New UK Type Approval Obligations: eCoC Under Assimilated Regulation 2018/858
The legal basis for UK eCoCs
The UK's eCoC mandate stems from Assimilated Regulation (EU) 2018/858 — the EU type approval framework regulation that was retained in UK law after Brexit. Under this regulation, from 5 July 2026, manufacturers must make the Certificate of Conformity available to the VCA as structured data in electronic format, without unnecessary delay and at no cost, after the vehicle is produced.
This regulation replaced the earlier Directive 2007/46/EC (which is no longer in force) and provides the overarching framework for vehicle type approval, market surveillance, and conformity obligations in the UK.
GB and UK(NI) type approval schemes
The UK operates two parallel type approval schemes:
GB Type Approval (g11)
For vehicles sold in Great Britain. From February 2026, all M and N category vehicle types must hold a full GB type approval (g11). Provisional approvals have expired. O category vehicles must hold full GB approval by February 2027.
UK(NI) Type Approval (n11)
For vehicles sold in Northern Ireland, which remains aligned with the EU type approval framework. Vehicles approved under the UK(NI) scheme carry the n11 approval authority code.
Dual marking and Northern Ireland
In December 2025, the UK Government announced its intention to mandate dual GB and EU type approval marking for vehicles placed on the Great Britain market. This would ensure that all vehicles sold in GB can also be sold in Northern Ireland without separate approval.
For eCoC purposes, manufacturers with dual-marked vehicles need to generate both UK and EU eCoCs from the same data set. Only the GB eCoC needs to be submitted to the VCA for dual-marked vehicles.
Key regulations at a glance
- Assimilated Reg (EU) 2018/858 — eCoC mandatory from 5 July 2026
- Implementing Reg (EU) 2021/133 — specifies eCoC data format and exchange
- Implementing Reg (EU) 2024/1061 — further eCoC implementation details
- SI 2025 No. 661 — GB type approval amendment regulations
Multi-stage derogation for body builders
Recognising the complexity of multi-stage builds, the VCA has provided a temporary derogation: second-stage manufacturers (body builders) can obtain multi-stage approvals before the base vehicle manufacturer has obtained full GB type approval.
- M and N category vehicles: derogation until 1 August 2026
- O category vehicles: derogation until 1 August 2027
- Does not apply where the same manufacturer holds both base and completed vehicle approvals
EU-format CoC derogation ending
Until 1 July 2026, there is a derogation permitting the use of EU-format CoCs in Great Britain. After this date, only GB eCoCs (submitted to the VCA) will be accepted. Manufacturers relying on EU-format CoCs must transition to the UK IVI format before the deadline.
COCDesk — built for UK regulatory compliance
COCDesk is designed to handle the full scope of UK eCoC obligations:
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