Germany is first to publish a NAP timeline: what it means for the rest of the EU
We track National Access Point (NAP) readiness across the EU (see our readiness tracker), and most countries still speak in generalities: "we are preparing," "work is underway." Germany's Kraftfahrt-Bundesamt (KBA) just gave IVI participants concrete dates and operating rules for its own version 2.0 NAP. It is the first time the eCoC mechanism from Regulation (EU) 2018/858 has been described in operational terms: what switches off, what switches on, and in what order.
Why Germany is the best test case for the rest of the EU
Germany built its own National Access Point instead of waiting on the shared EUCARIS build, which let it publish a concrete plan earlier than other member states. Its timeline is currently the best available indicator of how the rules in Regulation (EU) 2018/858 will actually be implemented elsewhere, even though the specific national dates will differ.
Three mechanisms in Germany's timeline that will reach every market
EUCARIS forwarding
From 5 November 2026, German registration authorities can query IVI-CoC 2.0 records, and the EUCARIS network starts forwarding those same records to other member states. That is the same cross-border mechanism meant to handle a vehicle bought in one EU country and registered in another.
The end of deletion, the start of corrections
Records reach other countries over EUCARIS before they are even stored locally, which is why KBA will no longer be able to delete them from version 2.x onward. The only way to fix a mistake is a separate correction record. It is hard to see other NAPs carving out an exception to the same data architecture.
A forced submission order
National data may only be sent after the IVI-CoC record has been transmitted, and KBA recommends waiting a full day. This is a sequencing requirement, not a parallel one, so systems built to send both datasets at once will need fixing regardless of the target country.
What this means if you sell into several EU markets at once
- Do not design your eCoC process around a single market. The mechanisms KBA revealed come from the regulation, not from anything German-specific, so they will surface wherever a NAP is still being built.
- Validate your signing certificate against the EU's DSS tool now, regardless of which market you sell into first.
- Build a fixed gap between sending the eCoC and sending national data into your process, so the same logic works in every market without manual exceptions.
- Treat every mistake as a candidate for correction rather than deletion and resubmission, before your local NAP forces the point.
One logic, every EU market
CoCDesk uses one submission, sequencing and correction logic regardless of whether a document goes to the NAP in Germany, Poland or any other EU country, so a company selling into several markets does not need to maintain separate logic per country.
Source: Kraftfahrt-Bundesamt (KBA), Abteilung Typgenehmigung, notice to IVI process participants, September 2026.
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