EU Pushes the eCoC Deadline Back to 29 November 2026: the Implications for Manufacturers
A transitional arrangement for rolling out eCoC
In the wake of the 168th meeting of the European Commission's Working Group "Motor Vehicles" (MVWG) on 6 May 2026, EU Member States have settled on a transitional arrangement that cushions the 5 July 2026 eCoC obligation in jurisdictions whose national infrastructure won't be ready in time.
Under it, EU manufacturers may keep using paper Certificates of Conformity, or eCoC print-outs, until 29 November 2026 at the very latest. The aim is to give national access points (NAPs) and manufacturers the breathing space to test and bed in the new electronic registration process without jeopardising vehicle registrations.
The essentials at a glance
- Original deadline: 5 July 2026, when Member States must accept the eCoC as structured electronic data
- New cut-off: 29 November 2026, the final day on which paper CoCs and eCoC print-outs may be used
- Legal basis: Article 37(10) of Regulation (EU) 2018/858
- Scope: Member States where the NAP isn't yet operational, or came in less than four months before 5 July 2026
- Accepted duplicate: a signed and stamped print-out of the structured data, without the measures set out in Annex VIII of Commission Implementing Regulation (EU) 2020/683
Why the extension came about
The European Commission opened proceedings at the 168th MVWG meeting by reminding Member States of their legal duty to have data networks in place to receive eCoCs as structured electronic data from 5 July 2026. Yet, drawing on information gathered from the Member States, the EC acknowledged that at least several Member States will not have a fully working national access point, data retrieval or processing capability ready by the deadline, threatening the entire vehicle registration process in those jurisdictions.
The minutes pointed to three technical causes:
NAP design lag
The full design decisions for the National Access Point, supplied by Eucaris, landed too late for everyone to integrate, test and deploy on schedule.
Incomplete IVI services
The full suite of Initial Vehicle Information (IVI) services in Eucaris wasn't ready in time to support a harmonised rollout.
Late eCoC format
The final eCoC 2.0 format and the requirements around it were locked down with little time left for manufacturers to validate their mass data uploads.
What the transitional arrangement genuinely permits
The arrangement is tighter than it first looks. Under Article 37(10) of Regulation (EU) 2018/858, Member States agreed to permit — exceptionally and for a strictly limited window — the continued use of paper CoCs and the national procedures already in place, national eCoC procedures included, until 29 November 2026 at the latest.
Crucially, this relief is available only where national infrastructure is missing, or arrived less than four months before 5 July 2026, denying manufacturers a reasonable window to test mass data uploads. In Member States whose NAP is fully live on time, the 5 July obligation still applies in full.
A signed and stamped print-out of the structured data is enough to count as a valid duplicate, without the further measures laid down in Annex VIII to Commission Implementing Regulation (EU) 2020/683.
What it means for EU manufacturers
For manufacturers spread across several Member States, this is breathing space rather than a let-off. For the first time, implementation obligations pull apart: where the NAP is ready, eCoC submission is compulsory from 5 July; where it isn't, paper CoCs and print-outs stay valid until 29 November. During the transition, your internal processes have to run both routes at once.
The five-month window also shuts sooner than it appears. Most manufacturers need three to four months for system integration, signature testing and operator training — which puts the practical start date for a rollout in July, not November.
Don't mistake this for a reset
The November 2026 date is a backstop for jurisdictions where the infrastructure genuinely isn't ready — not a reset of the implementation timeline. In Member States whose NAP is live on 5 July, eCoC submission is mandatory from that day, so stalling your project on the assumption of an EU-wide extension carries real regulatory risk.
Six months to the November deadline: your next steps
Whether your jurisdiction runs to the original 5 July date or the new 29 November cut-off, the practical groundwork is the same. Put the window to use to:
- Establish which NAPs your business must submit to, and whether each will be live on 5 July or leaning on the transitional arrangement
- Produce and validate test IVI XML files against the eCoC 2.0 schema for every relevant Member State
- Carry out end-to-end XAdES digital signature integration tests against each NAP API
- Set up a fallback for generating signed and stamped print-outs for as long as the transitional arrangement applies
- Bring operations and homologation staff up to speed on both the digital submission and the paper-duplicate workflow
eCoC EU² covers both routes
eCoC EU² software handles the complete eCoC lifecycle and the paper-duplicate fallback at the same time, keeping you compliant whichever route applies in each jurisdiction:
With six months left until the November backstop, now is the moment to act. Get in touch and we'll help you scope a deployment that suits your production volumes and Member State coverage.