COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT Accompanying the documents Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers, and amending Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union 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, and repealing Council Directive 1999/37/EC
Date: 2025-05-26
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: data recording, exchange of information, information system, road safety, road transport, roadworthiness tests, technical regulations, vehicle, vehicle documents, vehicle registration

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   EUROPEAN COMMISSION  Brussels, 26.5.2025  SWD(2025) 97 final/2  CORRIGENDUM This document replaces SWD(2025) 97 final of 24.4.2025 Insertion of the cross-reference to the COM(2025) 180 final and correction of the title Concerns the English language version only  The text shall read as follows: COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT    Accompanying the documents Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/45/EU on periodic roadworthiness tests for motor vehicles and their trailers, and amending Directive 2014/47/EU on the technical roadside inspection of the roadworthiness of commercial vehicles circulating in the Union   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, and repealing Council Directive 1999/37/EC    {COM(2025) 179 final} - {COM(2025) 180 final} - {SEC(2025) 119 final} - {SWD(2025) 96 final} - {SWD(2025) 98 final} - {SWD(2025) 99 final}  
 
 
A. Need for action  

What is the problem and why is it a problem at EU level?  

This  initiative  seeks  to  evaluate  and  further  improve  the  impact  on  road  safety  and 
environmental performance of vehicles of the three Directives of the Roadworthiness Package 
(RWP). Despite existing EU legislation, as well as improvements in vehicle technology, including 
active safety and intelligent driver assistance systems in new vehicles, unsafe vehicles are still present 
on EU roads, contributing to crashes, either as the main cause or as a contributing factor. Some unsafe 
vehicles  are  identified  at  periodical  technical  inspection  (PTI)  or  roadside  inspection  (RSI),  i.e. 
vehicles with major or dangerous deficiencies. Others may not be detected at either because PTI or 
RSI cannot detect them or because they are not subject to testing. These include vehicles with safety-
related tampering and vehicles with incorrectly secured cargo.  

The second problem is insufficient control of air pollutant and noise emissions from vehicles. Some 
of the tests used in today’s PTIs are no longer sufficiently sensitive to detect emission failures and the 
current testing procedures are not fit to meet the EU policy goals as regards air pollution and noise. 
The measurement of nitrogen oxide emissions (NOx) or particle number (PN) values for new cars are 
still not covered by the current RWP and there are currently no EU provisions for testing vehicles for 
manipulation/defect  of  NOx  reduction  systems  or  of  diesel  particulate  filters.  Given  these 
shortcomings, the RWP’s contribution to reducing the number of high-emitting vehicles has become 
less relevant. Moreover, the Directives are not effective in enforcing rules in EU cross-border 
traffic and trade of vehicles. 

The RWP Directives were subject to an ex-post evaluation performed ‘back-to-back’ with the impact 
assessment. The evaluation concluded that the RWP was only partially successful in achieving its 
objectives of contributing to increased road safety and helping reducing air pollutant emissions from 
road transport. Defective vehicles may still not always be detected, as some categories of vehicles are 
not subject to PTI or RSI in some Member States, or the frequency or scope of the testing is not 
adapted to their higher safety and environmental risk. The identified weaknesses in the current RWP 
require the Directives to be adapted, to address not only current needs but also future challenges, such 
as the testing of advanced driver assistance and automated systems.  

Road transport, especially freight, is an international sector, with vehicle approval and inspection 
regulated at the EU and international (UNECE) level. Therefore, it has by nature a strong cross-border 
dimension.  The identified problems  apply  across the  entire Union and  have  the same underlying 
causes.  

What should be achieved?  

In line with the European Green  Deal and  the  Sustainable and Smart  Mobility Strategy, the 
initiative will contribute to improving road safety in the EU, sustainable mobility, and facilitating the 
free movement of persons and goods in the EU. To this end, the specific objectives of the initiative 
are to: (1) ensure the consistency, objectivity, and quality of roadworthiness testing of today’s 
and tomorrow’s vehicles; (2) significantly reduce tampering and improve the detection of vehicles 
with  deficiencies,  to  allow  for  the  detection  of  defective/tampered  safety  and  emission  (i.e.  air 
pollution  and  noise  emission)  control  systems,  as  well  as  of  odometer  fraud;  and  (3)  improve 
electronic  storage  and  exchange  of  specific  vehicle  data,  therefore  addressing  the  problem  of 
insufficient availability of such data and mutual recognition by enforcing authorities.  

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What is the value added of action at the EU level (subsidiarity)?  

Since road transport  and the  automotive industry operate  cross-border in the internal  market  and 
internationally, it is much more efficient and effective to address the issues at the EU level than at the 
level  of  Member  States.  While  national  practices  differ  historically,  a  certain  minimum  level  of 
harmonisation in vehicle testing and commonly agreed solutions to exchange vehicle data between 
Member States is more effective than multiple uncoordinated national solutions. With common rules 
applied to testing modern vehicle technologies (electric vehicles -EVs-, advanced driver assistance 
systems  -ADAS-,  and  the  most  recent  emission  control  equipment),  Member  States  will  realise 
economies of scale and testing equipment manufacturers can operate in a more homogenous market.  

B. Solutions  

What are the various options to achieve the objectives? Is there a preferred option or not? If 
not, why?  

Four policy options (PO1a, PO1b, PO2, PO3) have been designed to address the problems. All 
policy options adapt PTI to EVs and include new test items through the ePTI (including the testing 
of software integrity of safety- and emission-relevant systems). They also include new emission test 
methods for both particles and NOx necessary to adapt to more recent emission control technologies 
and to capture high emitting vehicles, including tampered ones. A roadworthiness test following any 
significant modification involving e.g., the change of the propulsion system or the emission class is 
also required in all policy options, as well as digitalisation of the roadworthiness certificate, linking 
national vehicle registers and extending the set of harmonised vehicle data in those registers.  All 
policy options also introduce a requirement for Member States to record odometer readings in national 
databases and make those records available to other Member States in the case of re-registration. 

In addition to the common measures, PO1a is focusing on a more efficient use of vehicle (registration 
and status) data, including issuing registration certificates in digital format. PO1b focuses on more 
effective technical inspections using remote sensing technology, which allows the identification of 
potentially  high-emitting  vehicles  that  can  be  either  (i)  inspected  at  a  subsequent  roadside  check 
immediately after being identified or (ii) invited to a roadworthiness centre for an emission test. It 
would also remove the possibility to exempt motorcycles from PTI, require yearly emission testing 
of  light  commercial  vehicles  and  make  the  inspection  of  cargo  securing  mandatory.  PO1b  also 
introduces mandatory annual PTIs for vehicles that are 10 years or older. PO1b would facilitate the 
free  movement  of  people,  by  requiring  that  the  Member  State  of  registration  recognises  the  PTI 
certificate issued by another Member State for a period of up to six months, provided that the next 
PTI is conducted in the Member State of registration.  

PO2 combines most of the measures of PO1a and PO1b. It includes an additional measure on data 
governance, aiming to define the procedures and the means of access to vehicle technical information 
(including in-vehicle data). It would also introduce roadside inspections for light commercial vehicles. 
PO3  is  the  most  ambitious  policy  option,  as  it  goes  even  further  on  harmonising  the  scope  and 
methods of roadworthiness testing and the mutual recognition of PTI certificates. To the measures 
included  in  PO2,  PO3  adds  further  extension  of  scope  of  PTI  to  cover  all  motorcycles  without 
exception and light trailers, and it extends RSI to motorcycles. It also includes a requirement that PTI 
certificates issued in any other EU Member States are recognised by the Member State of registration 
without limitations. 

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PO2 is the preferred option, given it is considered effective in reaching the policy objectives, it 
presents  high  effciency  and  net  benefits  and  it  is  coherent  with  the  well-established national 
policies in the field. 

What are different stakeholders’ views? Who supports which option?  

The preferred policy option enjoys the support of the PTI industry (CITA, FSD and others) as well as 
consumers (FIA), testing equipment (EGEA) and motorcycle manufacturers (ACEM). It is supported 
also by some Member States, notably those that rely on thousands of smaller roadworthiness testing 
centres. Regarding access and exchange of information, various respondents (including CITA, 
EGEA and EReg), underlined the importance of free and easy access to in-vehicle data to enable 
the proper inspection of vehicles. Stricter cargo securing requirements included in this option are 
strongly supported by the logistics industry.  

 C. Impacts of the preferred options  

What are the benefits of the preferred option (if any, otherwise main ones)?  

PO2 will contribute to increasing road safety in the EU, with the impact estimated at 6,912 lives 
saved and 64,885 serious injuries avoided over the 2026-2050 period, relative to the baseline. 
It  will also  contribute to sustainable mobility by reducing  air pollutant and noise emissions, 
which will lead to external costs savings, estimated at EUR 83.4 billion (expressed as present 
value over the 2026-2050 period relative to the baseline). It will contribute to facilitating the 
free movement of persons and goods in the EU through removal of obstacles to re-registration 
of vehicles in another Member State and (limited) EU-wide recognition of PTI certificates.  

PO2 is expected to bring significant benefits through introducing test methods for the inspection of 
electric vehicles, improved emission testing (NOx and PN measurement), and the introduction of 
testing methods for ADAS and other safety systems. The annual testing of vehicles older than 10 
years will not only bring large safety and environmental benefits, but it will create thousands of new 
jobs, especially in Member States where jobs are being lost in the automotive industry. Benefits are 
also  expected  due  to  the  introduction  of  mandatory  cargo  securing  inspections  and  the  data 
governance measures. New ways of testing, such as plume chasing and remote sensing to screen the 
pollutant and noise emissions of large numbers of vehicles, will make the detection of high-emitting 
vehicles significantly more efficient. 

PO2 is expected to improve detection and thus lead to fewer defective and tampered vehicles, also 
through the extension of the RSI to light commercial vehicles. It is expected to lead to a significant 
reduction in odometer tampering due to an obligation to record odometer readings and to make the 
records available in the case of re-registration. It should also bring benefits due to the mandatory 
electronic roadworthiness certificate, the introduction of the vehicle registration document in digital 
format, access to PTI reports in national databases and the extension of relevant vehicle data included 
in the national vehicle registers. Total benefits in preferred policy option are estimated at EUR 391.6 
billion, expressed as present value over 2026-2050 relative to the baseline.  

What are the costs of the preferred option (if any, otherwise main ones)?  

Total costs of the preferred policy option (PO2) are projected to be EUR 65.9 billion, expressed as 
present  value  over  2026-2050  relative  to  the  baseline.  Of  these,  the  largest  share  of  costs  are 
administrative costs for other businesses (i.e. vehicle owners) linked to additional periodic technical 

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inspections and cooperating on roadside inspections with the public authorities (representing around 
39% of the total costs in PO2), followed by adjustment costs for PTI centres (for equipment, training, 
and additional inspectors to perform the inspections), representing around 35% of the total costs in 
PO2. Administrative costs for national public administrations mainly relate to the setup of the database 
for odometer readings and the operation of the system (3.6% of the total costs in PO2). Administrative 
costs for citizens, on the other hand, are estimated at 21% of the total costs in the preferred policy 
option and are driven by the mandatory yearly testing of vehicles older than 10 years, the introduction 
of roadside inspections for motorcycles, and the additional emission tests for vehicles that are found 
to be  high emitters. Other costs represent a relatively small share of the total costs.  

What are the impacts on SMEs and competitiveness?  

There will be additional costs for SME inspection centres due to adaptation to electric and hybrid 
vehicles, inclusion of ePTI to check compliance with General Safety Regulation, mandatory PN and 
NOx testing, additional emission tests for light commercial vehicles and motorcycle noise testing. 
These additional costs relate to training for inspectors and the acquisition of necessary equipment. 
However, additonal equipment costs mean additional revenues for garage equipment manufacturers, 
many of whom are also SMEs. At the same time, PTI operators will be able to recover any increase 
in costs through the PTI fees, thereby maintaining their profit levels while also gaining new revenue 
sources. It will be primarily SMEs that will benefit from the 19,000 to 20,000new jobs to be created 
thanks to more frequent and more sophistcated testing. While large PTI operators may be able to 
benefit  more  than  smaller  ones,  all  of  them  should  in  principle  gain.  Finally,  a  more  effective 
enforcement  of  the  roadworthiness  framework  will  ensure  fairer  competition,  reducing  the 
opportunities for gaining price advantage on the basis of lower vehicle standards, and avoidance of 
the required maintenance of vehicles. 

Will there be significant impacts on national budgets and administrations?  

The preferred policy option is expected to lead to one-off and recurrent administrative costs for 
the  Member  States  authorities,  estimated  at EUR 2.39 billion, expressed as present value over 
2026-2050. These costs will be driven by the measure addressing odometer fraud, where a system 
for the recording of odometer readings of vehicles at garages and other repair stations will have to be 
developed. Expressed as present value over 2026-2050, total one-off and recurrent administrative 
costs due to this measure are estimated at EUR 2.12 billion. In addition, the roadside testing of vans 
will generate recurrent administrative costs (i.e. labour costs for the additional inspections), estimated 
at EUR 107.5 million expressed as present value over 2026-2050 relative to the baseline.  

Total adjustment costs for the preferred policy option are estimated at EUR 207.2 million, expressed 
as present value over 2026-2050 relative to the baseline, of which EUR 29.7 million are one-off costs. 
The most significant additional adjustment costs for authorities arise due to the introduction of remote 
sensing, and the option to use plume chasing to measure NOx emissions from trucks, as well as the 
installation of noise cameras. This involves one-off costs for the purchase of the necessary equipment, 
the setting up of the corresponding IT infrastructure and related training of inspectors, as well as 
recurrent costs for the maintenance of the equipment and data management, and labour costs for the 
inspectors performing the plume chasing. The total adjustment costs due to this measure over 2026-
2050 are estimated at EUR 192.9 million, expressed as present value relative to the baseline. 

The initiative is also expected to bring cost savings for national administrations, which arise from the 
introduction of the roadworthiness certificate in electronic format, the interlinking of national vehicle 
registers and from issuing digital registration certificates. The savings are expected to be significant, 
reaching EUR 5.23 billion, expressed as present value over the period 2026-2050. 

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Proportionality 

The preferred policy option is considered proportionate to what is necessary to reach the overall 
policy objectives. The scope of the option is limited to what can best be achieved at the EU level (in 
terms of harmonisation of methods and scope of testing, as well as in finding common solutions to 
ensure efficient sharing and access to the necessary vehicle data). Although some of the measures are 
associated with significant costs, the benefits largely outweigh the costs. 

D. Follow up 

When will the policy be reviewed?  

Five years after the revised legislation will have been applied, the Commission shall carry out an 
evaluation of the RWP to verify to what extent the objectives of the initiative have been reached and 
provide its main findings on implementation in the report to the Council and the European Parliament. 
The report shall, where necessary, be accompanied by appropriate recommendations. 

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