Kao Data Harlow AI campus / KLON-03

FJI source-qualified: four-document gate met, including project-specific government evidence. Qualification evidence and decisions →

Project status: KLON-03 under construction; earlier campus buildings operational. Capacity scope: 17.6 MW planned KLON-03 IT; 22 MW Nebius agreement spans campus, allocation unknown. How we verify evidence.

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Approximate locality marker. Construction-stage classification does not mean every planned phase is permitted, energized or serving customers.

Investment takeaway

A contracted AI expansion at an established UK campus, supported by construction evidence and a project-specific environmental decision, offers a more tangible delivery case than speculative UK greenfield announcements. Listed exposure differs sharply: Nebius pays for compute hosting; Infratil participates through ownership; Shell supplies electricity.

Power and readiness

The existing campus supply and renewed Shell electricity arrangement are documented. Downing plans a private-wire solar project supplying up to 40 MW; neither the solar announcement nor annual renewable certificates proves continuous carbon-free electricity or new phase grid headroom. The environmental permit covers emergency generators, not IT commissioning.

Capital and financing

Infratil reports construction progressing and materially all operating and under-construction capacity contracted at year-end. No KLON-03-specific debt amount, lease pricing or return is disclosed. Nebius’s £1.7 billion UK program is a national allocation, not Harlow capex. Kao-wide revenue and EBITDA must not be assigned to this campus.

Company economic roles

Kao Data develops and operates the campus. Harlow Operations Limited is the permit operator. Nebius (NBIS) is the contracted AI cloud customer; Infratil (IFT) is a listed investor; Shell (SHEL) is the electricity supply counterparty; Downing is the prospective solar developer. NVIDIA-ready design is not a verified GPU procurement contract.

Milestones

KLON-03 was announced March 12, 2025. Downing disclosed the solar arrangement November 18, 2025. Infratil’s May 26, 2026 results reported construction progressing and capacity from early 2027. The Environment Agency granted its variation June 3, 2026; the Nebius agreement followed June 8. Shell signed its renewed agreement July 1 (published July 2).

Risks

Commissioning and cooling delivery, tenant ramp and concentration, electricity tariffs and prospective solar permitting remain material. Historical campus design totals differ from the current operator profile; use phase-specific figures and retain that discrepancy.

What would change the assessment

Verified ready-for-service and energized customer delivery would strengthen the assessment. A revised customer agreement, delayed power or cooling commissioning, or new backup-operating restrictions would weaken it.

Unknowns

The exact Nebius allocation between KLON-02 and KLON-03, GPU delivery date, Harlow revenue and EBITDA, lease economics, actual utilization, solar PPA terms and commissioning, and phase-specific grid capacity are not established.

Coverage and scope

Begins U.K. coverage through a documented AI expansion at an established campus. One Harlow campus; KLON-03 construction readiness, earlier buildings operational, no duplicate phase entry.

Financial significance and assumptions

Infratil reports construction progressing and materially all operating and under-construction capacity contracted at year-end. No KLON-03-specific debt amount, lease pricing or return is disclosed. Nebius’s £1.7 billion UK program is a national allocation, not Harlow capex. Kao-wide revenue and EBITDA must not be assigned to this campus.

Our analysis: construction can precede customer billing and cash returns. No utilization, pricing, margin or project earnings model is assumed. Investment plans, financing facilities and money spent are different quantities.

Listed company connections

• NBIS: Contracted AI customer; campus hosting costs differ from Nebius revenue.
• IFT: Listed investor in Kao; owner-wide results cannot be assigned to KLON-03.
• SHEL: Electricity supply counterparty; contract value and campus earnings undisclosed.

Government record audit

Environment Agency · Record / evidence ↗. Reviewed October 7, 2026.

Identifier

EPR/WE4588AB/V002

Record type

Bespoke environmental permit variation decision

Applicant / entity

Harlow Operations Limited

Filed

not established

Decision

2026-06-03

Status

Granted

Phase scope

Emergency standby generators KLON1/2/3

Conditions / limits

Routine monthly readiness tests on weekdays between 9 a.m. and 5 p.m.; air emission and performance monitoring and reporting. Read the decision with the full permit. Covers emergency combustion plant, not computing commissioning.

Source basis and claim audit

7 distinct reviewed documents. Primary evidence and independent reporting are identified below; syndicated releases count once. Sources establish only the stated claim, not whole-campus completion.

1. Kao Data ↗ · Company disclosure. Published 2025-03-12; event 2025-03-12; reviewed October 7, 2026.

   KLON-03 construction announcement: 17.6 MW planned AI capacity, hybrid direct-to-chip cooling and up to 130 kW racks are company design claims.

2. Infratil ↗ · Listed owner results. Published 2026-05-26; event 2026-05-26; reviewed October 7, 2026.

   FY26 presentation, PDF page 24 (printed 19): KLON-03 construction progressing; capacity expected from early 2027. Materially all operating and under-construction capacity was contracted at year-end. Revenue £48 million and EBITDAF £4.7 million are Kao-wide figures.

3. Environment Agency ↗ · Government decision. Published 2026-06-03; event 2026-06-03; reviewed October 7, 2026.

   Permit EPR/WE4588AB/V002 granted to Harlow Operations Limited June 3, 2026. Adds KLON-03 emergency generators and extra KLON-01/02 units. 152 MW combined thermal combustion input is not IT load.

4. Kao Data ↗ · Company commercial disclosure. Published 2026-06-08; event 2026-06-08; reviewed October 7, 2026.

   22 MW ten-year Nebius campus agreement; AI Cloud and Token Factory to be hosted at Harlow. The entire allocation is not attributed solely to KLON-03.

5. DatacenterDynamics ↗ · Independent specialist reporting. Published 2026-06-08; event 2026-06-08; reviewed October 7, 2026.

   Independent specialist reporting of the Nebius agreement and national investment plan. Historical building capacity figures differ from the current operator profile.

6. Downing Renewable Developments ↗ · Power counterparty disclosure. Published 2025-11-18; event 2025-11-18; reviewed October 7, 2026.

   Prospective private-wire solar development up to 40 MW with planned PPA; announcement does not establish solar commissioning or continuous firm electricity.

7. Kao Data / Shell agreement ↗ · Power supply disclosure. Published 2026-07-02; event 2026-07-01; reviewed October 7, 2026.

   Shell Energy UK signed renewed supply agreement July 1, published July 2. Kao-wide approximately 140 GWh annual supply since 2022 is renewable-certificate matched, not exclusive Harlow generation.

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