CO2 emissions from car manufacturers 2024: fines up to €95/g and what changes for fleets

Key data

Car and van manufacturers that sold vehicles in the EU during 2024 now know their verdict: Commission Implementing Decision (EU) 2026/1907, published on 5 August 2026 in the EU Official Journal, officially sets the actual average CO2 emission values for each manufacturer and compares them with the individual targets assigned under Regulation (EU) 2019/631. The result determines who pays and how much.

What does this regulation establish?

Commission Implementing Decision (EU) 2026/1907 does not create new obligations: it certifies compliance or non-compliance with existing ones for the 2024 financial year. Each manufacturer has an individual target for average CO2 emissions, calculated based on the average weight of the vehicles it sells. The decision publishes the actual values achieved and contrasts them with those targets.

The penalty mechanism is clear and proportional to sales volume:

• If a manufacturer's actual average emissions exceed its individual target, the excess emission fine is triggered.
• The fine can reach €95 for each gram of CO2/km of excess, multiplied by the total number of vehicles sold in the EU that year.
• Manufacturers can group together in "pools" to average their combined emissions and reduce exposure to penalties.
• The regulation covers both new cars and new light commercial vehicles (vans).

This decision closes the annual regulatory cycle: registration data is collected during the year, verified, and finally certified by the Commission through this implementing decision. It is the document that activates or rules out the economic consequences for each manufacturer.

Economic and operational impact

The economic impact of this decision is measured on two levels: that of manufacturers and that of companies managing fleets.

For manufacturers: a deviation of just 1 g of CO2/km from the target, for a manufacturer selling 500,000 vehicles per year in the EU, represents an exposure of €47.5 million (€95 × 500,000 units). With higher sales volumes and greater deviation, the figure scales linearly. High-volume brands such as Volkswagen, Stellantis, Renault or Toyota are those with the greatest potential exposure.

For companies with fleets in Spain: manufacturer penalties translate into pressure on supply. Manufacturers at risk of fines have incentives to:

• Limit the availability of high-emission combustion models in the European market.
• Apply aggressive discounts on electric vehicles to improve their emission average.
• Prioritise the sale of electric or plug-in hybrid vehicles over high-displacement diesel or petrol vehicles.

For fleet managers, this means that the availability and price of certain combustion models may be affected in the short term, and that the commercial conditions for electric vehicles may improve as a direct result of this regulatory pressure.

Who does it affect?

• New car manufacturers with sales in the EU in 2024 (Volkswagen Group, Stellantis, Renault Group, Toyota, among others).
• New light commercial vehicle manufacturers (vans) with registrations in the EU in 2024.
• Manufacturer groupings ("pools") that have chosen to average emissions jointly.
• Importers and distributors in Spain that depend on the supply of models affected by supply restrictions resulting from penalties.
• Companies with corporate vehicle fleets that plan renovations and must anticipate changes in availability and prices.
• CFOs and purchasing directors who negotiate vehicle rental or leasing contracts for their organisations.
• Tax and mobility advisors who support companies in the transition towards more sustainable fleets.

Practical example

Imagine a reference manufacturer—with a profile similar to that of a major European group such as Stellantis or Volkswagen—that in 2024 sold 800,000 cars in the EU and recorded an average emission of 102 g of CO2/km, when its individual target was 100 g of CO2/km.

The deviation is 2 g of CO2/km. Applying the maximum fine:

• €95 × 2 g × 800,000 vehicles = €152,000,000 of potential exposure to excess emission fines.

This figure explains why major manufacturers have accelerated their electrification strategy and why, in practice, fleet managers in Spain have seen how certain combustion models become more expensive or restricted in availability. Decision 2026/1907 is the document that certifies whether that particular manufacturer has crossed that line in 2024.

What should companies do now?

1. Consult the official decision to identify whether the manufacturers of your fleet vehicles have exceeded or not their CO2 target in 2024. This anticipates whether there will be supply restrictions or incentives for electric vehicles.
2. Review current rental and leasing contracts to assess whether agreed terms may be affected by changes in manufacturers' commercial policy resulting from penalties.
3. Plan fleet renewal with a 2025-2026 horizon incorporating electric or plug-in hybrid vehicles, taking advantage of the discounts that manufacturers apply to improve their emission average.
4. Coordinate with the rental provider or importer to find out which models may have limited availability as a result of restrictions that manufacturers apply to manage their exposure to fines.
5. Inform the CFO or financial management about the indirect impact of this regulation on the total cost of ownership (TCO) of the fleet, especially if operating with high-displacement or diesel vehicles.

Official source

Consult full regulation in 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=OJ:L_202601907