Executive briefing based on the EUCARIS webinar of 19 May 2026 and the decision of the 168th meeting of the Motor Vehicles Working Group (MVWG).
What is changing in the EU
The electronic Certificate of Conformity (eCoC) in IVI 2.0 format replaces the paper CoC under Article 37 of Regulation (EU) 2018/858. The original mandatory go-live date (5 July 2026) has been softened by a European Commission decision at the 168th MVWG meeting of 6 May 2026:
- eCoC (v1.x or 2.0) is optional until 29 November 2026.
- A paper CoC remains mandatory where an eCoC is not provided.
- The Commission has explicitly left it to each Member State to decide how vehicle registration is handled during the transitional period.
Legal note
The 29 November 2026 date is not a formal legislative amendment, it is a working-group decision reflected in the MVWG minutes. The original 5 July deadline technically still stands in the text of the Regulation.
Each country decides its own implementation timeline
This is the most important operational takeaway from the webinar. Sjaak Kempe (EUCARIS) put it plainly:
“The transitional period will look different in every country.”
For a manufacturer or distributor selling into the EU, this means three possible scenarios in parallel:
1. Country with a live NAP
E.g. Germany, the Netherlands. eCoCs accepted digitally; a paper copy may still be required in parallel under national law.
2. No NAP, with EUCARIS retrieval
The manufacturer can submit through another country's NAP (e.g. RDW in the Netherlands), and the destination country retrieves the document via EUCARIS.
3. No NAP and no retrieval
Paper CoC is almost certainly required; a digital submission has no legal effect in that country.
There is no single EU-wide go-live date. There is also no central registry of readiness across the 27 Member States, EUCARIS itself confirmed this. Manufacturers must monitor each market individually.
Member State status (as of 19 May 2026)
| Country | NAP / Status | Notes |
|---|---|---|
| Germany | Ready before 5 July 2026 | Own NAP (KBA), not using the EUCARIS solution |
| Netherlands | Preparing, most advanced | RDW; already accepting the IVI 2.0 format |
| Poland | Preparing | Working through the download-certificate implementation |
| Czech Republic | Own NAP | Not using the EUCARIS solution |
| France, Italy, Lithuania, Romania, Finland, Luxembourg | Preparing | Early stage; many blocked by the download-certificate issue |
| Spain | Unclear | DGT has not confirmed its approach |
Key takeaway: the German market
- • Germany has confirmed readiness before 5 July 2026 and is rolling out its own NAP via KBA (not using the EUCARIS solution).
- • Anyone selling vehicles into the German market must be ready for eCoC by 5 July 2026 at the latest.
- • Germany is not waiting for EU harmonisation, the digital requirement applies in its registration system regardless of the Commission's decision on the transitional period.
What this means in practice for EU manufacturers and distributors
- Selling only in a country whose NAP is not yet live: the paper CoC remains mandatory until 29 November 2026; eCoC becomes optional once the local NAP is operational.
- Selling into Germany: you need to be ready for eCoC from 5 July 2026.
- Selling across multiple EU markets at once: both formats will be required in parallel, paper and eCoC.
- Cross-border model works: you can submit the eCoC through another country's NAP (e.g. RDW in the Netherlands), provided the destination country has a retrieval point connected to EUCARIS.
- Signing certificate must come from a Qualified Trust Service Provider (QTSP) on the EU Trusted List, only such certificates are accepted across all NAPs.
Recommendations
- Treat 5 July 2026 as a hard operational deadline for anyone placing vehicles on the German market.
- Treat 29 November 2026 as the maximum hard deadline for the rest of the EU. The time it takes to deploy the infrastructure (NAP integration, QTSP certificate, XML pipeline) is the same regardless of country.
Source: EUCARIS Technical Webinar IVI 2.0 / eCoC, 19 May 2026 (Sjaak Kempe). Legal basis: Regulation (EU) 2018/858, Article 37; eIDAS Regulation (EU) 910/2014, Articles 36 and 38.
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