A management-level briefing drawn from the EUCARIS webinar of 19 May 2026 and the ruling of the 168th meeting of the Motor Vehicles Working Group (MVWG).
What is shifting across the EU
Under Article 37 of Regulation (EU) 2018/858, the electronic Certificate of Conformity (eCoC) in IVI 2.0 format takes over from the paper CoC. The original mandatory go-live date of 5 July 2026 has been eased by a European Commission decision taken at the 168th MVWG meeting on 6 May 2026:
- eCoC (v1.x or 2.0) stays optional until 29 November 2026.
- Where no eCoC is supplied, a paper CoC is still required.
- The Commission has deliberately handed each Member State the choice of how to manage vehicle registration during the transitional period.
A legal caveat
The 29 November 2026 date isn't a formal change to the legislation; it is a working-group decision captured in the MVWG minutes. Strictly speaking, the original 5 July deadline still appears in the wording of the Regulation.
Every country sets its own implementation timeline
This is the single biggest operational lesson from the webinar. Sjaak Kempe (EUCARIS) summed it up bluntly:
“The transitional period will look different in every country.”
For any manufacturer or distributor selling into the EU, that translates into three scenarios running side by side:
1. A country with a live NAP
Germany and the Netherlands, for example. eCoCs are taken digitally, though national law may still call for a paper copy alongside.
2. No NAP, but EUCARIS retrieval
The manufacturer files through another country's NAP (RDW in the Netherlands, say), and the destination country pulls the document via EUCARIS.
3. No NAP and no retrieval
A paper CoC is all but certain to be needed; a digital submission carries no legal weight in that country.
There is no common EU-wide go-live date, and — as EUCARIS itself confirmed — no central register of readiness spanning the 27 Member States. Manufacturers therefore have to track each market on its own.
Where each Member State stands (as of 19 May 2026)
| Country | NAP / Status | Notes |
|---|---|---|
| Germany | Ready ahead of 5 July 2026 | Running its own NAP (KBA) rather than the EUCARIS solution |
| Netherlands | In preparation, furthest along | RDW; already taking the IVI 2.0 format |
| Poland | In preparation | Still working through the download-certificate implementation |
| Czech Republic | Own NAP | Not relying on the EUCARIS solution |
| France, Italy, Lithuania, Romania, Finland, Luxembourg | In preparation | At an early stage; many held up by the download-certificate issue |
| Spain | Uncertain | The DGT has yet to confirm its approach |
The headline point: Germany
- • Germany has confirmed it will be ready before 5 July 2026 and is deploying its own NAP through the KBA (not the EUCARIS solution).
- • Anyone placing vehicles on the German market has to be eCoC-ready by 5 July 2026 at the very latest.
- • Germany isn't holding back for EU harmonisation; the digital requirement bites in its registration system whatever the Commission decides about the transitional period.
What it all means in practice for EU manufacturers and distributors
- Selling only in a country whose NAP isn't live yet: the paper CoC stays mandatory until 29 November 2026, and the eCoC turns optional once the local NAP is up and running.
- Selling into Germany: you have to be eCoC-ready from 5 July 2026.
- Selling across several EU markets at once: you'll need both formats running in parallel — paper and eCoC.
- The cross-border model works: you can lodge the eCoC through another country's NAP (RDW in the Netherlands, for instance), as long as the destination country has a retrieval point linked to EUCARIS.
- The signing certificate has to come from a Qualified Trust Service Provider (QTSP) on the EU Trusted List — only those certificates are honoured across every NAP.
What we recommend
- For anyone placing vehicles on the German market, treat 5 July 2026 as a firm operational deadline.
- For the rest of the EU, take 29 November 2026 as the outer limit. The effort of standing up the infrastructure — NAP integration, QTSP certificate, XML pipeline — is the same wherever you are.
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.