New CO2 data obligations for heavy-duty vehicle manufacturers: what changes in 2026

Key data

Truck, bus and trailer manufacturers operating in the European Union have a new reporting obligation from 10 September 2026. The Delegated Regulation (EU) 2026/1282 amends Annexes IV and V of Regulation (EU) 2019/1242, which sets CO2 emission standards for new heavy-duty vehicles, expanding the catalogue of data that must be tracked, reported and published.

This is not a change in emission limits, but in the data architecture that underpins their control: what is measured, what is reported, what is published and what is protected. For compliance departments and technical teams at manufacturers, this means reviewing existing information flows before the entry into force date.

What does this regulation establish?

The regulation acts on two technical annexes of Regulation (EU) 2019/1242 and produces four specific types of changes:

Additionally, the regulation corrects material errors detected in Annexes IV and V of the base regulation, which may affect the interpretation of previous obligations.

The context is relevant: Regulation (EU) 2019/1242 already required manufacturers and Member States to report CO2 emissions data for heavy-duty vehicles. This amendment expands the scope to new vehicle and trailer groups that were not previously included, and updates technical parameters to reflect technological changes introduced by regulations approved after 2019.

Economic and operational impact

The direct impact of this regulation is operational and compliance-related, not financial in terms of fees or fines (the regulation does not establish its own penalties). However, failure to comply with the reporting obligations of Regulation (EU) 2019/1242 may result in regulatory consequences under that base regulation.

The main operational impacts for manufacturers are:

• Review of data collection systems: The new component parameters and category M identifiers require updating internal technical data management systems.
• Adaptation of communication flows with national authorities: Component data for in-service verification require coordination with national registers.
• Expansion of reporting scope: Manufacturers producing new vehicle or trailer groups now included in the regulation's scope must join the tracking system for the first time.
• Management of sensitive data: Protection of commercially sensitive data in the central register requires correctly identifying and classifying which data should not be published.

For national registration authorities, the regulation also expands their reporting obligations, which may require adaptations to registration information systems.

Who does it affect?

• New heavy-duty vehicle manufacturers (trucks, tractors, construction vehicles) marketing in the EU
• Completed vehicle manufacturers of category M (buses and coaches), now expressly included in mandatory identifiers
• Trailer manufacturers, incorporated into the scope of the base regulation by the expansion of vehicle groups
• National registration authorities of Member States, responsible for reporting registration data
• Compliance and homologation departments of manufacturing groups with presence in Europe

Practical example

A European bus manufacturer (category M) that until now was not required to report its identifier as a completed vehicle manufacturer will have to incorporate this data into its reports from 10 September 2026.

Furthermore, if that same manufacturer uses specific components (for example, propulsion systems or transmissions) whose data are necessary for in-service verification, it will have to include them in the data report. At the same time, if any of that component data is commercially sensitive (for example, proprietary technical parameters), it must ensure that it is correctly marked to not be published in the EU central register, taking advantage of the protection introduced by this regulation.

The homologation team will need to review Annexes IV and V in their corrected version to verify that existing reporting formats remain valid after the correction of material errors.

What should companies do now?

1. Verify if the reporting scope changes: Check whether the company manufactures category M vehicles or trailers from the new groups incorporated into the scope of Regulation (EU) 2019/1242. If so, reporting obligations apply from 10 September 2026.
2. Review Annexes IV and V in their updated version: Corrected material errors may affect the interpretation of existing obligations. Compare current reporting formats with the amended annexes.
3. Update internal data systems: Incorporate new component parameters and category M manufacturer identifiers into technical data management and homologation systems.
4. Classify commercially sensitive data: Identify which component data are sensitive to ensure they are not published in the central register, applying the protection introduced by the regulation.
5. Coordinate with national registration authorities: If the company operates in multiple EU markets, verify that communication flows with each national authority are aligned with the new requirements.
6. Document the adaptation process: Maintain traceability of changes made to reporting systems to demonstrate compliance in the event of inspection or in-service verification.

Official source

Consult the complete regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026R1282