU public procurement.
Federal ICT and infrastructure.
ICT and C4ISR procurement.
Robotics and autonomy R&D.
EPC and operator supplier programmes.
Related thinking.
Recent notes that bear on this sector.

CBAM’s first real year. The bill is small; the data is not.
The EU carbon border adjustment has charged for embedded emissions since 1 January. Certificates for 2026 imports go on sale in February 2027 and must be surrendered by 30 September 2027. The 2026 charge is small, but it rises every year, and what it costs depends on data most importers do not yet hold.

China’s rare earth pause has two more months. Plan as if it ends.
China’s suspension of its October 2025 rare earth controls was due to end on 10 November. The US–China truce behind it now runs to 10 January 2027. The April 2025 licensing on seven medium and heavy rare earths never stopped. Magnet-dependent supply chains should plan for both.

The US “affiliates rule” is paused, not gone. Check who owns your customers.
Washington’s pause on the BIS affiliates rule was due to end on 9 November and is expected to follow the US–China truce to 10 January 2027. When it returns, companies 50% or more owned by listed parties face the same restrictions as their owners, whether or not they appear on any list.