A management briefing built on the EUCARIS webinar of 19 May 2026 together with the ruling from the 168th session of the Motor Vehicles Working Group (MVWG).
What is shifting across the EU
The electronic Certificate of Conformity (eCoC), delivered in IVI 2.0 format, supersedes the paper CoC under Article 37 of Regulation (EU) 2018/858. The original compulsory go-live date of 5 July 2026 has now been eased by a European Commission decision taken at the 168th MVWG meeting on 6 May 2026:
- The eCoC (v1.x or 2.0) stays optional up to 29 November 2026.
- Wherever no eCoC is supplied, a paper CoC is still required.
- The Commission has deliberately left each Member State to determine how vehicle registration runs throughout the transitional period.
Legal note
The 29 November 2026 date is not a formal amendment to the legislation; it is a working-group decision captured in the MVWG minutes. In the wording of the Regulation itself, the original 5 July deadline technically remains in force.
Every country sets its own rollout schedule
This is the single most important operational message from the webinar. Sjaak Kempe (EUCARIS) said it 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
For example Germany or the Netherlands. eCoCs are accepted digitally, though national law may still require a paper copy alongside them.
2. No NAP, but EUCARIS retrieval available
The manufacturer files through another country's NAP (RDW in the Netherlands, say), and the destination country then pulls the document down via EUCARIS.
3. Neither a NAP nor retrieval
A paper CoC is almost certainly needed; in that country a digital submission carries no legal weight.
There is no common EU-wide go-live date, and — as EUCARIS itself confirmed — there is no central record of readiness covering the 27 Member States. Manufacturers have to track each market on its own.
Member State status (as of 19 May 2026)
| Country | NAP / Status | Notes |
|---|---|---|
| Germany | Ready ahead of 5 July 2026 | Operating its own NAP (KBA); not adopting the EUCARIS solution |
| Netherlands | In preparation, furthest along | RDW; already taking the IVI 2.0 format |
| Poland | In preparation | Still resolving the download-certificate implementation |
| Czech Republic | Own NAP | Not adopting the EUCARIS solution |
| France, Italy, Lithuania, Romania, Finland, Luxembourg | In preparation | Early days; several held up by the download-certificate problem |
| Spain | Uncertain | DGT has yet to confirm how it will proceed |
The key point: the German market
- • Germany has confirmed it will be ready before 5 July 2026 and is deploying its own NAP through KBA (rather than the EUCARIS solution).
- • Anyone placing vehicles on the German market has to be eCoC-ready by 5 July 2026 at the very latest.
- • Germany is not holding out for EU harmonisation; the digital requirement applies within its registration system whatever the Commission decided about 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 stays compulsory until 29 November 2026, and the eCoC turns optional once the local NAP goes operational.
- Selling into Germany: you have to be eCoC-ready from 5 July 2026.
- Selling into several EU markets simultaneously: you will need both formats running in parallel — paper and eCoC.
- The cross-border route works: you may file the eCoC through another country's NAP (such as RDW in the Netherlands), as long as the destination country runs a retrieval point linked to EUCARIS.
- The signing certificate must originate from a Qualified Trust Service Provider (QTSP) on the EU Trusted List — only those certificates are recognised across every NAP.
Recommendations
- Regard 5 July 2026 as a firm operational deadline for anyone putting vehicles on the German market.
- Regard 29 November 2026 as the outer limit for the remainder of the EU. The effort to stand up the infrastructure — NAP integration, the QTSP certificate, the XML pipeline — is the same whatever the country.
Sources: 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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