opinion parliamentary committee draft, 15 October 2025
On the proposal for a directive of the European Parliament and of the Council on the registration documents for vehicles and vehicle registration data recorded in national vehicle registers
Document IMCO-PA-778121 · (COM(2025)0179 – C100073/2025 – 2025/0096(COD))
Committee on the Internal Market and Consumer Protection · Rapporteur: Klara Dostalova
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Short justification 103 paragraphs
The proposed amendments introduce significant modifications to the Commission's proposal, establishing a more balanced framework between digital transformation objectives and practical implementation realities while reinforcing data protection safeguards and Member State competencies. The amendments extend the implementation period from 4 years to 7 years across all relevant provisions, acknowledging the substantial technical, administrative, and budgetary challenges associated with implementing new digital infrastructure, particularly for Member States with varying levels of administrative capacity and existing legacy systems.
A fundamental revision concerns the approach to mobile registration certificates, transforming the mandatory issuance obligation into an optional framework whereby Member States may issue mobile certificates while physical certificates remain available by default upon applicant request. The issuance of mobile certificates would require explicit consent from the vehicle owner, establishing a consent-based rather than default digital system. Additionally, Member States would be permitted to utilize secure national digital solutions as alternatives to the EU Digital Identity Wallets, recognizing existing national infrastructure investments and interoperability considerations.
Several amendments establish stricter data governance frameworks, introducing a maximum 5-year retention period for information concerning previous holders and owners, with data processing strictly limited to safety and fraud prevention purposes. Personal data accessed for verification purposes would be restricted exclusively to competent authorities, with explicit prohibition on sharing with private entities or processing for commercial purposes. Cross-border access to registration data would be granted only upon justified request from competent authorities, establishing a request-based rather than automatic access regime.
The amendments introduce enhanced Member State operational flexibility through a temporary de-registration mechanism, modeled on existing Dutch practices, permitting vehicle suspension for up to 3 years with subsequent simplified re-registration procedures that do not require new technical inspections. Member States would retain the right to refuse re-registration where reasonable suspicion of fraud exists and may impose additional verification procedures or require new technical inspections in such circumstances, strengthening Member State capacity to combat cross-border vehicle fraud while maintaining proportionate administrative procedures.
Regarding odometer fraud prevention, the amendments limit recording obligations to the last valid periodic technical inspection, eliminating requirements for complete lifetime mileage history maintenance, achieving fraud prevention objectives while avoiding disproportionate administrative burden and data storage requirements. The amendments clarify that microchip functionality on smart card format certificates operates complementarily to QR code functionality, ensuring technological redundancy and verification flexibility, while registration cancellation procedures must be based on clearly defined legal grounds under Union or national law, with advance communication to vehicle owners, reinforcing principles of legal certainty and procedural fairness.
The amendments substantially strengthen parliamentary oversight mechanisms concerning delegated acts by requiring the Commission to present an impact assessment prior to adopting any delegated acts, establishing an evidence-based legislative approach. The delegation period is reduced from 5 years to 2 years, with renewal requiring explicit approval from the European Parliament and Council rather than tacit extension. A sunset clause provides that where delegation is not renewed, existing measures remain in force but no new acts may be adopted without recourse to the ordinary legislative procedure, ensuring appropriate separation between delegated and legislative powers. These amendments establish a framework that balances digital innovation with implementation feasibility, strengthens data protection standards, preserves Member State operational flexibility, and reinforces democratic accountability in the legislative process, responding to stakeholder consultations and reflecting proportionate, evidence-based policymaking that serves both internal market objectives and fundamental rights protection.
AMENDMENT
The Committee on the Internal Market and Consumer Protection submits the following to the Committee on Transport and Tourism, as the committee responsible:
Amendment 1
Proposal for a directive
Recital 6
| Text proposed by the Commission | Amendment |
|---|---|
| (6) To make it easier and faster to check information on physical certificates, Member States should be able to include a QR code on registration certificates, including those in smart card formats. It should also be possible to issue physical registration certificates in smart card format with a microchip, provided that certain technical specifications are followed. | (6) To make it easier and faster to check information on physical certificates, Member States should be able to include a QR code on registration certificates, including those in smart card formats. It should also be possible to issue physical registration certificates in smart card format with a microchip, which is complementary to the QR code functionality, provided that certain technical specifications are followed. |
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Or. en
Amendment 2
Proposal for a directive
Recital 7
| Text proposed by the Commission | Amendment |
|---|---|
| (7) The digital transformation is one of the Union’s priorities. It is important to remove the remaining barriers, including the administrative burden associated with the re-registration of vehicles. This can impede the free movement of people, and their right to circulate freely within the Union and to take up residence in a Member State other than the one where their vehicle is currently registered. Therefore, as from [date of entry into force + 4 years], mobile registration certificates should be issued by default without affecting the applicant’s right to also request a physical registration certificate. To ensure interoperability of mobile registration certificates across the Union, technical specifications for those certificates should be set out. This will also make it possible to ensure vehicle registration certificates can be checked and verified. | (7) The digital transformation is one of the Union’s priorities. It is important to remove the remaining barriers, including the administrative burden associated with the re-registration of vehicles. This can impede the free movement of people, and their right to circulate freely within the Union and to take up residence in a Member State other than the one where their vehicle is currently registered. Therefore, as from [date of entry into force + 7 years], mobile registration certificates should be issued by default without affecting the applicant’s right to also request a physical registration certificate. To ensure interoperability of mobile registration certificates across the Union, technical specifications for those certificates should be set out. This will also make it possible to ensure vehicle registration certificates can be checked and verified. |
Or. en
Amendment 3
Proposal for a directive
Article 3 – paragraph 3
| Text proposed by the Commission | Amendment |
|---|---|
| 3. Until [entry into force + 4 years], Member States shall issue physical registration certificates. They may also issue mobile registration certificates in addition to the physical certificates. | 3. Until [entry into force + 4 years], Member States shall issue physical registration certificates. They may also issue mobile registration certificates, subject to the consent of the vehicle owner, in addition to the physical certificates. |
Or. en
Amendment 4
Proposal for a directive
Article 3 – paragraph 4
| Text proposed by the Commission | Amendment |
|---|---|
| 4. With effect from [entry into force + 4 years + 1 day], Member States shall only issue mobile registration certificates. However, upon request of the applicant, Member States shall also issue a physical registration certificate. | 4. With effect from [entry into force + 7 years + 1 day], Member States may issue mobile registration certificates. However, physical registration certificates shall remain available by default upon request of the applicant. |
Or. en
Amendment 5
Proposal for a directive
Article 5 – paragraph 2 – introductory part
| Text proposed by the Commission | Amendment |
|---|---|
| 2. Member States shall ensure that mobile registration certificates are issued free of charge as electronic attestations of attributes to the European Digital Identity Wallets in accordance with Regulation (EU) No 910/2014., The wallets shall provide authorised persons with the possibility to do at least the following: | 2. Member States shall ensure that mobile registration certificates are issued free of charge as electronic attestations of attributes either to the European Digital Identity Wallets in accordance with Regulation (EU) No 910/2014 or to another secure national digital solution recognised by the Member State. |
| The wallets shall provide authorised persons with the possibility to do at least the following: |
Or. en
Amendment 6
Proposal for a directive
Article 6 – paragraph 1 – subparagraph 2 – point d
| Text proposed by the Commission | Amendment |
|---|---|
| (d) information on the previous holder and, where available, the previous owner of the vehicle; | (d) information on the previous holder and, where available, the previous owner of the vehicle, limited to data necessary for safety or fraud prevention purposes and retained for a maximum period of five years; |
Or. en
Amendment 7
Proposal for a directive
Article 6 – paragraph 1 – subparagraph 2 – point e
| Text proposed by the Commission | Amendment |
|---|---|
| (e) information on any change to the ownership of vehicles, including vehicles which are not authorised to be used in road traffic due to suspension in accordance with Article 8, or due to the temporary de-registration of the vehicle; | (e) information on any change to the ownership of vehicles, including vehicles which are not authorised to be used in road traffic due to suspension in accordance with Article 8, or due to the temporary de-registration of the vehicle; limited to data necessary for safety or fraud prevention purposes and retained for a maximum period of five years. |
Or. en
Amendment 8
Proposal for a directive
Article 6 – paragraph 1 – subparagraph 2 – point g – point vii
| Text proposed by the Commission | Amendment |
|---|---|
| (vii) has been subject to cancellation of its registration for any other reasons. | (vii) has been subject to cancellation of its registration for reasons laid down in Union or national law and communicated in advance to the vehicle owner. |
Or. en
Amendment 9
Proposal for a directive
Article 6 – paragraph 1 – subparagraph 3 a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| For the purposes of odometer fraud prevention, Member States shall record odometer readings from the last valid periodic technical inspection; Member States shall not be required to maintain or record the vehicle's complete lifetime kilometre history. |
Or. en
Amendment 10
Proposal for a directive
Article 7 – paragraph 1
| Text proposed by the Commission | Amendment |
|---|---|
| Member States shall ensure that the personal data necessary for the verification of the information reported on the physical registration certificate or mobile registration certificate are not retained by the verifier, unless retention is authorised by Union or national law. They shall also ensure that the issuing authority of the registration certificate is not notified about the verification process of physical vehicle registration certificates, and that it processes the information received through the notification only for the purpose of responding to the verification request for mobile vehicle registration certificates. | Member States shall ensure that the personal data necessary for the verification of the information reported on the physical registration certificate or mobile registration certificate are not retained by the verifier, unless retention is authorised by Union or national law. They shall also ensure that the issuing authority of the registration certificate is not notified about the verification process of physical vehicle registration certificates, and that it processes the information received through the notification only for the purpose of responding to the verification request for mobile vehicle registration certificates. Only competent authorities may access personal data for verification. Personal data accessed for verification shall not be shared with private entities or processed for commercial purposes. |
Or. en
Amendment 11
Proposal for a directive
Article 10 – paragraph 1
| Text proposed by the Commission | Amendment |
|---|---|
| 1. Until [date of entry into force + 4 years], Member States may require that the driver carry Part I of the physical registration certificate to identify a vehicle in road traffic. After that date, Member States shall accept both physical and mobile registration certificates for that purpose. | 1. Until [date of entry into force + 7 years], Member States may require that the driver carry Part I of the physical registration certificate to identify a vehicle in road traffic. After that date, Member States shall accept both physical and mobile registration certificates for that purpose. |
Or. en
Amendment 12
Proposal for a directive
Article 10 – paragraph 2
| Text proposed by the Commission | Amendment |
|---|---|
| 2. Until [date of entry into force + 4 years] the competent authorities shall require the submission of only Part I of the physical registration certificate when re-registering a vehicle previously registered in another Member State. Until that date, they may also accept the presentation of a mobile registration certificate, if any. | 2. Until [date of entry into force + 7 years] the competent authorities shall require the submission of only Part I of the physical registration certificate when re-registering a vehicle previously registered in another Member State. Until that date, they may also accept the presentation of a mobile registration certificate, if any. |
Or. en
Amendment 13
Proposal for a directive
Article 10 – paragraph 3
| Text proposed by the Commission | Amendment |
|---|---|
| 3. From [entry into force + 4 years +1 day], Member States shall accept both Part I of the physical registration certificate and the presentation of the mobile registration certificate for the purposes of re-registering a vehicle previously registered in another Member State. The re-registering Member State shall verify with the Member State of registration which format(s) of the registration certificates have been issued. | 3. From [entry into force + 7 years +1 day], Member States shall accept both Part I of the physical registration certificate and the presentation of the mobile registration certificate for the purposes of re-registering a vehicle previously registered in another Member State. The re-registering Member State shall verify with the Member State of registration which format(s) of the registration certificates have been issued. To prevent fraud or odometer manipulation, Member States may require an additional verification step prior to recognition. |
Or. en
Amendment 14
Proposal for a directive
Article 10 – paragraph 6 a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| 6a. Member States shall have the right to refuse re-registration where fraud is suspected. In such cases, Member States may require a new technical inspection to be carried out before proceeding with registration. |
Or. en
Amendment 15
Proposal for a directive
Article 10 – paragraph 6 b (new)
| Text proposed by the Commission | Amendment |
|---|---|
| 6b. Member States may provide for temporary de-registration of vehicles. During the period of temporary de-registration, the vehicle shall not be used on public roads and the registration certificate shall be suspended. Re-registration may be completed through a simplified procedure without requiring a new technical inspection, provided the temporary de-registration does not exceed three years. |
Or. en
Amendment 16
Proposal for a directive
Article 12 – paragraph 1 – introductory part
| Text proposed by the Commission | Amendment |
|---|---|
| The Commission shall be empowered to adopt delegated acts in accordance with Article 13 in order to amend: | Prior to the adoption of any delegated acts, the Commission shall present an impact assessment. The Commission shall thereafter be empowered to adopt delegated acts in accordance with Article 13 in order to amend: |
Or. en
Amendment 17
Proposal for a directive
Article 13 – paragraph 2
| Text proposed by the Commission | Amendment |
|---|---|
| 2. The power to adopt delegated acts referred to in Article 12 shall be conferred on the Commission for a period of five years from [date of entry into force]. The Commission shall draw up a report in respect of the delegation of power not later than nine months before the end of the five-year period. The delegation of power shall be tacitly extended for periods of an identical duration, unless the European Parliament or the Council opposes such extension not later than three months before the end of each period. | 2. The power to adopt delegated acts referred to in Article 12 shall be conferred on the Commission for a period of two years from [date of entry into force], renewable only with explicit European Parliament and Council approval. The Commission shall draw up a report in respect of the delegation of power not later than nine months before the end of the five-year period. The delegation of power shall be tacitly extended for periods of an identical duration, unless the European Parliament or the Council opposes such extension not later than three months before the end of each period. |
Or. en
Amendment 18
Proposal for a directive
Article 13 – paragraph 6 a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| 6a. A sunset clause shall apply to the delegation of powers. Where the delegation is not renewed upon expiry, existing measures adopted pursuant to the delegated powers shall remain in force, but no new acts may be adopted under the delegation without recourse to the ordinary legislative procedure. |
Or. en
Amendment 19
Proposal for a directive
Article 15 – paragraph 1 – subparagraph 2
| Text proposed by the Commission | Amendment |
|---|---|
| In particular, Member States shall provide access to relevant registration data [in accordance with Article 6, including the information contained in the latest roadworthiness certificate issued in accordance with Directive 2014/45/EU, suspensions under Article 8, and any available information on restrictions affecting re-registration, stored in national vehicle registers, to the registration authorities in other Member States. | In particular, Member States shall provide access to relevant registration data only upon justified request from another Member State’s competent authority [in accordance with Article 6, including the information contained in the latest roadworthiness certificate issued in accordance with Directive 2014/45/EU, suspensions under Article 8, and any available information on restrictions affecting re-registration, stored in national vehicle registers, to the registration authorities in other Member States. |
Or. en
Annex: declaration of input 4 paragraphs
Pursuant to Article 8 of Annex I to the Rules of Procedure, the rapporteur for opinion declares that he included in his draft opinion input on matters pertaining to the subject of the file that he received, in the preparation of the draft opinion, from the following interest representatives falling within the scope of the Interinstitutional Agreement on a mandatory transparency register, or from the following representatives of public authorities of third countries, including their diplomatic missions and embassies:
| 1. Interest representatives falling within the scope of the Interinstitutional Agreement on a mandatory transparency register |
| Permanent Representation of the Czech Republic to the European Union |
| 2. Representatives of public authorities of third countries, including their diplomatic missions and embassies |
The list above is drawn up under the exclusive responsibility of the rapporteur for opinion.
Where natural persons are identified in the list by their name, by their function or by both, the rapporteur for opinion declares that he has submitted to the natural persons concerned the European Parliament's Data Protection Notice No 484 (https://www.europarl.europa.eu/data-protect/index.do), which sets out the conditions applicable to the processing of their personal data and the rights linked to that processing.