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Software & SaaS × ESG & Sustainability — International / Multilateral · Last updated 11 Jun 2026 · methodology v2.3 · Hallucination Register
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AI Hallucination on the OECD Recommendation on Digital Technologies and the Environment (2025) for ESG & Sustainability teams at Software & SaaS firms in international jurisdictions

ESG & Sustainability teams at Software & SaaS firms operating under digital infrastructure environmental impact and data-centre energy reporting are increasingly using AI to surface OECD data-centre energy benchmarks for sustainability-report sections, draft investor data room briefs on digital-infrastructure footprint, populate regulatory mapping documents with verbatim OECD statistics, and contextualise product sustainability claims against national data-centre energy trends.

The OECD's 2025 Revision of the Recommendation on Digital Technologies and the Environment carries a named, citable statistic on Ireland's data-centre share of metered electricity, drawn from Ireland's Central Statistics Office, that ESG & Sustainability teams at software and SaaS firms will reach for when populating sustainability disclosures, ESG investor responses, and regulatory briefings on digital-infrastructure environmental impact. That statistic is exactly the kind of figure the RLB Specialist Panel tested two frontier AI subjects against.

The RLB Specialist Panel issued a Specialist Panel application-style question on the share of Ireland's 2021 metered electricity that data centres accounted for, per the figure cited in the OECD Digital Economy Outlook 2024 chapter referenced by the 2025 Recommendation, sourced from Ireland's CSO (2023). Two frontier AI models tested by the RLB Specialist Panel returned the figure as 14 per cent and extended the answer with a four-point time series running from 5 per cent in 2015 through 21 per cent in 2023. The regulator's verbatim text records 11 per cent in 2021, with no multi-year trajectory.

The failure class is Fabricated Fact: a confidently delivered, citably attributed statistic that does not match the source document, compounded by a fabricated time series that does not appear anywhere in the OECD or CSO published record.

For ESG & Sustainability teams at software and SaaS firms, this is operationally consequential because the wrong figure is not a vague paraphrase. It is delivered with a real source chain, CSO 2023 via OECD Digital Economy Outlook 2024, that survives standard reference-check review.

When ESG teams at SaaS firms use AI tools to surface OECD data-centre energy benchmarks, the AI produced the wrong figure for Ireland's 2021 share of metered electricity, 14 per cent versus the correct 11 per cent per CSO 2023 as cited in OECD Digital Economy Outlook 2024, and fabricated a multi-year trajectory that does not exist in the source document. Any sustainability report section, investor data room brief, or regulatory mapping document that incorporates this figure carries a materially incorrect OECD statistic with correct-looking source attribution, a combination that passes standard QA review undetected.

For SaaS firms benchmarking their digital infrastructure footprint against OECD-cited sector data, or making product sustainability claims that reference national data-centre energy trends, the downstream exposure includes audit findings, investor relations issues, and reputational damage if the discrepancy surfaces through primary source verification by a third party.

The audit's finding on this question is published with an immutable RLB Citation ID. The relevant entry is RLB-H-INT-OECD-OECD-DIGITAL-TECHNOLOGIES-ENVIRONMENT-2025-Q006-Sonnet46. The full audit is published at the OECD Digital Technologies and the Environment Recommendation (2025 Revision) hub on RegLegBrief.com.

This is the consolidated view of findings. Click the Citation IDs or 'see details →' on any item for the full details for each finding.

  1. Ireland data-centre electricity share fabrication
    RLB-F-INT-OECD-OECD-DIGITAL-TECHNOLOGIES-ENVIRONMENT-2025-Q006

    When ESG teams at SaaS firms use AI tools to surface OECD data-centre energy benchmarks, the AI produced the wrong figure for Ireland's 2021 share of metered electricity (14% versus the correct 11% per CSO 2023 as cited in OECD Digital Economy Outlook 2024), and fabricated a multi-year trajectory that does not exist in the source document. Any sustainability report section, investor data room brief, or regulatory mapping document that incorporates this figure carries a materially incorrect OECD statistic with correct-looking source attribution, a combination that passes standard QA review undetected.

    For SaaS firms benchmarking their digital infrastructure footprint against OECD-cited sector data, or making product sustainability claims that reference national data-centre energy trends, the downstream exposure includes audit findings, investor relations issues, and reputational damage if the discrepancy surfaces through primary source verification by a third party.

    see details →

Every finding on this page compares an AI subject's account of the rule against the regulator's verbatim text from the regulator's own portal. Both are linked. Each delta, its root causes, and impact analysis are documented and published with immutable Citation IDs.