The European Union (EU) has embraced the “twin transition” – the simultaneous pursuit of digitalisation and ecological transformation – as a cornerstone of its industrial policy. EU lawmakers argue that digital technologies can advance environmental protection by enhancing environmental monitoring, optimising resource use, and enabling data-driven sustainability efforts. However, this vision tends to overlook the environmental costs of digitalisation, including rising energy and water consumption, intensive resource extraction, and the proliferation of electronic waste. This article critically examines whether EU law is adequately equipped to support a twin transition, drawing on a black-letter analysis of EU legal provisions, as well as insights from science and technology studies and critical environmental law. It posits that, while environmental law plays a significant role in the datafication of the environment and the digitalisation of society, it falls short in regulating digital technology and data in ways that advance sustainability. For the twin transition to evolve beyond a political slogan and deliver real ecological benefits, substantial legal reforms would be required. The regulation of digital technology would have to move beyond corporate self-regulation and disclosure-based models of environmental governance. Data governance should be reoriented to emphasise freedom of access and a more deliberatively restrained approach to data generation.

Over the past decade the European Union (EU) has transformed sustainability into a dense matrix of legally binding ESG reporting obligations for companies. Compliance increasingly hinges on firms’ ability to collect and verify thousands of datapoints deep into global supply chains – an exercise that is costly, error-prone and may yield non-comparable results. (Semi-)centralised ESG data-sharing arrangements – shared hubs where suppliers post one or more verified sets of sustainability figures that all their customers can reuse – can restore some efficiency by eliminating duplicate requests and supplying standardised, audit-ready inputs, but this amplifies competition-law risk. Drawing on competition law and policy and recent Dutch banking practice, the paper devises a set of legal “firewalls” and access rules that neutralise collusive potential resulting from the information exchange that takes place while safeguarding smaller market players from exclusion. These safeguards are essential to ensure that ESG data collaboration supports – not hinders – the EU’s Twin Transition towards a green and digital economy.