- Draft published
- 19 October 2026
- Feedback deadline
- 16 November 2026
- Planned adoption
- Q4 2026
Consultation launched on 19 October 2026
The European Commission published a draft implementing regulation, reference Ares(2026)9814179, on 19 October 2026. The initiative concerns access to, and use of, certain non-public information in digital battery passports. Feedback is open until 16 November 2026 (midnight Brussels time), with Commission adoption currently planned for the fourth quarter of 2026. The document remains a draft: it has not been adopted and is not yet binding. [1]
Why this matters to battery passport platforms
Article 77 of Regulation (EU) 2023/1542 separates publicly accessible data from information for competent authorities and data for persons with a legitimate interest. Points 2 and 4 of Annex XIII include technical model information and individual-battery data such as state of health, lifecycle status and information resulting from use. The implementing act is intended to specify who may access these restricted fields and on what terms. Final entitlements will depend on the adopted text. [1, 2]
Which stakeholders and what safeguards?
Legitimate-interest uses relate particularly to repair, remanufacture, reuse, repurposing and recycling, and in relevant circumstances to purchasers or those acting on their behalf. Restricted information is not opened to everyone. A DPP provider should therefore prepare an access matrix based on roles, purposes and datasets, with identity verification, access logs and a way to revise permissions following adoption. These are sensible implementation preparations, not a claim that specific draft permissions are already mandatory. [1, 2]
The battery passport deadline remains unchanged
Article 77(1) of Regulation (EU) 2023/1542 sets 18 February 2027 for the passport of each LMT battery (light means of transport, including relevant e-bike batteries), each industrial battery above 2 kWh and each electric vehicle battery placed on the market or put into service. Consultation on data-access rights does not by itself postpone this deadline or turn proposed access rules into existing requirements. [2]
Practical preparation for NexusDPP users
Manufacturers and importers gathering information from non-EU suppliers can distinguish public, authority-only and legitimate-interest information; attach ownership and access classifications to each field; link model-level records with serialised individual batteries; and maintain access audit records and protection of commercially sensitive information. An adaptable permissions layer can help avoid reworking every passport after the final implementing act is published. [1, 2]
Official sources
Checked against official sources on 23 October 2026. The proposal may change: consult the adopted act before treating draft permissions as binding requirements.