COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on Clean Corporate Vehicles
Date: 2025-12-16
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: aid to undertakings, carbon neutrality, electric vehicle, greenhouse gas, large business, motor vehicle pollution, pollution control measures, sustainable mobility, technical standard, vehicle fleet

EN 

  EN 

   EUROPEAN COMMISSION  Strasbourg, 16.12.2025  SWD(2025) 1060 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Regulation of the European Parliament and of the Council  on Clean Corporate Vehicles  {COM(2025) 994 final} - {SEC(2025) 994 final} - {SWD(2025) 1061 final}  
 
 
Table of contents 

1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................................. 1 

1.1.  Political Context ........................................................................................................... 1 
1.2.  Legal Context ................................................................................................................ 2 
1.3.  Market Context ............................................................................................................. 4 
Corporate vehicles in the overall EU road vehicles market ................................... 4 
1.3.1. 

1.3.2. 

Market structure and characteristics of corporate fleets ......................................... 4 

2. 

PROBLEM DEFINITION ....................................................................................................... 7 

2.1.  What are the problems? ................................................................................................ 7 
2.2.  What are the problem drivers? .................................................................................... 12 
2.3.  How likely is the problem to persist? ......................................................................... 15 

3.  WHY SHOULD THE EU ACT? ........................................................................................... 15 

3.1.  Legal basis .................................................................................................................. 15 
3.2.  Subsidiarity: Necessity of EU action .......................................................................... 16 
3.3.  Subsidiarity: Added value of EU action ..................................................................... 16 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 16 

4.1.  General objectives ...................................................................................................... 16 
4.2.  Specific objectives ...................................................................................................... 17 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ....................................................... 18 

5.1.  What is the baseline from which options are assessed? .............................................. 18 
5.2.  Description of the policy options ................................................................................ 21 
Possible policy options and preliminary screening of options ............................. 21 
5.2.1. 

5.2.2. 

5.2.3. 

Discarded policy options ...................................................................................... 21 

Retained policy options ........................................................................................ 22 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................. 33 

6.1.  Economic impacts ....................................................................................................... 34 
Impacts on businesses .......................................................................................... 34 
6.1.1. 

6.1.2. 

6.1.3. 

6.1.4. 

6.1.5. 

6.1.6. 

6.1.7. 

6.1.8. 

6.1.9. 

Impacts on citizens ............................................................................................... 43 

Impacts on national public authorities ................................................................. 45 

Impacts on the European Environment Agency ................................................... 47 

Impacts on competitiveness ................................................................................. 47 

Impacts on small and medium enterprises (SMEs) .............................................. 50 

Impact on the functioning of the internal market and competition ...................... 51 

Impacts on innovation and technological development ....................................... 51 

Territorial impacts ................................................................................................ 52 

6.1.10.  Digital by default .................................................................................................. 52 

6.2.  Social impacts ............................................................................................................. 52 
Impacts on health ................................................................................................. 52 
6.2.1. 

6.2.2. 

6.2.3. 

Impacts on employment ....................................................................................... 53 

Impacts on fundamental rights ............................................................................. 53 

6.3.  Environmental impacts ............................................................................................... 53 

I 

 
7.  HOW DO THE OPTIONS COMPARE? .............................................................................. 56 

7.1.  Effectiveness ............................................................................................................... 56 
7.2.  Efficiency .................................................................................................................... 57 
7.3.  Coherence ................................................................................................................... 58 
7.4.  Subsidiarity and proportionality ................................................................................. 59 
7.5.  Sensitivity analysis ..................................................................................................... 60 
7.6.  Assessment of the impacts of EU content requirements ............................................. 61 

8. 

PREFERRED OPTION ......................................................................................................... 63 

8.1. 
Identification of the preferred policy options and stakeholder views ......................... 63 
8.2.  REFIT (simplification and improved efficiency) ....................................................... 64 
8.3.  Application of the ‘one in, one out’ approach ............................................................ 64 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................... 65 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................. 66 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................. 70 

ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................................ 80 

ANNEX 4: ANALYTICAL METHODS ....................................................................................... 92 

ANNEX 5: COMPETITIVENESS CHECK ................................................................................ 158 

ANNEX 6: SME CHECK ............................................................................................................ 163 

ANNEX 7: DISCARDED POLICY OPTIONS ........................................................................... 168 

ANNEX 8: MODULATION OF THE TARGETS FOR CARS AND VANS ............................ 174 

ANNEX 9: MONITORING AND EVALUATION ..................................................................... 179 

INCENTIVES  FOR  ZERO-EMISSION  CORPORATE  VEHICLES  AT 
ANNEX  10: 
NATIONAL LEVEL .................................................................................................................... 181 

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Glossary 

Term or acronym  Meaning or definition 

ACEA 

AFIR 

BEV 

CfE 

CSRD 

CVD 

EAFO 

EEA 

EU ETS2 

GDP 

HDV 

LDV 

OEM 

OPC 

RRP 

SDG 

SMEs 

TCO 

V2G 

ZEV 

European Automobile Manufacturers’ Association 

Alternative Fuels Infrastructure Regulation 

Battery electric vehicle 

Call for Evidence 

Corporate Sustainability Reporting Directive 

Clean Vehicles Directive 

European Alternative Fuels Observatory 

European Environment Agency  

EU Emissions Trading System covering CO2 emissions from fuel 
combustion in buildings, road transport and additional sectors (mainly 
small industry) 

Gross Domestic Product 

Heavy-duty vehicle 

Light-duty vehicle 

Original Equipment Manufacturer 

Open public consultation 

Recovery and Resilience Plan 

Sustainable Development Goal 

Small and medium-sized enterprises 

Total cost of ownership 

Vehicle-to-grid 

Zero-emission vehicle 

III 

 
 
 
 
 
 
1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

This  Impact  Assessment  accompanies  a  new  legislative  proposal  on  clean  corporate  vehicles.  The 
accelerated  uptake  of  zero-emission  vehicles  (ZEVs)  in  corporate  fleets  is  important  for  supporting  the 
decarbonisation  of  the  European  road  transport  sector,  while  safeguarding  the  competitiveness  of  the 
European  automotive industry  and  ensuring  an  overall  fair transition  through  the  accelerated  build-up  of 
second-hand markets for ZEVs. 

1.1.  Political Context 

The automotive sector is a key European industry. In 2024, the sector accounted for roughly EUR 1 trillion 
of GDP, a third of private research and development investment in the EU and it provides direct and indirect 
employment to 13 million Europeans. For commercial vehicles, European lorries makers account for more 
than 40% of the world market1. Road transport is the dominant transport mode in the EU, accounting in 
2023  for  52.6%  of  total  freight  transport  activity  and  81.2%  of  passenger  transport  activity,  while  being 
responsible for 22.6% of EU greenhouse gas emissions2 and 35% of total NOx emissions3.  

At present, the automotive and road transport sectors are undergoing a structural transformation. The shift to 
sustainable  mobility  and  zero-emission  powertrains  is  accelerating,  driven  by  global  competition  and 
regulatory requirements that address the need to reduce emissions from road transport in order to achieve the 
EU’s climate and air quality objectives. The European Green Deal Communication4 and the European 
Climate  Law5  set  out  the  steps  towards  climate-neutrality  by  2050  and  the  need  to  reduce  transport 
greenhouse  gas  emissions  by  90%  by  2050,  relative  to  1990.  The  Sustainable  and  Smart  Mobility 
Strategy6 recognised that this systemic change requires almost all road transport vehicles in the EU to be 
zero-emission by 2050 and announced targeted actions to boost the uptake of ZEVs in corporate and urban 
fleets.  

To help secure global competitiveness of the European automotive sector and maintain a strong European 
production  base,  the  Commission  adopted  on  5  March  2025  the  Industrial  Automotive  Action  Plan7. 
Under  the  overall  umbrella  of  the  Clean  Industrial  Deal,  the  Plan  sets  out  a  strategic  industrial  policy 
framework to help the automotive industry master the transition to sustainable and smart mobility that lies 
ahead. In this context, the Decarbonise Corporate Fleets Communication8 further exemplified the key 
role of corporate vehicles, given their larger market share and significant impact on the second-hand vehicle 
market9, where the majority of Europeans are getting their vehicles from10. It also noted that accelerating the 
uptake of zero-emission vehicles in corporate fleets will not only further reduce transport emissions but can 
also be a tool benefitting the competitiveness of European automotive sector by increasing demand, and it 
concluded that further action is needed The Commission President in the 3rd Strategic Automotive Dialogue 

1 COM(2025) 95 final; Statista Market Insights, January 2025 
2 Statistical pocketbook 2025 - European Commission 
3  Air  pollution  in  Europe:  2024  reporting  status  under  the  National  Emission  reduction  Commitments  Directive  | 
Publications | European Environment Agency (EEA) 
4 Communication on the Green Deal 
5 Regulation (EU) 2021/1119 
6 Sustainable and Smart Mobility Strategy 
7 Industrial Action Plan for the Automotive Sector 
8 Communication: Decarbonise Corporate Fleets 
9 “Corporate vehicle” shall be understood as any vehicle registered by a legal entity, as opposed to “private vehicles” 
that  are  registered  by  a  physical  person.  “Corporate  fleet”  should  be  understood  as  two  or  more  corporate  vehicles 
registered, owned and/or used by the same legal entity.   
10 Joint Research Centre, Zacharof, N., Nur, J., Kourtesis, D., Krause, J. and Fontaras, G. (2025), A review of the used 
car market in the European Union, https://data.europa.eu/doi/10.2760/3237256   

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on 12 September 202511 confirmed the need for action on accelerating uptake of zero-emission vehicles in 
corporate fleets.   

Through  its  potential  to  reduce  emissions,  this  initiative  will  contribute  towards  the  United  Nations 
Sustainable Development Goal (SDG) 13 “Take urgent action to combat climate change and its impacts”. It 
will also indirectly support Sustainable Development Goal (SDG) 3 “Ensure healthy lives and promote well-
being for all at all ages”, target 3.9 (substantially reduce the number of deaths and illnesses from hazardous 
chemicals and air, water and soil pollution and contamination).  

1.2.  Legal Context 

At present, there is no EU-level initiative specifically targeting corporate vehicle fleets. Corporate vehicles 
are, however, affected by other EU legislation, most notably the CO2 emission performance standards for 
vehicles12,  the  Clean  Vehicles  Directive13,  the  EU  Emissions  Trading  Scheme  for  road  transport  (EU 
ETS2)14, Energy Taxation Directive15  and the Eurovignette Directive16. The uptake of ZEV in corporate 
fleets  is  also  supported  through the provisions  on  deployment  of  recharging  and  refuelling infrastructure 
under the Alternative Fuels Infrastructure Regulation17.  

On the supply-side, the CO2  emission performance standards  for  light-duty vehicles  (cars  and  vans)  and 
heavy-duty vehicles define a clear trajectory towards the gradual decarbonisation of new registrations. By 
2035 all new light-duty vehicles must achieve zero tailpipe emissions18, while emissions of new heavy-duty 
vehicles (most  lorries  and certain coaches) must be reduced by 45% in 2030  and by 90% by 204019. In 
addition, for urban buses, 90% of the new registrations must be zero-emission by 2030 and 100% by 203520. 
These  measures  fully  cover  the  supply-side,  ensuring  that  an  increasing  offer  of  ZEVs  becomes 
progressively available across the EU over the next decade.  

Certain aspects of the CO2 emission performance standards for light-duty vehicles are subject to review, in 
parallel with this initiative21. The two initiatives are complementary, as they both aim to support a fair and 
effective  transition  towards  a  decarbonised  road  transport,  addressing  barriers  currently  faced  by  vehicle 
manufacturers while maintaining the broad approach and ambition. The CO2 standards act on the supply-
side  incentivising  vehicle  manufacturers  to  put  on  the  market  zero-emission  vehicles,  while  the  clean 
corporate vehicles initiative aims at ensuring demand for such vehicles especially in those market segments 
where  the  effectiveness  in  reducing  emissions  is  higher.  The  revision  of  the  CO2  standards  introduces 
flexibility to mitigate non-compliance risks while staying the course on the transition. The two initiatives are 
therefore coherent and working towards the same objective, since the clean corporate vehicles initiative will 
provide greater certainty about the level of demand for ZEVs that manufacturers can expect from the market 

11 President von der Leyen chairs third Strategic Dialogue with the European Automotive Industry 
12 Regulation (EU) 2023/851 and Regulation (EU) 2024/1610 
13 Directive (EU) 2009/33/EC  
14 EUR-Lex - 02003L0087-20230605 - EN - EUR-Lex 
15 https://eur-lex.europa.eu/eli/dir/2003/96/oj/eng 
16 Directive - 2022/362 - EN - EUR-Lex 
17 Regulation - 2023/1804 - EN - EUR-Lex 
18 Regulation (EU) 2023/851   
19 Regulation (EU) 2024/1610 
20 While for light-duty vehicles and for urban buses the contribution of each vehicle to meeting the targets is broadly 
similar, the significant difference between different types (‘sub-groups’) of lorries (e.g. between a 7.5 tonnes rigid lorry 
intended  primarily  for  urban  deliveries  and  a  40  tonnes  truck  and  trailer  intended  for  long  haul)  means  that  the 
calculation of their contribution to a manufacturers’ emissions requires the use of payload weighting factors, reflecting 
the respective usage and total emissions. 
21 Revision of the CO2 emission standards for cars and vans 

2 

 
 
segments that are capable of a faster and more efficient transition. Together, the two initiatives will create a 
more favourable legal framework for the competitiveness and sustainability of the EU road transport sector. 

In addition, the EU ETS222 establishes a carbon price signal to incentivise emission reductions, while the 
Eurovignette  Directive23  contributes  by  ensuring  that  road  charging  schemes  reflect  environmental 
externalities. EU ETS2 will cover and address the CO2 emissions from fuel combustion in buildings, road 
transport and additional sectors (mainly small industry not covered by the existing EU ETS). The ETS2 will 
complement sectoral policies, also helping Member States achieve their emission reduction targets under the 
Effort Sharing Regulation (ESR)24. There are synergies between this initiative and the ETS2. On one hand, 
this initiative is expected to drive a higher uptake of zero-emission vehicles relative to the baseline, avoiding 
pressure on the carbon prices. On the other hand, the carbon price set by the ETS2 will provide a market 
incentive for investments in zero-emission mobility. Both co-legislators have introduced a postponement of 
ETS2 by one year, to 2028, in their respective positions on the 2040 climate target proposal, amending the 
European Climate Law. The synergies between the two initiatives remain the same, even if the start of the 
ETS2 is postponed by one year. Even with one year delay for ETS2, Member States remain legally obliged 
to meet their binding 2030 targets under the Effort Sharing Regulation, ensuring that the EU stays on course 
to  climate  neutrality.  In  this  context,  it  should  also  be  noted  that  under  the  Effort  Sharing  Regulation 
Member States are already putting in place measures covering the transport sector. This initiative aims to 
further bolster those efforts. 

Currently,  the  main  demand-side  measure  on  road  transport  vehicles  is  the  Clean  Vehicles  Directive 
(CVD)25. The CVD requires Member States to ensure that clean vehicles26 represent a minimum share of all 
public procurement on their territory over two five-year periods. The Directive applies to all procurement of 
vehicles by a Contracting Authority or Contracting Entity under EU public procurement rules, including 
purchases, lease-purchase, rental or services contracts27, but it does not define the concept of “public fleet”. 
As a result, coverage varies significantly across vehicle types: public procurement accounts for over 70% of 
buses, below 5% of lorries and 1% of light-duty vehicles28. Therefore, while a significant share of urban 
buses  falls  within  the  scope  of  the  CVD,  the  majority  of  light-duty  vehicles  and  lorries  are  outside  its 
coverage.  

The Alternative Fuels Infrastructure Regulation sets binding minimum targets for rollout of recharging and 
refuelling infrastructure to support the required uptake of alternative fuel vehicles across all transport modes 
and in all EU Member States29. 

EU  level  demand-side  measures  to  support  the  transition  to  zero-emission  corporate  vehicles  and  to 
complement the supply-side measures in place, are limited in coverage, and have a strong impact mostly on 
the market segment of urban buses. In addition, the support frameworks at national level for corporate ZEV 
are  fragmented,  as  further  explained  in  section  2.2.  For  this  reason,  this  impact  assessment  focuses  on 
demand-measures focusing on cars, vans and lorries.    

22 ETS2: buildings, road transport and additional sectors - Climate Action 
23 Directive - 2022/362 - EN - EUR-Lex 
24 Effort sharing 2021-2030: targets and flexibilities - Climate Action 
25 Directive (EU) 2009/33/EC   
26  Under  the  CVD,  as  of  2025  “clean  vehicles”  include  zero-emission  light-duty  vehicles  and  heavy-duty  vehicles 
fuelled by alternative fuels. The Directive also includes specific targets for zero-emission buses. 
27 Additionally, because the CVD only regulates public procurement that is already reported in the procurement TED 
Database,  it  was  possible  to  make  use  of  this  existing reporting  framework.  A  similar reporting  framework  does  not 
exist for corporate fleets. 
28 SWD(2017) 366 final, Impact Assessment accompanying the Clean Vehicles Directive revision 
29 Regulation - 2023/1804 - EN - EUR-Lex 

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1.3.  Market Context  

In  2023,  approximately  one  million  companies  were  registered  in the  EU  as  road transport  operators,  of 
which 600,000 companies in haulage and 474,806 companies in passenger transport30. However, corporate 
vehicles  are  used  much  more  broadly,  as  companies  across  different  economic  sectors31  own  or  operate 
them, contributing to a very large and diverse EU road vehicle fleet.    

1.3.1.  Corporate vehicles in the overall EU road vehicles market 

In 2023, there were almost 290 million vehicles on European roads, of which approximately 250 million 
cars, 30 million vans, 0.7 million buses and coaches, and 6 million lorries32. Each year, around 10 million 
new  cars,  1.5  million  new  vans,  30  thousand  new  buses  and  coaches  and  300  thousand  new  lorries  are 
registered in the EU. While around 42% of new car sales on the European vehicle market are to citizens (i.e. 
physical persons who purchase a vehicle in their own name), the rest of the cars, around 90% of the vans, 
and  almost  all buses,  coaches,  and lorries  are  purchased  by  corporate  actors33.  These include  companies  
buying vehicles for their own use, leasing companies and financial institutions buying vehicles to lease them 
to individuals or other companies, as well as rental and taxi companies, which acquire vehicles to provide 
mobility  services.  It  is  important  to  note  that,  due  to  their  shorter  initial  ownership  duration  and  faster 
turnover,  corporate  cars  represent  a  significantly  higher  share  of  new  registrations  than  of  the  stock  of 
vehicles on European roads. The market for trucks is substantially different from that of cars and vans, as 
there are no real privately registered vehicles, but corporate vehicles  represent the almost totality of new 
registrations. 

1.3.2.  Market structure and characteristics of corporate fleets 

While  the  term  “corporate  vehicle”  can  be  used  to  identify  any  vehicle  registered  by  a  legal  entity  (as 
opposed to citizens), this definition includes a broad range of very different vehicles, operators, fleets, and 
business  models.  Corporate  vehicles  can  be  divided  into  a  set  of  broad  categories  based  on  the  type  of 
vehicle  and  activity,  as  presented  in the  Table 1  and  further  explained below.  Understanding  the market 
structure and characteristic of corporate vehicles is essential for assessing the impacts of possible regulatory 
intervention.  

Table 1: Subcategories of vehicles as share in the corporate vehicle new sales in 2024  
Category 

Company car  Manufacturer 

Rental  

Leasing and long-
term rental 

2.7% 
Cars 
Vans34 
49.7% 
Lorries 
84.5% 
Source:  Dataforce  database;  Note:  For  cars  and  vans,  the  data  coverage  for  all  subcategories  is  available  for  11 
Member States (BE, CZ, DK, FR, IT, LV, LT, NL, PL, SK, ES), with for leasing and long-term rental category data is 
not available for 16 Member States, including the biggest automotive market (DE).  

41.4% 
32.0% 
5.1% 

15.5% 
7.3% 
4.8% 

20.7% 

self-registrations 
19.7% 
10.9% 
5.6% 

True Fleets 
(other) 

Leasing fleets. Leasing companies own large fleets of vehicles that they lease to other companies (large as 
well as SMEs) and/or to citizens. This category presents significant overlaps with some of the others, as for 

30 Source: Eurostat. Enterprises by detailed NACE Rev. 2 activity and special aggregates [sbs_ovw_act]. 
31 For example, the vans used by service providers such as electricians, plumbers, or gardeners to reach their clients and 
provide their services are also corporate vehicles. 
32 ACEA Report - Vehicles on European roads 2025 
33 Source: Dataforce database. More details on the Dataforce database are provided in Annex 4 (section 1).  
34 For vans the category of “true fleets” is recorded differently across Member States; the figure presented here is the 
aggregate of the relevant categories. 

4 

 
 
 
 
example company cars and vehicles used in true fleets are often procured through leasing35. This includes 
both operating and financial leasing; in both cases, the leased vehicle remains in the ownership of the leasing 
company but in the case of financial leasing the risks and rewards of ownership are transferred to the lessee. 
Financial  leasing  generally  entails  a  purchase  option  for  the  lessee  at  the  end  of  the  contract  period. 
Operating  leasing  is  essentially  a  long-term  rental  agreement  and  often  involves  a  full-service  package 
including maintenance and insurance. For companies, the balance sheet treatment between operating and 
financial leasing can vary, with implications for their tax and credit ratings, depending on the legal and fiscal 
framework in each Member State36.     

Car  leasing  fleets  represent  a  large  share  of  corporate  car  fleets  (more  than  40%  of  new  corporate 
registrations  in  2024),  as  shown  in  the  table  above.  This  means  that  about  2.4  million  new  cars  on  the 
European market are leased to corporate customers every year. This is a consolidated market, dominated by 
a relatively small number of large operators managing the large majority of the market such as multi-brand 
lessors  Ayvens,  Arval,  Alphabet  (BMW)  and  Athlon  (Daimler)  and  the  four  European  manufacturers’ 
captives, Volkswagen Financial Services, RCI Bank and Services (Renault), Free2Move Lease (PSA) and 
Leasys (Fiat). Customers in the leasing sector are split roughly into around two thirds large companies and 
one third SMEs and citizens37. Leasing companies typically resell their cars after 3-5 years38, resulting in a 
relatively fast turnover to the second-hand market. The type of actors involved in the leasing of vans and 
lorries are similar to those of cars, but the market is significantly smaller, both in terms of number of vehicles 
involved and market shares. Citizens represent only a negligible share of van and lorries leasing clients.  

Company cars. These are vehicles provided by an employer to an employee as a benefit-in-kind, which the 
employee  can  drive  for both business  and private purposes.  They typically  have  a  slightly  higher yearly 
mileage than the average, especially when the employer also provides coverage of the fuel costs as a benefit-
in-kind. Company cars are often procured through leasing, so that there can be a significant overlap with 
leasing  fleets  as  described  above39. They  usually  benefit  from  fiscal  incentives  that  are  not  available  to 
vehicles purchased by citizens – this is often a key driver in the choice to provide such a benefit-in-kind as 
opposed to a corresponding increase in salary. These benefits usually apply in a similar way irrespective of 
whether the car is procured by the employer through purchase or leasing.  

Rental fleets. Rental companies rent  cars or other vehicles to other companies or  citizens. The rental of 
different  vehicle  types  (cars,  vans,  etc.)  presents  noticeable  differences.  In  particular,  while  car  rental  is 
mostly  touristic  or  business,  van  rental  primarily  represents  a  logistics  and  mobility  option  for 
companies. The  car  rental  market  is  rather  concentrated  as  90%  of  the  market  (in  car  rental  sales)  is 
estimated to be controlled by five main players: Europcar Mobility Group (with its brands Europcar and 
Goldcar,  29%),  Sixt  SE  (21%),  Avis  Budget  Group  Inc  (17%),  The  Hertz  Corp  (13%)  and  Enterprise 
Holding  Inc (10%)40.  A significant  share  of  the  revenue in  the  car  rental industry is  generated  at  airport 

35 This means that a share of the cars in the category “leasing” in the table presented above are used as company cars or 
true fleets, in addition to those already identified as such. 
36  Felix  Kirsch,  Marius  Biedka,  Ben  White,  “Consideration  of  light  duty  vehicle  leasing  in  relation  to  the  cost 
effectiveness of LDV CO2 regulation”, Ricardo Energy & Environment,  Final Report for the European Commission, 
DG Climate Action, 2016 https://climate.ec.europa.eu/system/files/2016-11/ldv_leasing_en.pdf   
37  https://www.arval.com/sites/default/files/inline-files/Arval%20investor%20presentation%20Mars%202025vdef.pdf  
https://www.ayvens.com/-/media/ayvens/public/cp/files/events/annual-shareholders-meetings/assemblee-generale-
2025/2024_ayvens_urd_en_mel_250411.pdf?rev=2bba65cf20c1407f99fa0ba575ddcbc5; targeted consultation. 
38  Targeted  stakeholders’  consultation  –  this  figure  is  representative  of  the  sector  based  on  inputs  provided  by  the 
interviewed leasing companies and their associations.  
39 This means that a share of the cars in the category “leasing” in the table presented above are used as company cars, in 
addition to those already identified as such. 
40  Euromonitor  (2021)  in  Europcar  (2021)  Universal  registration  document,  as  well  as  UK  Competition  and  Market 
Authority  (2015),  Short-term  car  rental  in  the  European  Union,  in  European  Commission,  Ipsos,  Tetra  Tech,  VVA 

5 

 
 
 
locations. Major rental companies indicate that their share of revenue generated at airport represents more 
than  half  of their total  revenues,  and  that  airport  stations tend  to  have  a  significantly  higher  revenue  per 
vehicle than other locations41.   

Vehicles registered by manufacturers themselves. This includes e.g. showroom and test vehicles. These 
vehicles  reach  the  second-hand  market  very  quickly  (usually  under  a  year  since  first  registration,  with 
comparatively  small  mileage).  Their  market  share  varies  significantly  across  different  Member  States, 
depending among others on the presence and relative size of vehicle manufacturers, going from less than 3% 
in some Member States to almost 30% in others42. 

True fleets. This category includes all vehicles registered by companies and used for their own commercial 
activities. This includes a number of very different types of vehicles, entities, and business cases, including 
for example:  

•  Urban mobility on-demand service car fleets (taxis, ride-hailing, car sharing); these fleets have a strong 
link with local and urban mobility and typically operate on the basis of licences setting conditions for 
their operation. Approximately 370,000 companies operated taxis in 2022, the vast majority of which are 
micro-enterprises43. A significant share of these fleets operates primarily in large cities44.  

•  Service  cars  and  vans:  the  cars  and  vans  used  by  companies  to  transport  equipment  and  provide 
services45. Because service cars and vans are operated by companies whose main activity is not transport, 
there are no precise statistics about the number of companies involved at the EU level. 

•  Logistics fleets: these include the fleets of lorries and vans used to distribute goods. Lorries are almost 
exclusively registered by companies, so that corporate fleets represent the almost totality of the market; 
true fleets represent the vast majority of corporate lorries fleets. Logistics fleets are used for long-haul 
transport and for regional distribution, as well as for last-mile and urban delivery. Large van fleets are 
typically operated by postal services, e-commerce, large retailers, etc. especially for last-mile and urban 
delivery. 600,000 companies operate in the road haulage sector, including both large logistics companies 
operating fleets of tens or hundreds of lorries, and SMEs operating a few or even a single lorry. 87% of 

(2024) Information gathering for assisting the European Commission in complying with its obligations under Article 40 
(“reporting”) of Regulation (EU) 2017/2394 on Consumer Protection Cooperation – Case study on car rental 
41 For instance, for Avis Budget Group Inc, the share of revenue generated at airports as a percentage of total revenue in 
2024 was 67% (Avis Budget Group Annual report 2024). For the Hertz Corporation, the figure in 2024 was 55% (Hertz 
annual  report  2024).  For  Europcar  Mobility  Group,  airport  stations  are  one  of  the  main  sources  of  revenue,  as  such 
stations generally make higher revenue per unit than stations located elsewhere; in total, airport locations account for 
19% of the total number of stations, but for 37% of the revenue (excluding franchises) (Europcar Mobility Group, 2021 
Universal Registration Document). 
42 In some Member States, these vehicles represent a significant share of the market: for example, in Germany their share 
was 29.4% of the total car new registrations in 2024, as in Germany often car companies provide cars to their employees for usage 
and then they are sold to the private market as “Jahreswagen” (annual cars) or “Werkswagen” (factory cars). In other Member 
States, however, in particular those where major vehicle manufacturers have a more limited manufacturing presence, the share of 
vehicle registered by manufacturers themselves is significantly lower: for example, in DK and IE, which have no significant 
local car production, this category represents less than 3% of the total market. 
43 Source: Eurostat. Enterprises by detailed NACE Rev. 2 activity and special aggregates [sbs_ovw_act]. 
44 For example, in 2021 there were  61,500 taxis and 40,000 ride-hailing drivers in France, most of them operating in 
Île-de-France: 80% of ride-hailing trips taking place in France that year were in that region, and Île-de-France had an 
average  of  17  taxis  per  10,000  inhabitants,  compared  to  a  national  average  of  9.  UITP,  Global  taxi  and  ride-hailing 
figures 2024 (https://www.uitp.org/publications/global-taxi-ride-hailing-figures-2024/).  
45  These  include  large  fleets  of  cars  and  vans  operated  e.g.  by  engineering  or  telecom  companies  for  their  repair  works,  by  a 
company’s drivers for the management’s business travels, as well as individual vehicles registered by service providers such  as 
plumbers, furniture vendors, local farmers, sales representatives, or professionals such as lawyers or doctors. In this latter case, the 
distinction between a service car and a company car is often subtle, as the same vehicle might be used both as a service vehicle and a 
private one. 

6 

 
 
companies  operating  in  this  sector  are  micro-enterprises46.  Large  companies  typically  subcontract  a 
significant part of their road haulage activities (more than 80% according to industry representatives) to 
other companies, both large and SMEs. This takes the form of contracts between shipping companies and 
both large and small transport operators; the latter also often sub-contract part of the activity to smaller 
operators, so that it is common to have three or four levels of sub-contracting between the company that 
owns the goods to be transported (the so-called “shipper”) and the enterprise that owns and operates the 
lorries that are actually transporting and delivering those goods47.  

The vehicles in true fleets can either be purchased or leased by the companies that operate them, and in 
many  cases  leasing  is  the  preferred  option,  especially  for  cars  and  vans.  There  is  a  significant  overlap 
between  this  category  and  the  leasing  fleets  described  above,  also  in  the  way  vehicles  are  recorded  in 
statistics on corporate vehicle types48. 

2.  PROBLEM DEFINITION 

The problem, problem drivers and implications that are relevant for this initiative are presented in Figure 1.  

Figure 1: Overview of problem drivers, problems and consequences 

Source: European Commission 

2.1.  What are the problems? 

The problems that this initiative aims to tackle are the low uptake of ZEVs in corporate fleets (cars, vans 
and lorries), and the insufficient availability of affordable ZEVs to ensure a fair transition. Due to their 
high  share  in  new  vehicle  registrations,  and  their  specific  characteristics  in  terms  of  vehicle  operations, 
corporate vehicles have a significant potential to accelerate the uptake of zero-emission vehicles in the EU in 

46 Source: Eurostat. Enterprise statistics by size class and NACE Rev. 2 activity [sbs_sc_ovw]. 
47 During the targeted consultation, the five logistics companies and three haulers’ associations interviewed highlighted 
the significant variety of contracts used for this type of sub-contracting, in terms of the type and duration of the contract 
(with  significant  difference  between  long-term  scheduled  services  covering  several  months  and  spot  market  where  a 
specific  transport  service  is  procured  with  short  notice)  as  well  as  the  inclusion  of  other  specific  conditions  (for 
example whether the haulier is allowed to further sub-contract part of the service). The type and content of the contracts 
used can vary significantly between sectors and type of goods transported, as well as between  long-haul and last mile 
within the same business. In some cases, there is also significant seasonal variability, for example with a  substantially 
higher share of spot contracts in parcel delivery services around festivities.    
48 While exact details vary across Member States depending on how data are collected and analysed, in many cases a 
leased  corporate  vehicle  used  in  a  true  fleet  (e.g.  a  furniture  vendor’s  van,  or  a  taxi)  will  be  recorded  as  part  of  the 
leasing fleet only, potentially leading to an underestimation of the actual size of “true fleets”.  

7 

PROBLEM DRIVERSPROBLEMSIMPLICATIONSUptake of ZEVs in corporate fleets (cars, vans and lorries) is lowRisk of missing decarbonisation targetsFragmented support framework at national level for corporate ZEV (PD1)High purchase costs and operational constraints  of ZEVs compared to conventional vehicles (PD2)Missed opportunities forboosting the competitiveness of the EU automotive industryLackof fairness in the transition to zero-emission transport -leaving vulnerable users behindAvailability of affordable ZEV is insufficientto ensure a fair transition 
 
 
order to increase transport emission reductions, to boost the competitiveness of the European automotive 
industry and to ensure a fair transition (by increasing the uptake of ZEV in the second-hand market).  

A substantial strengthening of demand for ZEVs from corporate fleets is needed to provide greater certainty 
about the level of demand for ZEVs that manufacturers can expect from these market segments, that are 
capable of a faster and more efficient transition. The 2030 targets under the CO2 standards for cars, vans and 
lorries require an accelerated uptake of zero-emission vehicles in the next years. Without further regulatory 
intervention at the EU level that enables clear market direction for the uptake of ZEV in corporate fleets at 
national  level,  the  potential  of  the  corporate  vehicles  to  contribute  to  the  necessary  demand  will  remain 
underexploited. This is because they represent a significant share of new registrations, they display higher 
mileage and faster turnover. However, it should be noted that this is a targeted initiative and other initiatives 
under  preparation,  such  as  the  Industrial  Accelerator  Act,  are  better  placed  for  addressing  the 
competitiveness of the European automotive industry.  

Problem 1: The uptake of zero-emission vehicles in corporate fleets (cars, vans and lorries) is low  

Corporate vehicles represent around 58% of new registrations of cars49, around 90% of new registrations of 
vans50 and virtually all new registrations of lorries51. Despite differences among subcategories (e.g. leasing 
fleets, company cars, and true fleets), the share of zero-emission vehicles in corporate fleets remains low at 
close to 17% of new registrations for cars, 8% for vans and 3.7% for lorries in the first half of 202552.  

In 2024, the share of ZEVs in new registrations by leasing fleets was 16%, somewhat higher than both the 
overall market average (13.6%) and the average in new corporate registrations (14%). Some of the main 
multi-brand lessors report significantly higher ZEVs shares in both fleets and new registrations compared to 
the  market  average53.  In  the  first  half  of  2025  the  share  of  ZEV  in  new  registrations  by  leasing  fleets 
increased to 17.8% (with the overall market average of ZEVs rising to 15.5%)54.  

A large share of company cars and service vehicles, such as taxis, are often leased rather than purchased.  
The  share  of  ZEVs  offered  by  large  leasing  companies  can  therefore significantly impact the  choices of 
other  corporate  fleets  managers.  A  low  share  of  ZEVs  in  the  available  leasing  options  may  represent  a 
bottleneck for the decarbonisation of road transport operations, while a higher share could accelerate uptake 
and adoption of ZEVs across corporate fleets and in the private market, including through faster availability 
of second-hand ZEVs.  

Company cars and true fleets of cars operated directly by firms recorded ZEVs shares in new registrations 
of 17% and 18%, respectively, in 2024, and 24% and 20% respectively in the first half of 202555. While 
above the overall market average, these shares remain insufficient to fully capture the emissions reduction 
potential  of  high-mileage  corporate  vehicles.  Vehicles  in  some  true  fleets  are  responsible  for  a 
disproportionately high share of emissions compared to other use cases, due to their particularly high yearly 
mileage56.  A  faster  shift  to  ZEV  in  those  fleets  could  substantially  reduce  real-world  road  transport 

49 Vehicles of category M1 in accordance with Regulation 2018/858  
50 Vehicles of category N1 in accordance with Regulation 2018/858 
51 Vehicles of category N2 or N3 in accordance with Regulation 2018/858 
52 Source: Dataforce database and European Alternative Fuels Observatory 
53 https://www.arval.com/sites/default/files/inline-files/Arval%20investor%20presentation%20Mars%202025vdef.pdf 
https://www.ayvens.com/-/media/ayvens/public/cp/files/events/annual-shareholders-meetings/assemblee-generale-
2025/2024_ayvens_urd_en_mel_250411.pdf?rev=2bba65cf20c1407f99fa0ba575ddcbc5  
54 Dataforce database 
55 Dataforce database 
56 For example, the associations representing taxi and ride-hailing services that were interviewed as part of the targeted 
stakeholders’ consultation indicated typical yearly mileages of around 80,000-120,000 km among their members, with 

8 

 
 
 
emissions, irrespective of whether the vehicles are leased or purchased.  

Rental  car  fleets  recorded  only  5%  of  ZEVs  in  new  registrations  in  2024,  significantly  below  both  the 
overall market average and the average share of ZEVs in new corporate registrations, and 6.1% in the first 
half  of  202557.  Rental  vehicles  typically  have  comparatively  high  yearly  mileage,  which  increases  their 
potential impact on real-world emissions reductions. Furthermore, among different corporate fleets, short-
term (few days to few weeks) rental cars are usually among the fastest to reach the second-hand market, 
typically  in  less  than  a  year58.  As  a  result,  a  higher  share  of  ZEVs  in  these  fleets  could  accelerate  both 
emission reduction and enhance the affordability of ZEVs for citizens. Vehicles used for short-term rentals, 
such as rental car fleets at airports, other multimodal hubs or tourist areas represent a significant share of the 
car rentals. They can play a pivotal role in increasing the visibility of ZEV solutions, offering an opportunity 
to  experience  zero-emission  technology,  and  addressing  existing  user  concerns  such  as  range  anxiety. 
However, at present, the low share of ZEVs in rental fleets limits the realisation of these benefits, and the 
potential for emission reductions, and improved affordability of ZEVs remains largely untapped. 

Vehicles registered by manufacturers themselves accounted for 12% of ZEVs in new car registrations 
in 2024 slightly below the overall market average, and 18% in the first half of 202559.   

Logistics  fleets  recorded  a  share  of  8.2%  ZEVs  in  new  registrations  of  vans,  and  3.4%  ZEVs  in  new 
registrations of lorries in 2024 (3.7% in the first half of 2025)60. According to ACEA, 73% of road freight 
tonnage is carried over distances of less than 150 km - well within the range of existing ZEVs models - 
while  less  than  2%  gets  carried  over  1,000  km61.  As  a  result,  the  potential  for  emission  reductions  and 
transition to ZEVs remains largely underexploited. 

While only limited published figures are available, and there are significant differences in mileage between 
different types of corporate fleets, interviews with associations representing taxi and ride hailing services, 
consistently indicated typical yearly mileages of around 80,000-120,000 km among their members, while 
leasing  and  rental  companies  also  generally  indicated  significantly  higher  mileage  than  private  vehicles. 
These figures are consistent with available sectoral publications62. A further indirect confirmation comes 
from the usage patterns of vehicles: private cars generally spend more than 90% of the time parked, and less 
than 10% in use63 whereas for example a taxi or a delivery van typically spends at least 8 hours per day in 
use on every working day of the year, resulting in significantly higher yearly mileage. 

Overall, the low share of ZEV in new registrations of corporate vehicles limits the decarbonisation potential 
of  high-mileage  vehicles, slows the diffusion  of  ZEVs in the  second-hand market,  and  results in  missed 
opportunities to improve energy efficiency and reduce costs.  

noticeable variations by country and by area of operation – in particular between major cities, smaller cities, and rural 
areas. 
57 Dataforce database 
58 Based on interviewed rental companies and their associations.    
59 Dataforce database 
60 European Alternative Fuels Observatory 
61 https://www.acea.auto/files/ACEA_trucks_fact_sheet_Feb2025.pdf . 
62 https://www.gtl-taxi.be/6_34_0_0_0_FR_Fonctions_du_taxi https://www.journaldunet.com/mobilites/1494709-la-
constante-evolution-des-vtc-et-des-taxis/ https://www.taxi-point.co.uk/post/what-s-the-annual-average-mileage-for-a-
taxi-driver-and-how-does-it-vary-from-region-to-region 
https://news.belgium.be/sites/default/files/legacy/media/source68983/Rapport_Kilometers_2017_FR.pdf  
63 https://www.racfoundation.org/wp-content/uploads/standing-still-Nagler-June-2021.pdf 
https://www.energy.gov/eere/vehicles/articles/fotw-1356-august-19-2024-household-vehicles-were-parked-95-typical-
day-2022 https://www.transportenvironment.org/articles/driverless-cars-increase-congestion-could-cut-massive-
parking-times  

9 

 
 
The low uptake of ZEVs in corporate fleets is seen as a relevant problem by consulted stakeholders: in the 
2024 open public consultation (OPC), more than half of the 267 respondents64 expressed the view that the 
current share of ZEVs registered by corporate entities is not sufficient to put road transport on the path to 
adequately  contributed  towards  the  climate  neutrality  target  for  2050,  and  between  38%  and  47% 
(depending on the type of vehicle) of respondents who expressed an opinion on whether corporate vehicles 
should switch to ZEVs faster than private vehicles either agreed or strongly agreed with this idea. 

Problem  2:  The  availability  of  affordable  zero-emission  vehicles  is  insufficient  to  ensure  a  fair 
transition  

Affordability here looks at barriers that do not enable a fair transition, which include situations where a ZEV 
alternative is not available for the type of planned vehicle acquisition. This is for example because a suitable 
low-end ZEV model is not yet available on the market (linked to the prevalence of high-end models in the 
first  groups  of  ZEVs  reaching  the  EU  market),  because  ZEVs  are  not  yet  sufficiently  available  on  the 
second-hand  market  (linked  to  the  limited  time  since  their  increased  market  uptake),  or  because  more 
convenient options such as leasing or long-term rental do not yet offer ZEVs for the desired models. In these 
cases, the prospective user is facing an initial higher capital cost for a similar type of vehicle. In order to 
switch from a conventional to a zero-emission vehicle the prospective user would also be required to change 
the planned way of acquiring the vehicle (e.g. buying a higher-end vehicle, buying a new vehicle instead of a 
second-hand  one,  or  buying  a  vehicle  instead  of  leasing  it),  resulting  in  further  additional  costs.  This 
effectively limits the capacity of citizens and SMEs to transition to ZEVs. The limited availability of ZEV 
on  the  second-hand  market  is  particularly  important  in  light  of  the  fact  that  75%  of  the  total  yearly 
registrations of cars are registrations of used cars65. 

Currently, the portfolio of zero-emission car  models is still focused on the  higher end of  the market and 
smaller, more affordable models have started to enter the market only recently66. In the absence of tailored 
financing solutions, the higher purchase cost of new zero-emission vehicles represents a significant barrier to 
their uptake, particularly for SMEs, even in cases where the total cost of ownership (TCO) is competitive67. 
These barriers result in missed opportunities for TCO savings and for competitiveness. The second-hand 
vehicle market is significantly larger than the market for new vehicle registrations in the EU: in the four 
largest vehicle markets (France, Germany, Italy, Spain), new cars represent on average only a third of total 
annual sales68,69. Based on national statistics available for 15 Member States70, 75% of the registrations of 

64 160 out of 267 for cars, 165 for vans, 149 for lorries; Greening corporate fleets 
65 Based on national statistics available for 15 Member States (BE, DK, DE, EL, FR, HR, IT, LU, HU, MT, AT, CY, 
LV, NL and SE ).   
66 EUROSTAT data shows that between 2023 and 2024 the value of extra-EU imports of battery-electric cars into the EU fell by 
around one-third, while plug-in hybrid imports declined only marginally (-6%) and the value of imports of internal combustion 
vehicles increased. More than half of electric car imports are coming from China, but at the same time, trade and market data (JATO 
and Dataforce) indicate that Chinese manufacturers have sharply increased exports and registrations of plug-in hybrids to the EU, 
following the introduction of specific tariffs on battery electric vehicles. Overall, in the first months of 2024, passenger vehicles trade 
balance with China marked a deficit of EUR 1.2 billion, with imports of automotive parts from China increasing by around EUR 4 
billion between 2021 and 2024 (+66%), compared to a decline in exports to China of around 50%. This is due to a 30-35% price 
differential between European and Chinese products (Made  in  Europe  Local  content  policy  for  the  European  automotive 
industry. Gerpisa, April 2025). US manufactured vehicles are very rarely imported into the EU, and they don’t have a big role on 
the market. US companies have set up production facilities in Europe (Ford and Tesla). 
67 As noted by the Association of Automotive Parts Distributors and Producers (SDCM) in the feedback to the Call for 
Evidence: "The high upfront costs of electric vehicles and charging infrastructure impose a significant financial strain 
on SMEs, already grappling with rising logistics costs." 
68 Joint Research Centre, Zacharof, N., Nur, J., Kourtesis, D., Krause, J. and Fontaras, G. (2025), A review of the used 
car market in the European Union, https://data.europa.eu/doi/10.2760/3237256  
69 For example, in Germany, 6,479,953 second-hand car transaction were reported in 2024, against  2,817,331 new cars 
that entered the stock (Source: Kraftfahrt-Bundesamt - English). In the same year, in Italy,  there were 3,096,198 used-

10 

 
 
 
cars are registrations of used cars. Availability of ZEVs on the second-hand markets is therefore crucial to 
accelerate  their  uptake,  especially  in  the  short-term  when  new  ZEVs  remain  more  expensive71;  this  is 
particularly  relevant  for  lower  income  households,  which  are  more  likely  to  purchase  second-hand 
vehicles72. At present, however, the share of ZEVs in the second-hand market remains limited due to their 
relatively recent commercial availability. Consumer organisations note that the current low availability of 
ZEV  on  this  market  hinders  consumers’  capacity  to  benefit  from  potential  savings  offered  by  these 
vehicles73. Moreover, ZEVs currently depreciate faster than conventional vehicles, principally due to rapid 
technological  progress in ZEVs74.  While this trend  improves the  competitiveness75  of  new ZEV models 
compared to conventional ones, it also accelerates the perceived obsolescence of older ZEV models. During 
the Call for Evidence37 (CfE) that was open for feedback between 25 July and 8 September 202576, 24.6% 
(117) of those that responded indicated concerns about uncertain resale values and the early-stage nature of 
second-hand markets for ZEVs, which raises capital costs and leasing rates.  

Cars purchased by citizens typically take longer to reach the second-hand market than corporate cars. Across 
the largest EU car markets, the turnover of second-hand battery electric cars does not significantly differ 
from  the  overall  average  turnover  of  cars77.  Corporate  vehicles  should  therefore  play  a  critical  role  in 
accelerating the availability of second-hand ZEVs, due to their faster turnover. Rental cars are normally re-
sold within one year78 and leased vehicles generally reach the second-hand market within 3-5 years79, either 
as  a  second-hand  sale  or  as  second-hand  leasing.  The  second-hand  market  also  plays  a  key  role  for 
commercial vehicles: while large companies tend to buy new vans and lorries, those vehicles are typically 
re-sold  after  a  few  years,  mostly  to  SMEs.  Thus,  the  share  of  ZEV  in  new  corporate  van  and  lorries 
registrations by large companies is a critical factor in determining the availability of affordable ZEV options 
for SMEs and smaller logistics operators. 

Consumer  associations  have  highlighted  the  significant  economic  benefits  of  second-hand  ZEVs80. 
However, the limited time since most zero-emission models were launched, together with the relatively low 
share of ZEV in corporate fleets with high vehicle turnover, means that the availability on the second-hand 

6, 

to 

of 

the 

car 

new 

2024, 

(source: 

transfers 

passenger 

1,558,704 

ownership 

 compared 

registrations 

car 
https://unrae.it/files/Comunicato_Stampa_UNRAE_mercato_auto_usate_Dicembre_2024_67bc591cedf1a.pdf).. 
70 National statistics for BE, DK, DE, EL, FR, HR, IT, LU, HU, MT, AT, CY, LV, NL, SE.  
71  Gautam,  P.;  Pode,  G.;  Pode,  R.;  Ayetor,  G.K.;  Diouf,  B.  Depreciation  in  the  Electric  Vehicle  Transition: 
Sustainability 
2044–2074. 
Second-Hand  Electric  Vehicle  Market.  Vehicles 
https://www.mdpi.com/2624-8921/6/4/101  
72 Kris Vanherle (TML), Robert Vergeer (CE), “Data gathering and analysis to improve the understanding of 2nd hand 
car  and  LDV  markets  and  implications  for  the  cost  effectiveness  and  social  equity  of  LDV  CO2  regulations”,  Final 
Report  for  DG  CLIMA,  2  May  2016;  Gautam,  P.;  Pode,  G.;  Pode,  R.;  Ayetor,  G.K.;  Diouf,  B.  Depreciation  in  the 
Electric Vehicle Transition: Sustainability of the Second-Hand Electric Vehicle Market. Vehicles 2024, 6, 2044–2074. 
https://www.mdpi.com/2624-8921/6/4/101  
73 https://www.beuc.eu/position-paper/electrifying-company-fleets-lower-mobility-costs-consumers    
74  Gautam,  P.;  Pode,  G.;  Pode,  R.;  Ayetor,  G.K.;  Diouf,  B.  Depreciation  in  the  Electric  Vehicle  Transition: 
Sustainability 
2044–2074. 
Second-Hand  Electric  Vehicle  Market.  Vehicles 
https://www.mdpi.com/2624-8921/6/4/101  
75 Through faster decrease in costs and increased performance. 
76  Clean  corporate  vehicles.  The  Call  for  evidence  was  published  initially  in  English  with  all  the  other  language 
translations published on 11 August 2025. 
77 Joint Research Centre, Zacharof, N., Nur, J., Kourtesis, D., Krause, J. and Fontaras, G. (2025), A review of the used 
car market in the European Union, https://data.europa.eu/doi/10.2760/3237256 
78 Information provided by the rental companies interviewed as part of the targeted stakeholder consultation. 
79  Information  provided  by  interviewed  leasing  companies  and  their  association  in  the  targeted  stakeholders’ 
consultation. 
80 BEUC estimates that new electric cars registered in 2024 will deliver between  EUR 262 and EUR 849 savings  per 
year 
to  an  equivalent  petrol  car.  Source: 
https://www.beuc.eu/position-paper/electrifying-company-fleets-lower-mobility-costs-consumers  

third  owners  compared 

second  and 

future 

2024, 

their 

the 

for 

of 

6, 

11 

 
 
market remains very limited. Regarding key barriers to ZEV uptake, 138 respondents to the CfE (38.7%) 
have identified the low availability of suitable ZEV models for specific use cases. Heavy- and medium-duty 
operators emphasise that current ZEV options for some long-haul and demanding duty cycles remain limited 
or operationally challenging, in particular for specific routes or missions that require carrying heavy loads, 
due to current ZEV range or weight trade-offs81. Some also report model gaps or long delivery times for 
specific configurations.   

The faster turnover of corporate vehicles compared to private ones means that a higher share of ZEVs in this 
segment could accelerate the availability of zero-emission options on the second-hand market82. This would 
increase  access  to  more  affordable  ZEV  options,  including  for  lower-income  and  vulnerable  users.  The 
limited share of ZEVs in corporate fleets - especially for rental cars with particularly quick turnover - results 
in very limited access to ZEVs by lower income and vulnerable users, including both households and SMEs. 
Member States with a heavy reliance on imported second-hand vehicles are particularly impacted by this83.  

Some leasing companies also offer options to lease second-hand ZEVs after the expiry of the first lease, as 
an alternative to selling them, partly as a strategy to manage higher depreciation84. Such offers contribute to 
the  availability  of  affordable  ZEVs  on  the  second-hand  market  and  present  comparable  advantages  to  a 
second-hand purchase in terms of cost.  

Problem 2 is affected by a number of other factors addressed by other initiatives, that are outside the scope. 
However, there are specific aspects that are not sufficiently addressed by other initiatives, such as the current 
very  limited  availability  of  second-hand  ZEVs,  which  has  been  highlighted  among  others  by  consumer 
organisations  and  NGOs,  or  the  very  limited  availability  of  ZEVs  among  leasing  vehicles.  The  current 
market  conditions  therefore  effectively  prevent  citizens  and SMEs,  for  whom buying  a  new  vehicle  can 
represent a significant barrier in terms of cash flow and financial availability, from switching to ZEVs. Other 
relevant initiatives, such as CO2 standards for vehicles, Eurovignette Directive, or ETS2, only have a very 
limited impact on these aspects.   

2.2.  What are the problem drivers? 

Problem driver 1: Fragmented support framework at national level for corporate ZEV  

Problem  driver  1  concerns  the  fragmented  support  framework  at  national  level  for  corporate  ZEV.  This 
fragmentation concerns: 1) the overall level of ambition of national policies for zero-emission vehicles in 
corporate fleets that vastly differ among Member States and 2) the measures in support of their uptake that 
differ as well. This leads to uneven level playing field in the EU internal market, including the fact that 
several  Member  States  do  not  make  use  of  suitable  market  levers  (e.g.  vehicle  taxation,  road  tolling 
exemptions, etc.) or continue with harmful subsidy practices, because there is no clear long-term market 
direction that pushes national and regional authorities to take action. 

In a study examining five Member States it is estimated that those Member States spend more than EUR 40 

81 The electric vehicles either do not have enough battery range or have weight limitations, so using them for  specific 
routes or work schedules that are particularly difficult, e.g. heavy loads, frequent stops, or long hours tasks is difficult. 
82 T&E briefing on corporate fleets 2023 
83 An analysis of intra-EU second-hand vehicles trade is provided in Velten, Eike Karola, Clemens Brauer, and Jan-Erik 
Thie, (2020), ‘Used Vehicle Trade and Fleet Composition in Europe’. European Environment Agency (EEA) within the 
framework 
IS. 
https://www.ecologic.eu/sites/default/files/publication/2021/2632-01-Ecologic-ISI-UsedVehiclesStockTrade-
March2020-final.pdf    
84  Information  provided  by  interviewed  leasing  companies  and  their  association  in  the  targeted  stakeholders’ 
consultation. 

EEA/ACC/18/001/LOT1. 

Fraunhofer 

Ecologic 

Institute 

contract 

service 

and 

12 

 
 
billion annually on subsides or fiscal incentives supporting the company car market (registration tax, annual 
vehicle tax, VAT treatment etc.), most of which benefit conventional vehicles85. Although these measures 
differ  across  Member  States,  certain  types  of  support  are  prevalent  in  nearly  all  Member  States.  These 
subsidies and fiscal support schemes often hinder the transition of corporate fleets to ZEVs, as they continue 
to  favour  the  purchase  and  operation  of  conventional  ones.  The  impact  is  particularly  pronounced  for 
corporate  cars,  which  often  benefit  from  favourable  tax  treatments  and  their  classification  as  an  in-kind 
benefit. 

The  study  mentioned  above  highlighted  that  Member  States  provide  fiscal  incentives  in  the  form  of  tax 
reductions  for  both  the  employer  and  the  employee  when  a  company  car  is  procured  by  the  employer. 
Employees  typically  benefit  from  a  lower  benefit-in-kind  tax  rate,  reduced  social  security  taxes  on  the 
benefit-in-kind, and lower taxation on the benefit-in-kind on fuel for private use covered by the employer. 
Company cars are also often subject to lower ownership and registration taxes. Collectively, these incentives 
still tend to favour conventional vehicles, reducing the financial attractiveness of ZEVs for both employees 
and employers. 

Some Member States have introduced measures to promote the uptake of ZEVs in corporate fleets, and the 
market impact of such incentive measures is pronounced. Still, these remain fragmented and do not provide 
a consistent EU-level framework capable of accelerating the transition to zero-emission corporate vehicles 
across  different  fleet  types.  A  summary  of  the  incentives  for  corporate  ZEV  at  Member  State  level  is 
provided  in  Annex  10.  For  large  fleet  operators  active  across  different Member  States  - such  as  leasing, 
rental or large logistics companies - this fragmentation makes it more cumbersome to strategically plan the 
switch  to  ZEVs  across  the  whole  fleet  and  operation,  which  delays  decarbonisation  efforts.  174  of  the 
respondents  to  the  CfE  (36.6%)  reported  that  existing  tax  rules  and  incentives  are  either  insufficient, 
inconsistent across Member States, or volatile, undermining business cases and long-term fleet planning.  

Respondents  to  the  2024  OPC86  identified  national  taxation  and  fiscal  measures  as  key  incentives  for 
increasing the share of ZEVs in corporate fleets. Specifically, 65% of respondents considered fiscal factors – 
including  vehicle  registration  tax,  yearly  vehicle  tax  and  fiscal  treatment  of  vehicles  –  as  important  in 
determining  the  willingness  of  fleet operators  to include  ZEVs  in  different types  of  fleets.  However,  the 
persistence of tax and other incentives supporting conventional vehicles in corporate fleets combined with 
the  fragmented  support  for  ZEVs  across  Member  States,  mean  that  the  overall  stimulus  for  fleet 
electrification remains insufficient.  

Problem  driver  2:  Current  higher  purchase  costs  and  operational  constraints  of  zero-emission 
vehicles compared to conventional vehicles  

Higher  purchase  cost  as  described  in  problem  driver  2  is  meant  to  depict  the  typical  situation  where 
conventional  and  zero-emission  vehicles  with  the  required  characteristics  are  available,  but  the  zero-
emission vehicles have a significantly higher cost. This higher purchase cost has an impact on the business 
case of corporate vehicles, either directly in terms of total cost of ownership (TCO), or indirectly in terms of 
difficulties to access finance to cover the higher initial capital cost.  

The share of ZEV in new corporate vehicles is limited by a combination of economic costs and operational 
constraints: in order to be competitive with conventional vehicles, ZEVs would in many cases require either 
reduced costs or better enabling conditions reflecting the specific corporate fleets’ operational requirements.  

From  an  economic perspective, the  choice  of  a  commercial  vehicle is  usually primarily guided  by  TCO 

85 Company car fossil fuel subsidies in Europe - T&E 2024  
86 OPC - Greening corporate fleets 

13 

 
 
considerations. ZEVs currently have higher purchase costs and lower operation costs, already resulting in a 
competitive TCO  for some use cases,  but  not yet for others. Even in cases where the TCO of a  ZEV is 
competitive with that of a conventional one, however, the current high initial investment cost can represent a 
significant barrier, especially in the absence of tailored financing solutions. This is particularly the case for 
SMEs, as they are often not considered bankable for obtaining commercial debt solutions for the purchase of 
zero-emission vehicles.  

This issue was highlighted by 344 of the respondents to the CfE (72.3%) who stated that ZEVs still have 
higher  purchase  prices  and  uncertain  total  cost  of  ownership  (e.g.,  residual  values,  financing  terms), 
especially in use cases with specific operational requirements.   

In addition, 259 of those that provided feedback to the CfE (54.4%) indicated that a key barrier to the uptake 
of  ZEV  is  charging  infrastructure  availability,  particularly  where  fleets  require  predictable  turnaround 
times. Some corporate vehicles - in particular some true fleets, such as urban mobility on demand fleets, and 
logistics fleets of vans and lorries - have specific operational requirements in terms of hours of operation, 
mileage, etc. In cases where sufficiently fast and/or dedicated recharging infrastructure is not available for a 
given  fleet  of  corporate  vehicles,  this  may  result  in  an  effective  increase  of  their  operational  costs  by 
lowering their effective utilisation rate, thus reducing their TCO competitiveness compared to conventional 
vehicles87. The deployment of sufficient minimum infrastructure to support the uptake of ZEV in all EU 
Member  States  is  outside  the  scope  of  this  initiative,  and  will  be  ensured  by  the  Alternative  Fuels 
Infrastructure Regulation88; however, the availability of infrastructure for the general vehicle fleet may not in 
itself be sufficient to meet the specific operational needs of some individual corporate fleets, with the result 
that for those fleets the shift to ZEVs implies higher operational costs and will not happen in the absence of 
targeted support measures such as financial incentives balancing those extra costs and improving their TCO 
competitiveness.  

Other operational requirements (e.g. need to access low- and zero-emission zones, road charges exemptions, 
access to specialized lanes and requirements in the concession or licencing procedures) and the way zero-
emission vehicles are treated in that context – including in relation to favourable conditions and incentives 
offered to specific corporate vehicle types – offer opportunities to make zero-emission corporate vehicles 
more attractive and increase their TCO competitiveness. For example, the possibility to operate in a zero-
emission zone might make ZEVs more attractive for a logistics company (e.g. for last-mile urban deliveries). 
An easier access to concessions and licencing in a given urban area could similarly make the choice of a 
ZEV option more attractive for taxi or ride-hailing companies. However, these incentives are often not being 
sufficiently exploited by the relevant local, regional and national authorities, and the lack of a coordinated 
approach further limits their impacts. 

It  should  be  noted  that  operational  constraints  do  not  prevent  the  use  of  ZEVs,  but  they  make  it  less 
economically  viable:  the  ZEV  models  available  on  the  market  allow  all  types  of  activities  currently 

87 For example, the capacity of car rental fleets to switch to ZEVs can be limited by local factors, such as availability of recharging 
infrastructure. The current operation of conventional rental car fleets is dependent on the possibility of providing clients with a full 
tank at the start of the rental: the car is then either returned with a full tank by the previous client or refuelled by the operator in 
between rentals. During high-season for leisure travel or in destinations particularly busy for business travel, vehicles spend limited 
time parked between rentals - rental companies indicate that this is often less than one hour - and an extra fee is usually charged 
when the returned vehicle requires refuelling. Petrol stations are often available in the vicinity of the rental car parking area, allowing 
clients  to  refuel  the  car  shortly  before  returning  it.  When  switching  to  electric  vehicles,  meeting  some  of  these  operational 
requirements will require additional effort in the short term. The current fast turnaround between rentals cannot be ensured with slow 
charging only. In order to avoid significantly longer waiting times between rentals, the use of fast chargers will be required. It is also 
likely that more vehicles would be returned with the battery less than completely full, unless there is sufficient availability of fast 
recharging infrastructure in the vicinity. More vehicles will therefore need to be recharged at the car rental facilities. 
88 Regulation - 2023/1804 - EN - EUR-Lex  

14 

 
 
performed  by  conventional  vehicles,  but  in  some  cases  their  limitations  in  terms  of  range  and  required 
recharging time will result in reduced operation time, and therefore (indirectly) higher operation costs. For 
example, under certain circumstances a zero-emission lorry might need to spend extra time recharging along 
the route or between deliveries, resulting in e.g. the duration of a 9-hour trip increasing to 10 hours, or a 
rental car might need to increase the time between two consecutive rentals from 1 to 1.5 hours, to allow time 
for full recharging. A taxi operated by a driver who does not have access to overnight charging near his 
home might need to rely on public fast charging, with higher electricity prices. These operational constraints 
result in additional operation costs, which together with the higher purchase costs of ZEVs, result in higher 
TCO. 

2.3.  How likely is the problem to persist? 

Problem 1: The uptake of zero-emission vehicles in corporate fleets (cars, vans and lorries) is low. 
This problem is expected to subside over time as manufacturers will need to increase the share of ZEVs in 
order  to  meet  the  emission  reduction  targets  under  the  CO2  emission  performance  standards,  inevitably 
resulting in a higher share of ZEVs also in the corporate market. However, it would still be relevant until 
2035 for cars and vans and at least until 2040 for lorries.  

Problem  2:  The  availability  of  affordable  zero-emission  vehicles  is  insufficient  to  ensure  a  fair 
transition.  In  the  absence  of  EU-level  intervention,  this  problem  is  likely  to  subside  over  time  as 
manufacturers will need to increase the share of ZEVs including in the more affordable segments in order to 
meet the emission reduction targets under the CO2 emission performance standards. However, it would still 
be relevant until at least 2030 for new cars and vans and until 2035 for new lorries. On the second-hand 
market, the problem is likely to persist longer: even as the share of zero-emission vehicles increases and 
more  affordable  models  reach  the  market,  the  time  gap  between  private  vehicles  first  registration  and 
availability on the second-hand market will result in this problem persisting until at least 2036.  

Problem driver 1: Fragmented support framework at national level for corporate ZEV. Without EU 
level  action,  Member  States  are  expected  to  retain  their  current  fiscal  frameworks,  providing  an  overall 
insufficient stimulus for the switch to zero-emission vehicles. On average, they are expected to continue at 
least partially to subsidise fossil fuels use, and market signals promoting zero-emission corporate vehicles 
will remain only partially effective due to their fragmented approach. The share of ZEVs among company 
cars will remain low in several Member States, while the fragmented approach will hinder the full switch to 
ZEVs  by  large  fleet  operators  active  across  different  Member  States,  such  as  leasing  companies,  rental 
companies and large logistics companies. 

Problem  driver  2:  Current  higher  purchase  costs  and  operational  constraints  of  zero-emission 
vehicles compared to conventional vehicles. In the absence of EU-level intervention, the barriers delaying 
the large scale switch to ZEVs in corporate fleets are expected to persist, resulting in a slower uptake of zero-
emission solutions. SMEs in particular will keep facing significant barriers in access to  commercial debt 
finance for the higher capital expenditure of a ZEV, which will not be sufficiently compensated by existing 
operational and fiscal incentives. While over time the purchase cost of ZEVs will decrease and their market 
shares  increase  in  both  corporate  fleets  and  private  registrations,  the  trajectory  will  remain  significantly 
lower  than  would  be  needed  to  fully  exploit  the  emission  reduction  opportunities  offered  by  a  faster 
transition.     

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

The  legal  basis  for  this  initiative  is  Article  91  of  the  Treaty  on  the  Functioning  of  the  European  Union 
(TFEU),  which  enables  the  EU  to  lay  down  common  rules  applicable  to  international  transport  and  to 
improve the functioning of the internal market in the transport sector. Corporate fleets often operate across 

15 

 
borders,  and  the  absence  of  common  requirements  for  the  uptake  of  ZEVs  creates  a  risk  of  fragmented 
national approaches and unequal conditions of competition. EU legislation adopted under Article 91 TFEU 
would  support  the  decarbonisation  of  the  transport  sector  while  ensuring  coherent  internal  market 
functioning for mobility and logistics services. 

3.2.  Subsidiarity: Necessity of EU action 

National  measures  alone  cannot  ensure  a  level playing  field  and  support  a  stronger demand push that  is 
needed  now  to  get  to  the  required  acceleration  of  zero-emission  vehicle  markets  in  the  EU.  Without  an 
overall regulatory push at the EU level that commits all Member States to take measures to support transport 
actors in their transition to zero-emission mobility, national market support and implementation structures 
remain  divergent  and  of  different  ambition,  not  utilising  fully  the  effectiveness  and  efficiency  potentials 
embodied in key market levers such as fiscal incentives and support schemes; this would maintain a non-
predictable policy environment within the internal market that increases information cost for key transport 
actors  and  hinders  cost-effective  implementation  of  zero-emission  fleet  transitions.  Moreover,  diverging 
national action may disadvantage fleets operating across borders and limit the efficient allocation of zero-
emission  vehicles  in  the  internal  market.  These  challenges  cannot  be  effectively  solved  by  individual 
Member States acting alone.  

3.3.  Subsidiarity: Added value of EU action 

EU-level action will ensure market certainty and demand for zero-emission vehicles from corporate fleet 
operators,  helping  companies  operating  in  multiple  Member  States,  thus  creating  a  predictable  demand 
signal for vehicle manufacturers and charging infrastructure providers. It would also support more equitable 
access to zero-emission vehicles across Member States and facilitate more efficient achievement of EU-wide 
climate  targets.  216  respondents  to  the  CfE  (45.4%)  emphasise  that  firm  EU  signals  would  strengthen 
European manufacturing and supply chains, support job creation, and sustain industrial leadership in zero-
emission  technologies. Furthermore,  existing  EU-level  supply-side  measures  (CO2  emission  performance 
standards for road transport vehicles) would be complemented more effectively by demand-side measures 
taken at the same level than by national measures. EU-level action can also ensure a faster impact on the 
market, thanks to clearer and harmonised market signal. This is of crucial importance given the urgent need 
to safeguard the competitiveness of the EU automotive industry and the need to accelerate the uptake of 
zero-emission vehicles in second-hand markets in the EU.  

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

In  view  of  the  problems  identified  in  section  2,  the  general  objective  of  the  initiative  is  to  support  the 
decarbonisation of the EU road transport sector, while safeguarding the competitiveness of the European 
automotive industry and ensuring a fair transition. This is coherent with other EU transport decarbonisation 
policies, contributes towards SDG 13 ‘Take urgent action to combat climate change and its impacts’ and 
indirectly supports Sustainable Development Goal (SDG) 3 ‘Ensure healthy lives and promote well-being 
for  all  at  all  ages’.  A  shift  towards  zero-emission  road  transport  is  essential  to  contribute  towards  the 
economy-wide 55%  greenhouse  gas  emissions  reduction target  for  2030,  the proposed  climate target  for 
204089, and achieve climate-neutrality by 2050, in line with the European Climate Law90. It is also essential 
for the future growth and global competitiveness of the EU automotive sector, as highlighted in the Clean 

89 COM(2025) 524 final 
90 Regulation - 2021/1119 - EN - EUR-Lex 

16 

 
 
Industrial Deal91 and the Industrial Automotive Action Plan92. 

4.2.  Specific objectives 

Each of the three specific objectives of the initiative are designed to address the two problems and the two 
problem drivers described in section 2. They complement each other to help achieve the general objective: 

-  SO1: Stimulate the demand for ZEVs in the corporate segment. This specific objective addresses problem 
drivers 1 and 2. It aims to ensure a consistent framework across the EU for the uptake of corporate ZEV, 
reducing the current fragmentation, while providing certainty and thus promoting the competitiveness of 
the EU automotive industry. It complements the supply-side instruments of the CO₂ standards for light- 
and heavy-duty vehicles and the Alternative Fuels Infrastructure Regulation, which addresses the rollout 
of recharging and refuelling infrastructure in the EU.  

-  SO2: Reduce fossil fuels expenditures in the road transport sector. This specific objective, addressing 
problem drivers 1 and 2, aims to ensures a higher reduction of fossil fuels consumption through a faster 
deployment  of  ZEVs  in  corporate  fleets.  Because  of  their  higher  yearly  mileage  compared  to  private 
vehicles, corporate ZEVs are expected to bring higher fossil fuel savings, contributing to road transport 
decarbonisation  and  competitiveness  thanks  to  the  lower  TCO  of  corporate  ZEVs  compared  to 
conventional corporate vehicles.  

-  SO3: Accelerate the ZEV availability on the second-hand market. This specific objective aims to render 
ZEVs more affordable, in particular for citizens and SMEs. The lower purchase price of second-hand 
ZEVs can offer opportunities to switch to this option for a significantly higher number of citizens and 
transport operators, allowing them to benefit from their lower TCO compared to conventional vehicles93. 
Furthermore, by increasing the availability of second-hand ZEVs across the EU, this specific objective 
helps  making  them  more  affordable  through  intra-EU  trade  also  in  those  Member  States  where  the 
second-hand vehicle market is predominant and national incentives are not sufficient to make new ZEVs 
competitive, thus contributing to a more balanced progress towards road transport decarbonisation across 
the EU.  

Figure 2: General and specific objectives and their links to problem drivers 

Source: European Commission 

SO1, SO2 and SO3 are interrelated. However, it should be noted that SO1 could be fully achieved at the 
same time with a partial achievement of SO2 and SO3, or at the same time with their full achievement. This 

91 Clean Industrial Deal Communication 
92 Industrial Action Plan for the Automotive Sector 
93  The availability of second-hand ZEV leasing options will be considered as equivalent to second-hand ZEV purchase, as they 
bring comparable benefits in terms of affordability 

17 

PROBLEM DRIVERSSPECIFIC OBJECTIVESGENERAL OBJECTIVEStimulate the demand for ZEVs in the corporate segment (SO1)Reduce fossilfuels expenditures in the road transport sector (SO2)Accelerate ZEV availability onthesecond-hand market (SO3)Support the decarbonisation of the road transport sector, whilesafeguarding the competitiveness of the EU automotive industryand ensuring a fair transitionFragmented support framework at national level for corporate ZEV (PD1)High purchase costs and operational constraints of ZEVs compared to conventional vehicles (PD2) 
 
 
depends on the type of fleets for which an increase in ZEV is required. For example, if the increase in ZEVs 
required to meet SO1 would take place exclusively in true fleets such as taxis and ride-hailing, this would 
contribute significantly to SO2 (due to the high mileage of those vehicles) but only to a limited extent to 
SO3 (taxis are not among the corporate fleets that reach the second-hand market fastest, although they still 
do so faster than private cars). Conversely, if SO1 would be achieved exclusively through an increase in 
ZEVs  in  rental  cars,  the  contribution  to  SO3  would  be  significant  (because  of  the  very  fast  turnover  to 
second-hand market), but the contribution to SO2 would be more limited (because their yearly mileage is 
lower than that of taxis).  

The three specific objectives further contribute to ensuring the achievement of the general objective of the 
initiative:  to  support  the  decarbonisation  of  the  EU  road  transport  sector,  while  safeguarding  the 
competitiveness  of  the  European  automotive  industry  and  ensuring  a  fair  transition.  In  this  context,  EU 
content  requirements  are  expected  to  contribute  towards  the  achievement  of  the  general  objective  by 
safeguarding the competitiveness of the European automotive industry. However, it should be noted that this 
is  a  targeted  initiative  and  other  initiatives  under  preparation,  such  as  the  Industrial  Accelerator  Act,  are 
better placed for addressing the competitiveness of the European automotive industry. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1.  What is the baseline from which options are assessed? 

Section 2.1 identifies two main problems, namely the low uptake of ZEV in corporate fleets (cars, vans and 
lorries)  and  the  insufficient  availability  of  affordable  zero-emission  vehicles  on  the  second-hand  market, 
which  is  the  primary  mean  of  vehicle  purchase  for  SMEs  and  citizens.  Despite  differences  among 
subcategories  (e.g.  leasing  fleets,  company  cars,  and  true  fleets),  the  share  of  zero-emission  vehicles  in 
corporate fleets remains low at close to 17% of new registrations for cars, 8% for vans and 3.7% for lorries 
in the first half of 202594. 

As explained in section 2.1, corporate fleets are very important for conditioning ZEV registrations in the EU 
as  they  are  responsible  for  58%  of  new  registrations  of  cars,  around  90%  of  vans  and  virtually  all  new 
registrations of lorries. A substantial strengthening of demand for ZEVs from corporate fleets is needed to 
provide  greater  certainty  about  the  level  of  demand  for  ZEVs  that  manufacturers  can  expect  from  these 
market segments, that are capable of a faster and more efficient transition. The 2030 targets under the CO2 
standards for cars, vans and lorries require an accelerated uptake of zero-emission vehicles in the next years. 
Without further regulatory intervention at the EU level that enables clear market direction for the uptake of 
zero-emission  vehicles  in  corporate  fleets  at  national  level,  the  potential  of  the  corporate  vehicles  to 
contribute  to  the  necessary  demand  will  remain  underexploited.  Section  2.3  explains  that  although  the 
problems are expected to subside over time, without EU level action, problem 1 is likely to remain relevant 
until 2035 for cars and vans and at least until 2040 for lorries, while problem 2 is likely to persist until 2030-
2035 for new cars, vans and lorries and at least until 2036 on the second-hand market (because of the time 
gap between vehicles first registration and availability on the second-hand market). 

In  line  with  the  Better  Regulation  toolbox  (Tool  #60),  the  baseline  has  been  designed  to  include  the 
initiatives  of  the  ‘Fit  for  55’  package95  and  the  proposed  amendment  of  the  European  Climate  Law  to 
include a 2040 climate target for the EU96, of reducing the EU's net greenhouse gas emissions by 90% by 
2040  relative  to  1990,  with  a  limited  contribution  towards  the  2040  target  of  high-quality  international 
credits of 3% of 1990 EU net emissions. It also reflects the revised CO2 emission performance standards for 

94 Source: Dataforce database and European Alternative Fuels Observatory 
95 Delivering the European Green Deal - European Commission 
96 COM(2025) 524 final 

18 

 
 
heavy-duty vehicles97, the new Euro 7 standards98, the revised TEN-T Regulation99, as well as the initiatives 
part of the Greening Freight package100 and Roadworthiness package101. It also reflects the National Energy 
and Climate Plans prepared by the Member States under the Regulation 2018/1999 on the Governance of 
the Energy Union and Climate Action and submitted to the Commission during 2024-2025. The baseline 
scenario  assumes  no  further  EU  level  intervention  beyond  the  current  fragment  support  framework  at 
national level for corporate ZEV. More details on the baseline scenario assumptions and results are provided 
in Annex 4 (section 2). 

The baseline also incorporates perspectives on potential future developments captured in the 2022 Strategic 
Foresight Report102 and during a foresight workshop organised by DG MOVE and JRC on 10 February 
2025,  analysing  the  impacts  of  the  megatrends  and  drivers  of  change  on  the  EU  transport  sector103.  In 
particular, the projected transport activity draws on the long-term population projections from Eurostat and 
GDP growth from the Ageing Report 2024104. 

In the baseline scenario, EU transport activity is projected to grow post-2020, following the recovery from 
the COVID-19 pandemic. Road transport would maintain its dominant role within the EU by 2050, despite 
its lower modal share over time. Road passenger transport activity (expressed in passenger-kilometres)105 is 
projected to grow by 7% between 2015 and 2030 (15% for 2015-2050), while road freight transport activity 
(expressed in tonne-kilometres)106 by 32% during 2015-2030 (52% for 2015-2050). Transport activity for 
rail is projected to grow significantly faster than for road, driven in particular by the completion of the TEN-
T core network by 2030 and of the comprehensive network by 2050, supported by the Connecting Europe 
Facility107, Cohesion Fund and ERDF funding, but also by measures of the ‘Fit for 55’ package108 and the 
Greening Freight package.  

The share of ZEV in new registrations for corporate cars is projected to increase from 17% in 2025 to 31% 
in 2029 and 61% in 2030, while for vans from around 8% in 2025 to 30% in 2029 and 52% in 2030109. 

97 Regulation (EU) 2024/1610 
98 Regulation - 2024/1257 - EN - EUR-Lex 
99 Regulation - EU - 2024/1679 - EN - EUR-Lex 
100 Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu). 
101 Updated rules for safer roads, less air pollution and digital vehicle documents 
102 COM(2022) 289 final 
103 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
104 DG ECFIN, 2024 Ageing Report.  Economic and Budgetary Projections for the EU Member States (2022-2070)  - 
Economy and Finance 
105 Covering passenger cars, buses and coaches and power-two wheelers.  
106 Covering heavy goods vehicles and light commercial vehicles.  
107 Regulation - 2021/1153 - EN - EUR-Lex 
108 These measures increase to some extent the competitiveness of rail relative to road and air transport. 
109 Overall, the shares of ZEV in the new registrations of cars and vans for 2029 assume some anticipation of the  CO2 
emission  standards  for  2030  in  the  baseline  scenario.  According  to  Regulation  (EU)  2023/851  and  Commission 
Implementing Decision (EU) 2023/1623, the CO2 targets on vehicle manufacturers for new cars and vans for the period 
2025-2034 are defined as follows: (i) Cars:  93.6 g CO2/km (2025-2029) and 49.5 g CO2/km (2030-2034); (ii) Vans: 
153.9 g CO2/km (2025-2029) and 90.6 g CO2/km (2030-2034). In addition, a temporary flexibility has been added in 
2025.  Rather  than  having  to  comply  with  the  CO2  emissions  targets  annually,  for  the  years  2025,  2026  and  2027, 
manufacturers’  compliance  will  be  assessed  based  on  their  performance  over  the  entire  three-year  period.  The 
temporary flexibility is also reflected in the baseline. Meeting the CO2 target for 2025-2029 is estimated to require a 
share of ZEV in new registrations for cars of around 25% and for vans of around 19%, while meeting the CO 2 target for 
2030-2034 a share of ZEV in new registrations for cars of around 60% and for vans of around 50%. For 2029, vehicle 
manufacturers  are  required  to  comply  with  the  same  CO2  target  level  as  in  2025-2027  (including  the  temporary 
flexibility), and therefore they could choose to comply with the minimum shares of ZEV in new registrations for cars 
and vans that are needed for meeting the CO2 standards. On the other hand, considering the large difference between 
the shares of ZEV required for meeting the CO2 targets in 2025-2029 and in 2030-2034, vehicle manufacturers could 

19 

 
 
 
From 2035, all new light-duty vehicles (cars and vans) must achieve zero tailpipe emissions due to the CO2 
emission standards regulation, and thus the share of ZEV in new registrations of cars and vans is 100%. For 
lorries (virtually all corporate), the new registrations of ZEV are projected at around 7% in 2029, 24% in 
2030 and going up to 77% by 2050 in the baseline scenario. Taking into account the payload weighting 
factors under the CO2 emission performance standards110, the new zero-emissions registrations for regulated 
lorries are projected at 9% in 2029, 30% in 2030 and around 90% by 2050. 

The share of ZEV in the overall cars fleet is projected at 13% in 2030, going up to 83% in 2050 in the 
baseline scenario, while for vans at 10% in 2030 and 82% in 2050, and for lorries at around 2% in 2030 and 
48% in 2050 (around 2% in 2030 and 57% in 2050 taking into account the payload weighting factors under 
the CO2 emission performance standards). Of this, for corporte cars the share of ZEV is projected at 30% in 
2030 and 98% in 2050, due to the shorter initial ownership duration and faster turnover of the corporate 
vehicles.  For  corporate  vans,  which  represent  around  90%  of  the  total,  the  share  of  ZEV  in  the  fleet  is 
projected at 11% in 2030 and 84% by 2050. These developments are mainly driven by the CO2 standards 
Regulation, supported by the Alternative Fuels Infrastructure Regulation and incentives for ZEV at national 
level, in line with State aid rules, if applicable. NOx emissions from road transport are projected to reduce by 
72% in 2030 relative to 2015 (99% reduction for 2015-2050), while particulate matter (PM2.5) emissions 
would decrease by 48% in 2030 relative to 2015 (95% reduction for 2015-2050).  

In line with the Better Regulation toolbox, the baseline assumes that all legislation in place and proposed by 
the Commission is fully implemented, including the ETS2 which caps the emissions from road transport and 
buildings, and the Renewable Energy Directive setting targets for renewable energy in transport as well as 
mandates  for  renewable  fuels  of  non-biological  origin  (RFNBO)  and  advanced  biofuels.  Vehicle 
manufacturers  are  assumed  to  comply  with  the  CO2  emission  performance  standards  for  new  vehicles 
throughout  the  time  horizon  considered.  Member  States  and  transport  operators  also  comply  with  other 
requirements included in the existing legislation. The EU climate targets for 2030, 2040 and 2050 are met in 
the baseline and the CO2 emissions from road transport are projected to decrease by 27% by 2030 relative to 
2015, and be close to zero by 2050, thanks to the large-scale uptake of zero-emission vehicles and some use 
of renewable and low-carbon fuels.  

Driven  by  the  recovery  of  the  transport  activity  following  the  COVID-19  pandemic,  the  most  recent 
available  statistics  (for  2023)  show  no  progress  in  the  reduction  of  CO2  emissions  from  road  transport 
relative to 2015. In case vehicle manufacturers do not meet their CO2 emission targets, or Member States 
and  transport  operators  do  not  fully  comply  with  other  legal  requirements,  or  consumers  delay  the 
acquisition of new vehicles, the reduction in the CO2 emissions from road transport would be lower than 
projected in the baseline. In this case, other transport modes (where emissions are harder to abate) or other 
sectors would need to deliver higher emission reductions to meet the EU climate targets for 2030, 2040 and 
2050. However, as explained above, in line with the Better Regulation toolbox, the baseline assumes the 
implementation of existing policies.   

In addition, in the baseline the benefits of higher uptake of ZEV by large companies remain untapped. As 
corporate  vehicles  typically  have  comparatively  high  yearly  mileage,  their  higher  uptake  increases  the 
potential impact on real-world emissions reductions.  

choose  to  gradually  increase  their  registration  of  ZEV  in  2029  beyond  what  is  required  by  the  CO2  standards,  to 
anticipate the preparation for meeting the 2030 target. 
110 In the context of CO₂ emission standards for heavy-duty vehicles, lorry classes such as 9-RD (regional delivery), 5-
LH  (long-haul),  and  others  are  used  to  define  vehicle  configurations  and  typical  usage  profiles  for  compliance  and 
target-setting purposes under Regulation (EU) 2019/1242. These classifications help align emissions targets with real-
world operations across various duty cycles. 

20 

 
 
5.2.  Description of the policy options 

5.2.1.  Possible policy options and preliminary screening of options 

As  a  first  step,  a  comprehensive  list  of  possible  policy  measures  and  options  was  established  after 
consultations  with  stakeholders,  expert  meetings,  and  the  Commission’s  own  analysis.  This  list  was 
subsequently  screened  based  on  the  likely  effectiveness,  efficiency  and  proportionality  of  the  proposed 
measures in relation to the given objectives, as well as their legal and technical feasibility.  

5.2.2.  Discarded policy options 

Based on internal assessment and on information received in the context of the CfE and targeted stakeholder 
consultations, several options have been discarded. This includes setting mandatory targets for the minimum 
share of ZEV in all corporate fleets above a certain size. In such option all companies would be required to 
report on the number of vehicles they owned each year, and those owning more than a certain number of 
vehicles would need to ensure  that  a minimum share of those are ZEV. This option was not  considered 
proportionate due the very high administrative costs and the risk of imposing stringent targets on fleets for 
specific use cases where the ZEV availability is still limited; for example, fleets with specific use cases and 
operational requirements which are not yet met by ZEV models currently available on the market might be 
unable to meet the mandatory share of ZEVs.  

The setting of mandatory targets for the minimum share of ZEVs in specific types of corporate fleets (e.g. 
leasing or taxis) was also discarded on the basis of insufficient internal consistency, due to the very high risk 
of unintended consequences and avoidance action. For example, setting mandatory targets on leasing fleets 
might lead some operators and clients to shift from vehicle leasing to other financial solutions, or result in 
clients with a preference for conventional vehicles to decide to purchase rather than lease a vehicle. Setting 
mandatory targets for taxi companies and/or ride-hailing companies that own the vehicles of their fleet might 
damage  their  competitiveness  compared  to  ride-hailing  companies  using  a  higher  share  of  their  drivers’ 
private vehicles. This option was expected to show low effectiveness as a result of the limited scope, as a 
result of covering only some types of corporate fleets.  

Voluntary  commitments  by  large  shippers  and  large  fleet  operators  to  meet  a  minimum  share  of  zero-
emission vehicles by a given date were also discarded, because they were considered insufficient to address 
the identified problems and problem drivers. Another discarded option was a Commission Recommendation 
on the taxation of corporate vehicles i.e. providing favourable fiscal treatment of zero-emission corporate 
vehicles compared to conventional ones, given that suggestions on fiscal levers were already presented in 
Decarbonise Corporate Fleets Communication111 in March 2025.  

The possibility of particularly requiring vehicle-to-grid (V2G) capability for corporate vehicles in scope was 
also discarded as at this stage of development it was not considered proportionate and efficient, given that 
parts of the required technical specifications on the vehicle side are not yet standardised112, this capability is 
not  widely  implemented  on  electric  vehicles  on  the  market,  and  there  is  no  technical  requirement  for 

111 Communication: Decarbonise Corporate Fleets 
112  Currently,  this  capability  is  not  widely  implemented  on  electric  vehicles  on  the  market  and  there  is  no  technical 
requirement  for  electric  vehicle  manufacturers  to  include  it  in  vehicle  type-approval  documentation.  Therefore, 
Member States have no mechanism at their disposal to verify technical compliance of electric vehicles equipped with it. 
Moreover,  in  many  Member  States  essential  parts  of  grids  readiness  is  not  given,  starting  with  the  necessary  wide 
rollout  of  smart  meters,  but  also  other  aspects  of  fully  digitalising  grids.  The  upcoming  Electrification  Action  Plan, 
expected  in  early  2026,  will  set  out  the  steps  needed  to  inform  the  Commission  about  the  concrete  vehicle-to-grid 
technical requirements to be included in future type-approval legislation and, therefore, ensure a harmonised adoption 
of vehicle-to-grid capable vehicles. 

21 

 
 
electric vehicle manufacturers to include it in vehicle type-approval documentation. Furthermore, vehicle-
to-grid capability requirements would be very difficult to implement in the context of this proposal, and 
importantly, may interfere with other relevant legislative frameworks in this field (e.g. EU type approval 
legislation).  The  benefits  of  such  requirement  would  vary  significantly  from  one  fleet  to  another, 
depending on the type of vehicle and its use case.  

Other options were discarded due to the higher administrative costs and comparable benefits to some of the 
retained  options,  or  insufficient  internal  and/or  external  coherence  in  relation  to  e.g.  the  CO2  emission 
performance standards for heavy-duty vehicles113. Annex 7 provides an overview of all options discarded 
and a justification for not retaining them.  

5.2.3.  Retained policy options  

Two main groups of policy options have been retained for further analysis (PO1 and PO2), each including 
three different levels of ambition for the uptake of zero-emission cars, vans and lorries. The two groups of 
policy options were designed to address all problem drivers and specific objectives. 

The analysis of possible options and inputs from stakeholders highlighted the need to maintain sufficient 
flexibility  and  avoid  the  risk  of  imposing  mandatory  targets  on  individual  fleets.  Both  groups  of  policy 
options address this by not targeting directly individual fleets, but providing key enablers for the corporate 
fleets transition to ZEVs: the first group of options (PO1) sets targets for Member States,  enabling clear 
market direction which will require Member States to activate key national policy levers such as incentives 
for ZEV uptake in corporate fleets through differentiated vehicle and income taxation or e.g. favourable road 
charging regimes, if such measures are not in place already. Under this group of options Member States 
retain full flexibility for the implementation pathway under the binding overall target, leaving hence greater 
initial uncertainties about different regulatory approaches at national level, but ensuring greater flexibility 
and minimising the risk of imposing strict targets on specific fleets whose operational requirements cannot 
yet be met with ZEVs. The second group of options (PO2) follows the same approach for cars and vans but 
mobilises  demand  for  ZEV  trucks  through  a  binding  target  on  minimum  shares  of  ZEVs  in  transport 
activities of large companies, thus addressing certain companies directly, which increases certainty of the 
implementation pathway, while still not directly setting mandatory targets for individual transport operators. 
This  approach  aims  to  provide  certainty  of  demand  from  large  shippers  for  freight  transport  services 
performed through ZEVs; it relies on this guaranteed demand from shippers to push transport operators to 
increase the share of ZEVs in their fleets.  

Both groups of policy options (PO1 and PO2) consider the same approach for cars and vans, with national 
targets set on Member States for the share of zero-emission cars and vans in yearly new corporate vehicles 
registrations by large companies in their territory. PO1 and PO2 also consider the same three different levels 
of ambition for cars and vans. The difference between PO1 and PO2, as explained above, comes from the 
approach for lorries. While PO1 uses the same design for lorries as for cars as vans (with national targets set 
on Member States for the share of zero-emission lorries in yearly new corporate vehicles registrations by 
large companies in their territory), in PO2 large companies will need to ensure that a certain share of the 
tonne-km of activity performed on their behalf with lorries is performed with ZEVs. Large companies are in 
the  focus  of PO2  due to  their  comparatively stronger  ability to  accelerate  the transition  to  zero-emission 
lorries.  However,  all  transport  activity  performed  on  behalf  of  large  companies  is  in  the  scope  of  PO2, 
including own activity, direct sub-contracting and indirect sub-contracting as explained below. 

PO1 is expected to address all problems and problem drivers, without imposing disproportionate burdens on 
market actors. PO1 was designed taking into account the trade-off between expected impacts and flexibility 

113 Regulation (EU) 2024/1610 

22 

 
 
in view of a highly diverse market structure and use cases. Options going beyond the kind of national targets 
foreseen  by  PO1,  and  setting  mandates  for  individual  fleets  or  operators  might  better  ensure  that  the 
objectives are met, but they would not provide sufficient flexibility. Additionally, they carry significant risks 
of unintended consequences, including setting targets that cannot be met by certain operators with specific 
requirements and use cases, and would be expected to result in significant administrative burden. On the one 
hand, it was considered that the approach of setting the mandate not directly on the fleet operators, but on 
shippers (in PO2), would reduce the extent of some of those risks, by creating stable demand for freight 
activity performed by ZEV rather than a direct mandate on individual SMEs performing transport services. 
Unlike the options setting targets on specific operators or fleets, that were discarded, the setting of shippers’ 
mandates in PO2 was explicitly and repeatedly supported by some key stakeholders and noted in some of 
their submissions to the CfE114. For this reason, it was deemed necessary to retain this option for lorries and 
assess its impacts.  

PO1  and  PO2  are  expected  to  lead  to  a  more  balanced  contribution  towards  the  achievement  of  SO1 
(Reduce fossil fuels expenditures in the road transport sector), SO2 (Reduce fossil fuels expenditures in the 
road  transport  sector)  and  SO3  (Accelerate  ZEV  availability  on  the  second-hand  market)  than  other 
discarded policy options. 

Table 2 presents the key elements of each policy option, together with the associated specific objective and 
the problem driver they address, while the policy options are described in detail below.  

Table 2: Overview of the key elements of the policy options 

Specific objectives 
/ Problem drivers 

PO1A  PO1B  PO1C  PO2A  PO2A 

PO2C 

PD1, PD2,  
SO1, SO2, SO3 

√ 

√ 

√ 

√ 

√ 

√ 

Target setting 
Cars and vans: targets for Member States based on 
percentage of new zero-emission vehicles 
registrations by large companies (modulated by 
Member State based on the GDP per capita and the 
current share of ZEV in the fleet) 

target level 

low ambition  
medium ambition  
high ambition 

Lorries: target for Member States based on 
percentage of new zero-emission vehicles 
registrations by large companies (same for all 
Member States) 

PD1, PD2,  
SO1, SO2, SO3 

target level 

low ambition  
medium ambition  
high ambition 

Lorries: minimum target for the share of zero-
emission lorries in large companies’ transport 
activity (same for all large companies) 

PD1, PD2,  
SO1, SO2, SO3 

target level 

low ambition  
medium ambition  
high ambition 

Reporting and monitoring 

114 E-mobility Europe, Transport&Environment, ACEA 

23 

√ 

√ 

√ 

√ 

√ 

√ 

√ 
√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
Specific objectives 
/ Problem drivers 

PO1A  PO1B  PO1C  PO2A  PO2A 

PO2C 

Annual reporting by Member States of percentage 
of new zero-emission cars, vans and lorries 
registrations, based on data from national vehicle 
registries  
Annual reporting by large companies of the share of 
the tonne-km of activity performed on their behalf 
with zero-emission vehicles 
Reporting by Member States to be facilitated by the 
extension of the central register maintained by the 
European Environment Agency for CO2 standards 
for vehicles  
Monitoring enforcement by Member States 
authorities 

Vehicles covered by the policy option 
Cars, vans and lorries 

PD1, SO1 

√ 

√ 

√ 

PD1, SO1 

PD1, SO1 

√ 

√ 

√ 

PD1, SO1 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

Policy option 1 (PO1) sets binding minimum targets for Member States on the share of zero-emission 
vehicles (cars, vans and lorries) in yearly new corporate vehicles registrations by large companies in 
their territory.  

PO1 will require each Member State to ensure that, starting from 2029, a certain share of new registrations 
of  corporate  cars,  vans,  and  lorries  by  large  companies  in  its  territory  during  that  year  is  zero-emission. 
Corporate vehicles registered by SMEs are hence not included in the scope.  

In order to meet these national targets, Member States will have to put in place measures to increase the 
demand of corporate ZEVs from large companies, thus contributing to SO1 (Stimulate the demand of ZEVs 
in the corporate segment).  The design of the measures is under the discretion of the Member State. The 
resulting increase in the share of ZEVs in corporate fleets with a high yearly mileage, such as true fleets, 
contributes to SO2 (Reduce fossil fuels expenditures in the road transport sector). At the same time, PO1 
addresses SO3 (Accelerate ZEV availability on the second-hand market) by accelerating the deployment of 
ZEVs in corporate fleets with a shorter first ownership period, such as rental and leasing fleets, and vehicles 
registered by vehicle manufacturers. The additional ZEVs in those fleets are expected to rapidly reach the 
second-hand market (either as sales or as second leasing), increasing the availability of ZEV options for 
citizens and businesses relying on second-hand vehicles.   

The minimum national targets are set at different levels of ambition for cars, vans, and lorries, to reflect the 
different level of technology and market development, as well as the differences in targets for the respective 
vehicle categories under the CO2 emission performance standards. It is also necessary to take into account 
the  specific  situation  and  characteristics  of  different  Member  States,  in  relation  to  both  their  economy’s 
ability to address the higher initial capital costs of ZEVs, and the level of ZEV deployment in their vehicle 
registration.  However,  this  consideration  needs  to  be  balanced  with  the  need  to  avoid  undue  market 
distortion. Cars  and  vans are primarily used within the Member State where they are registered, and the 
markets for vehicles and services are mostly segmented by Member State115. For these vehicles, the level of 

115 The evidence base supporting the claim that cars and vans are primarily used within the Member State where they are registered 
and the markets for vehicles and services are mostly segmented by Member State is based on the characteristics and legal and 
operational requirements of different types of corporate fleets. Several types of true fleets, such as taxi, ride-hailing, and car sharing, 
operate on the basis of local permits and licences that limit their geographical area of activity, so that they are effectively never 
operating across borders. In the case of rental cars, most companies impose cross-border fees or other limitations for cross-border 
and 
operation 
information  collected  through  stakeholders’  interviews  and  desk  research  in  preparation  of  a  proposal  on  cross-border  rentals 
(Taking car rentals into other EU countries – rules) indicates that one-way cross-border rentals (where the vehicle is returned in 

(https://wayrent.com/blog/cross-border-car-rentals-in-europe-rules-fees-and-how-to-do-it-right/), 

24 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
ambition set for the EU as a whole can be modulated across Member States. The target for each Member 
State is calculated starting from the overall EU target, modulated on the basis of the share of ZEV in new 
registrations in each Member State in 2024 and the GDP per capita, with equal weighting. GDP per capita is 
considered  a  good  proxy  for  the  economic  capacity  of  operators  within  Member  States  to  afford  higher 
capital costs of ZEVs, while the share of ZEVs in new registrations represents a proxy for the presence of 
the necessary enabling conditions (vehicle availability, deployment of recharging infrastructure).  

For each Member State, the distance from the EU average was calculated for both GDP per capita and the 
share of ZEVs in new registrations in 2024. The average between those two factors was then calculated, 
giving them equal weighting.  

Table 3: Calculation of modulation factors for Member States 

% of ZEV in new 
registrations, M1+N1 
(2024) 

% of ZEV 
divided by EU 
average 

GDP per capita 
(EUR per 
capita) 

GDP per capita 
divided by EU 
average 

Modulation (50% BEV 
and 50% GDP 
weighting) 

Modulation 
factor 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
EU27 

16.58 
25.48 
3.54 
2.49 
6.96 
4.50 
46.81 
4.65 
27.59 
15.14 
12.70 
6.32 
6.80 
12.08 
3.99 
6.84 
5.62 
25.72 
20.91 
27.31 
2.98 
18.30 
6.21 
2.30 
5.26 
5.32 
33.27 
12.55 

1.32 
2.03 
0.28 
0.20 
0.55 
0.36 
3.73 
0.37 
2.20 
1.21 
1.01 
0.50 
0.54 
0.96 
0.32 
0.54 
0.45 
2.05 
1.67 
2.17 
0.24 
1.46 
0.49 
0.18 
0.42 
0.42 
2.65 

52760 
51810 
16110 
21740 
34490 
29440 
65650 
28740 
49100 
42590 
50830 
22560 
21570 
104510 
37180 
21610 
27150 
126910 
39330 
62380 
22560 
26700 
18560 
24000 
31490 
32590 
52600 
39710 

1.33 
1.30 
0.41 
0.55 
0.87 
0.74 
1.65 
0.72 
1.24 
1.07 
1.28 
0.57 
0.54 
2.63 
0.94 
0.54 
0.68 
3.20 
0.99 
1.57 
0.57 
0.67 
0.47 
0.60 
0.79 
0.82 
1.32 

1.32 
1.67 
0.34 
0.37 
0.71 
0.55 
2.69 
0.55 
1.72 
1.14 
1.15 
0.54 
0.54 
1.80 
0.63 
0.54 
0.57 
2.62 
1.33 
1.87 
0.40 
1.06 
0.48 
0.39 
0.61 
0.62 
1.99 

1.30 
1.30 
0.70 
0.70 
0.80 
0.70 
1.30 
0.70 
1.30 
1.20 
1.20 
0.70 
0.70 
1.30 
0.70 
0.70 
0.70 
1.30 
1.30 
1.30 
0.70 
1.00 
0.70 
0.70 
0.70 
0.70 
1.30 

a different Member State from the one where it is picked up) represent less than 1% of all rentals, and that most Member State either 
prohibit or restrict the rental of vehicles registered in another Member State. Under current car registration rules, rental cars returned 
in a different country than the one in which they are registered and rented may need to be immediately re-registered in the country of 
use, or immediately brought back to the country of origin (by lorry, by rail or with the help of a specific driver) except in the rare 
cases  when  a  customer  can  be  found  immediately  in  the  country  of  destination  for  a  return  trip.  These  different  re-registration 
procedures in Member States yield extra costs for car rental companies that are passed through to the citizens, and limit their cross-
border use. Finally, targeted interviews with logistics operators clearly indicate that vans are used for local and regional distribution 
(with  the  vehicle  picking  up  and  delivering  between  local  hub  and  customers),  while  transport  between  different  hubs  (which 
includes all long-haul and cross-border activities) is performed with lorries. 

25 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
To  ensure  balanced  development  and  minimise  market  fragmentation,  while  still  reflecting  differences 
between Member States, modulation factors were applied to Member States on the basis of the resulting 
calculation, as provided in the table below.  

Table 4: Distance from the EU average and the modulation factor 

Distance from EU average (GDP per capita and ZEV 
shares, equal weighting) 

≤ 0.7 

0.7 – 0.9 

0.9 – 1.1 

1.1 – 1.3 

≥1.3 

Modulation factor 

0.7 

0.8 

1 

1.2 

1.3 

On the other hand, international transport represented 38.7% of road freight transport in 2023, expressed in 
terms  of  tonnes-kilometres116.  Setting  differentiated  national  targets  for  these  vehicles  would  carry  a 
significant risk of distorting the market, by encouraging the registration of new vehicles used for this purpose 
in Member States with lower levels of ambition. For these vehicles, therefore, this option foresees the same 
level of ambition across all Member States. 

For lorries, it is also necessary to refer to the payload weighting factors under the CO2 emission performance 
standards, so that different sub-groups117 are counted correctly for the purpose of meeting the targets. This is 
necessary  to  ensure  that  the  proposal  effectively  contributes  to  transport  emission  reductions  and  helps 
vehicle manufacturers meet the CO2 emission performance standards targets. 

In  order  to  ensure  compliance  with  the  targets,  Member  States  will  review  their  policy  mix  and  adopt 
measures that can stimulate a quick market response. They will have flexibility to promote a faster shift to 
ZEV in corporate vehicles by reducing ZEV’s TCOs through fiscal and financial incentives, as well as by 
improving operational conditions (e.g. ensuring higher availability of recharging points at key locations), 
thus effectively reducing operation costs, or by setting mandatory targets for specific entities. They will be 
able to use any measures they deem necessary to this aim, including e.g. modifying the taxation of corporate 
vehicles in favour of ZEVs, more favourable road tolling, introducing requirements in licencing for specific 
passenger transport services (e.g. taxis, ride-hailing), improving enabling conditions such as availability of 
dedicated recharging points at specific locations or preferential access to parking. Because the targets are set 
on Member States, and they have different measures available to stimulate ZEVs in corporate fleets, this 
approach  is  not  expected  to  lead  to  the  kind  of  unintended  consequences  that  would  result  from  strict 
mandatory targets on individual entities – such as a greater use of sub-contracting or  as switch between 
leasing  and  ownership  –  but  to  Member  Stats  primarily  taking  measures  to  make  it  more  economically 
convenient to switch to ZEVs. Even in the case of Member States deciding to set mandatory targets for 
specific types of companies or fleets, however, the risk of potential indirect and unexpected impacts can be 
considered lower than for target setting at European level. National authorities have a better understanding of 
the fleets operating on their territory, as the complexity is lower and information and data are more easily 
available, and they can make full use of existing monitoring and reporting schemes – for example in the 
context of their fiscal system – to minimise the additional administrative burden. 

Monitoring and reporting will be ensured directly by the Member States, by extracting the relevant data from 
their vehicle registries and submitting it yearly to the Commission, and further addresses SO1 (Stimulate the 
demand of ZEVs in the corporate segment). While Member States are already able to differentiate corporate 
from private vehicles in their registry, the exclusion of corporate vehicles registered by SMEs would require 

116 Statistical pocketbook 2025 - Mobility and Transport - European Commission 
117 In the context of CO₂ emission standards for heavy-duty vehicles, truck classes such as 9-RD (regional delivery), 5-
LH  (long-haul),  and  others  are  used  to  define  vehicle  configurations  and  typical  usage  profiles  for  compliance  and 
target-setting purposes under Regulation (EU) 2019/1242. These classifications help align emissions targets  with real-
world operations across various duty cycles. 

26 

 
  
 
a one-off adaptation of Member States’ registries. This reporting will be performed in the framework of the 
the central register for CO2 standards for vehicles maintained by European Environment Agency (EEA). 
There will be no need for companies to submit any reports to public authorities.  

The three sub-options of policy option 1 (PO1A, PO1B and PO1C) are only different in terms of the levels 
of ambition for the targets for cars, vans and lorries. All other elements are the same. The EU level targets 
for PO1A, PO1B and PO1C are provided in the tables below, while the modulated targets for cars and vans 
for different Member States are included in Annex 8.  

Policy option 1A (PO1A): low ambition for the targets for cars, vans and lorries 

Table  5:  Minimum  target  level  for  ZE  new  corporate  vehicle  registrations  by  large  companies  in  PO1A 
(*modulated by Member State) 

Year 

Cars* 

Vans* 

Lorries 

2029 

35% 

25% 

10% 

2030 

65% 

55% 

40% 

2035 

100% 

100% 

65% 

2040 

100% 

100% 

95% 

2045 

100% 

100% 

95% 

2050 

100% 

100% 

95% 

Policy option 1B (PO1B): medium ambition for the targets for cars, vans and lorries 

Table  6:  Minimum  target  level  for  ZE  new  corporate  vehicle  registrations  by  large  companies  in  PO1B 
(*modulated by Member State) 

Year 

Cars* 

Vans* 

Lorries 

2029 

45% 

35% 

15% 

2030 

70% 

60% 

45% 

2035 

100% 

100% 

70% 

2040 

100% 

100% 

95% 

2045 

100% 

100% 

95% 

2050 

100% 

100% 

95% 

Policy option 1C (PO1C): high ambition for the targets for cars, vans and lorries 

Table  7:  Minimum  target  level  for  ZE  new  corporate  vehicle  registrations  by  large  companies  in  PO1C 
(*modulated by Member State) 

Year 

Cars* 

Vans* 

Lorries 

2029 

50% 

45% 

20% 

2030 

75% 

65% 

50% 

2035 

100% 

100% 

75% 

2040 

100% 

100% 

95% 

2045 

100% 

100% 

95% 

2050 

100% 

100% 

95% 

Policy option 2 (PO2) sets binding minimum targets for Member States on the share of zero-emission 
cars and vans in yearly new corporate vehicles registrations by large companies in their territory, and 
a  binding  minimum  target  for  the  share  of  zero-emission  lorries  in  large  companies’  transport 
activities.   

For cars and vans, PO2 follows the same approach as PO1, with national targets set on Member States for 
the share of zero-emission cars and vans in yearly new corporate vehicles registrations by large companies in 
their territory. For lorries, however, PO2 applies directly to all large companies (companies with at least 250 
employees and EUR 50 million turnover)118, irrespective of their economic field of activity (i.e. 54,219 large 

118 Large companies as defined by Eurostat; Glossary:Enterprise size - Statistics Explained - Eurostat 

27 

 
 
companies119).  These  companies  will  be  required to  report  yearly  the total  road  freight transport  activity 
performed on their behalf – both by their own lorries and by direct and indirect sub-contractors – in tonne-
km, and ensure that a minimum share of that activity has been performed with zero-emission lorries.  

PO2 addresses SO1 (Stimulate the demand of ZEVs in the corporate segment) by requiring each Member 
State to ensure that, starting from a given year, a certain share of new registrations of corporate cars and vans 
by  large  companies  in  its  territory  during  that  year  are  zero-emission,  and  by  creating  demand  by  large 
companies for freight transport services performed with ZEV. By increasing the share of ZEVs in logistics 
fleets and other corporate fleets with a high yearly mileage, PO2 will contribute to SO2 (Reduce fossil fuels 
expenditures in the road transport sector). At the same time, it will also address SO3 (Accelerate the ZEV 
availability on the second-hand market) by accelerating the deployment of ZEVs in corporate car and van 
fleets  with  a  shorter  first  ownership  period,  such  as  rental  and  leasing  fleets,  and  vehicles  registered  by 
vehicle manufacturers.  

Large companies will need to ensure that a certain share of the tonne-km of activity performed on their 
behalf with lorries is performed with ZEVs. Large companies are in the focus of this option due to their 
comparatively  stronger  ability  to  accelerate  the  transition  to  zero-emission  lorries.  All  transport  activity 
performed on behalf of a large company is in the scope, including: 

•  Own activity: all freight transport activity performed by lorries operated directly by the company. The 
company will record every tonne-km of activity performed by each of its lorries, and it will yearly report 
the total activity and the share of this activity performed by ZEVs. 

•  Direct sub-contracting: all freight transport activity performed by lorries operated by a sub-contractor 
on behalf of the company, irrespective of whether the sub-contractor is itself a large company or an SME. 
Every sub-contractor will record every tonne-km of activity performed by each of its lorries, attribute it to 
the relevant client (e.g. in the case of a lorry transporting goods for different clients, the activity in tonne-
km will have to be split correctly between the different clients) and report it to the client. 

•  Indirect sub-contracting: all freight transport activity performed by lorries operated by a sub-contractor 
of a company working directly or indirectly on behalf of the large company, irrespective of whether the 
sub-contractors are large companies or an SME themselves120. Every sub-contractor will record every 
tonne-km of activity performed by each of its lorries, attribute it to the relevant client (e.g. in the case of a 
lorry  transporting  goods  for  different  clients,  the  activity  in  tonne-km  will  have  to  be  split  correctly 
between the different clients), and report it to the client, who in turn will report it to its client, until the 
report reaches the large company that is directly in the scope. 

Most large companies perform a relatively low share of their road freight transport  activity through own 
fleets and generally rely on sub-contracting for the vast majority of their freight transport needs121. In order 
to meet their target, large companies will therefore need to ensure not only a certain share of ZEVs in their 
own fleet, but also that a certain share of the activity they procure – directly or indirectly – is performed by 
ZEVs. To this aim, they will effectively need to ensure that their direct and indirect sub-contractors, the vast 
majority  of  which  are  SMEs  and  micro-enterprises122,  have  in  their  fleets  the  number  of  zero-emission 

119 Source: Eurostat. Enterprise statistics by size class and NACE Rev. 2 activity [sbs_sc_ovw] 
120 It is common for logistics companies to have four or five levels of sub-contracting: the main company will contract 
its transport activity to another company, which in turn will sub-contract part of that activity to another company, and 
so on. All levels of sub-contracting are included in the scope of PO2, and all need to report their activity accordingly. 
121 Typically, above 80% according to industry representatives. 
122  87%  of  companies  in  this  sector  are  micro-enterprises.  Source:  Eurostat.  Enterprise  statistics  by  size  class  and 
NACE Rev. 2 activity [sbs_sc_ovw] 

28 

 
 
lorries needed for complying with the targets for their transport activities. This option therefore impacts the 
whole road freight transport sector, while it sets the legal obligation only for large companies.  

For the purpose of reporting, the share of freight transport activity performed on behalf of large companies, 
PO2  refers  to  the  rules  set  out  in  the  context  of  corporate  sustainability  reporting123  to  determine  how 
different  legal  entities  have  to  be  considered  (e.g.  legal  entities  under  ownership/control  of  another  legal 
entity, different legal entities under the same ownership, franchises, subsidiaries across different Member 
States, different legal entities belonging to the same group, etc.). These rules need to ensure that all parts of a 
company,  including  all  local  branches  across  different  Member  States,  are  covered,  and  that  no  double-
counting occurs across Member States.  

All transport companies, including SMEs, that directly or indirectly provide freight services by lorry to large 
companies will need to monitor and report their activity in terms of tonne-km performed by type of vehicle, 
in order to  allow the large company to monitor and report compliance with its target. In practical terms, 
every company providing freight transport services to a large company in scope will therefore be required to 
report the precise tonne-km of the service performed, and the share of those tonne-km performed with ZEV, 
taking into account both the transport services performed directly by its own trucks and drivers, and those it 
has  sub-contracted  to  another  entity.  Where  the  transport  activities  of  a  large  company  rely  on  multiple 
layers of sub-contracting, which is a common business practice, each sub-contractor will need to collect and 
consolidate  the  relevant  information  from  its  own  sub-contractors,  and  report  it  to  its  clients.  The  large 
company will then  consolidate data provided by all its sub-contractors in a report to be submitted to the 
relevant Member State.     

Because the target is set in terms of tonne-km, neither the large company nor the sub-contractors need to use 
specific  methodologies  to  calculate  the  fuel  consumption  or  greenhouse  gas  emissions  linked  to  specific 
transport activities. The data to be collected and reported is limited to the tonne-km of activity and whether 
the lorry that performed it is a ZEV.  

For cars and vans, Member States will have to report the share of ZEV in new corporate vehicle registrations 
by large companies in the same was as for PO1. For lorries, they will also be required to compile reports 
from  all  large  companies  established  on  their  territory  and  submit  them  yearly  to  the  Commission. 
Monitoring enforcement will be performed based on sample verification of the correctness of companies’ 
reporting.  Member  States’  reports  will  be  submitted  in  the  framework  of  the  central  register  for  CO2 
standards for vehicles maintained by EEA, which will face limited costs to expand and manage the database.  

The three sub-options of policy option 2 (PO2A, PO2B and PO2C) are only different in terms of the levels 
of ambition for the targets for cars, vans and lorries, as described below. All other elements are the same.  

Policy option 2A (PO2A): low ambition for the targets for cars, vans and lorries 

For cars and vans, the PO2A targets are the same as PO1A targets, while for lorries the targets are for large 
companies on the share of their freight activity performed by zero-emission lorries in tonnes kilometre. 

Table  8:  Minimum  target  level  for  ZE  new  corporate  vehicle  registrations  by  large  companies  in  PO2A 
(*modulated by Member State) 

Year 

Cars* 

Vans* 

2029 

35% 

25% 

2030 

65% 

55% 

2035 

100% 

100% 

2040 

100% 

100% 

2045 

100% 

100% 

2050 

100% 

100% 

123 Corporate Sustainability Reporting Directive 

29 

 
 
Year 

Lorries, % of tonnes 
kilometre 

2029 

3% 

2030 

5% 

2035 

14% 

2040 

30% 

2045 

50% 

2050 

68% 

Policy option 2B (PO2B): medium ambition for the targets for cars, vans and lorries 

For cars and vans, the PO2B targets are the same as PO1B targets, while for lorries the targets are for large 
companies on the share of their freight activity performed by zero-emission lorries in tonnes kilometre. 

Table  9:  Minimum  target  level  for  ZE  new  corporate  vehicle  registrations  by  large  companies  in  PO2B 
(*modulated by Member State) 

Year 

Cars* 

Vans* 

Lorries, % of tonnes 
kilometre 

2029 

45% 

35% 

4% 

2030 

70% 

60% 

6% 

2035 

100% 

100% 

16% 

2040 

100% 

100% 

32% 

2045 

100% 

100% 

52% 

2050 

100% 

100% 

70% 

Policy option 2C (PO2C): high ambition for the targets for cars, vans and lorries 

For cars and vans, the PO2C targets are the same as PO1C targets, while for lorries the targets are for large 
companies on the share of their freight activity performed by zero-emission lorries in tonnes kilometre. 

Table  10:  Minimum  target  level  for  ZE  new  corporate  vehicle  registrations  by  large  companies  in  PO2C 
(*modulated by Member State) 

Year 

Cars* 

Vans* 

Lorries, % of tonnes 
kilometre 

2029 

50% 

45% 

5% 

2030 

75% 

65% 

7% 

2035 

100% 

100% 

18% 

2040 

100% 

100% 

34% 

2045 

100% 

100% 

54% 

2050 

100% 

100% 

72% 

In relation to problem driver 1, PO1 and PO2 define a clear target structure that ends the fragmentation and 
provides clear market direction at national level. As a consequence of having to ensure compliance with the 
targets, Member States will have to review their policy mix and adopt measures that can stimulate a quick 
market response. In this context, experience from Member States with more mature zero-emission corporate 
fleet markets will inform the policy choices in other Member States and lead to a greater coherence of the 
policy mix across the Member States. The 2024 OPC clearly underlined the relevance of fiscal and financial 
incentives  for  the  transition  to  clean  corporate  fleets.  However,  in  full  respect  of  subsidiarity  and 
proportionality,  PO1  and  PO2  do  not  intend  to  harmonise  the  national  support  measures,  but  rather  to 
provide clear market direction for support of clean corporate fleets. 

In relation to problem driver 2, in PO1 for cars, vans and lorries and in PO2 for cars and vans, Member 
States  have  flexibility  to  promote  a  faster  shift  to  ZEV  in  corporate  vehicles  by  reducing  ZEV’s  TCOs 
through fiscal and financial incentives, as well as by improving operational conditions (e.g. ensuring higher 
availability  of  recharging  points  at  key  locations),  thus  effectively  reducing  operation  costs.  The 
Communication “Decarbonising Corporate Fleets”124 presented a series of measures that Member States can 
take to address these operational constraints. The setting of national targets will foster all Member States to 
make better use of relevant and proven support measures.  

124 COM (2025) 96 

30 

 
 
A summary of different stakeholder groups’ views in terms of (a) overall attitude towards the need to act and 
the ZEV transition in general, (b) ZEV mandates, and (c) vehicle tax/financial incentives is presented below:  

•  Electric  charging  and  hydrogen  refuelling  infrastructure  providers  are  generally  supportive  of  the 
transition towards zero-emission mobility and typically accept mandates, albeit with caveats. They argue 
that clear demand signals help de-risk infrastructure investments if they are coupled with realistic ramp-
up periods. They support incentives accelerating network build-up and fleet uptake (support for capital 
costs, grid-connection facilitation, targeted operating support in low-utilisation phases). Main concerns 
relate to charging infrastructure scale-up and reliability, grid-side bottlenecks (grid capacity and energy 
supply), and policy design to streamline permitting and connection. A number of stakeholders in this 
group underscore the positive case for incentives/tax measures crowding-in private investment.  

•  Civil  society  representatives  tend  to  favour  incentives  that  are  targeted  and  time-limited,  particularly 
those  that  are  CO2-based  or  removing  preferential  treatment  for  non-ZEVs,  to  avoid  rewarding  high 
emitters. Their reasons centre on climate urgency, public-health benefits, and consumer protection, while 
acknowledging the need for support measures (i.e. for lower-income users and SMEs) and infrastructure 
readiness. Main concerns relate to the ambition and design of mandatory targets (ensuring environmental 
effectiveness while preventing loopholes), coupled with the need for reliable, widely-available recharging 
infrastructure and incentives to accelerate adoption of ZEV without regressive impacts.  

•  Companies using transport and logistics services are more cautious or negative towards fleet mandates, 
with  many  arguing  that  binding  quotas  would  transfer  risks  to  buyers  without  solving  operational 
bottlenecks,  such  as  limited  range,  recharging  time,  or  infrastructure  availability.  Some  could 
conditionally support mandates if targets would be progressive, with sectoral flexibility. On incentives, 
there is conditional support for instruments that lower total cost of ownership (e.g., tax depreciation, toll 
relief,  bonus–malus  system  linked  to  CO₂  emissions),  provided  they  are  predictable  and  technology-
neutral. Main concerns relate to the charging availability/reliability as well as upfront risks for total cost 
of ownership. Operational planning and depot readiness also features strongly, where companies manage 
on-site charging for contractors or captive fleets.  

•  Final customers (road transport passengers, private companies for their employees), appear frequently 
critical of the ZEV transition and object to strict mandates or avoid taking a firm position. They lean 
towards incentives where these are customer-oriented (purchase grants, tax credits, toll exemptions) but 
warn against regressive designs. Main concerns relate to charging availability/reliability as well as total 
cost of ownership. They also share concerns about second-hand/residual values of company cars.   

•  Financial institutions and leasing stakeholders are sceptical and take critical positions on mandates. They 
view incentives favourably when these reduce financing risk (e.g., credit guarantees, depreciation rules, 
insurance/tax treatment that recognises lower running emissions). Main concerns relate to residual value 
of vehicles and second-hand market depth, which is a driver for pricing of leases and risks. They also 
share concerns on upfront risks and uncertainty related to total cost of ownership. They call for policy 
predictability to reduce risk premia and avoid abrupt changes stranding contracted fleets. In particular, 
leasing companies call for stable incentives and taxation rules.  

•  Logistics services companies show mixed to negative reactions to mandates and suggest that, if mandates 
are introduced, there should be derogations for specific duty cycles and realistic timelines targeting heavy 
and long-haul segments. On the other hand, incentives receive support when targeted at depot charging, 
last-mile operations, and load-factor-sensitive use cases, as well as when cross-border tolling/taxation is 
harmonised.  Main  concerns  relate  to operations:  charging  availability/reliability,  technology suitability 
(range/payload for time-critical operations), and depot readiness. Several stakeholders of this group also 
call for enhanced grid capacity and connection lead times at logistics hubs.  

31 

 
•  Public  authorities  often  show  support  for  mandates  as  a  tool  to  align  corporate  fleets  with  climate 
objectives, with caveats in relation to proportionality, subsidiarity, and administrative feasibility. They 
tend  to  favour  incentives  that  are  CO2-consistent,  temporary,  and  fiscally  responsible,  and  that  avoid 
distortion across Member States or breaching state-aid constraints. Main concerns relate to policy design 
and proportionality (workability of targets, data/monitoring burdens) and the need to remove practical 
barriers  to  delivery  (grid  capacity  and  energy  supply,  permitting,  and  public-realm  constraints  for 
chargers’ rollout).  

•  Rental  companies  are  mostly  critical  of  mandates  in  the  short-term,  citing  utilisation  volatility,  rapid 
model turnover, and uncertain residual value of vehicles. They support incentives that defray early-phase 
costs  and  stimulate  demand  (tax  treatment,  parking/zone  access  benefits),  while  calling  for  robust 
charging at airports, stations, and city hubs. Main concerns relate to vehicle availability and lead times to 
replace large fleets, residual value/second-hand markets, charging reliability (particularly for customers 
without home/depot charging). Many also quote concerns on total cost of ownership due to uncertainties 
about residual value of vehicles and split benefits (i.e. it is customers rather than rental companies that 
benefits from lower operation costs).  

•  Road haulage operators predominantly see mandates as impractical. According to them, if mandates are 
introduced,  substantial  flexibilities  for  heavy-duty,  long-haul,  and  cross-border  operations  would  be 
necessary.  They  support incentives  when these  are aimed  at  infrastructure  along  freight  corridors  and 
capital costs for vehicles, and energy-price stability. They also ask for technology neutrality for certain 
segments,  such  as  long-haul  lorries.  Main  concerns  relate  to  technology  performance  and  use-case 
suitability  for  heavier/long-haul  duty  cycles,  charging/refuelling  infrastructure  (including  high-power 
technologies 
lorry  charging),  grid  capacity  at  depots,  as  well  as 
(hydrogen/biomethane).  

in  alternative 

interest 

•  Passenger transport companies are broadly supportive of the transition but often critical of the proposed 
measures.  More  than  one  third  of  respondents  from  this  group  would  accept  mandates  with  caveats 
where  cities  provide  enabling  conditions  (charging  access,  zone  rules,  procurement  support),  while 
another  third  is  critical  of  mandates.  They  favour  incentives  that  reduce  downtime  and  cost  (rapid-
charging availability, tariff structures, targeted grants for professional drivers). Main concerns relate to 
charging  availability/reliability  (as  queueing  and  downtime  directly  erode  earnings),  total  cost  of 
ownership (high utilisation means small cost differences matter), and policy design (seeking pragmatic 
timelines/exemptions where infrastructure is not yet mature).  

•  Vehicle and transport equipment manufacturers (OEMs). This group typically supports mandates, albeit 
with  caveats,  favouring  predictable,  gradual  trajectories  that  align  with  industry’s  planning,  supply 
chains, and type-approval timelines. They support incentives that stimulate early demand, scale supply 
chains,  and  accelerate  infrastructure  (including  grid  connections),  while  being  negative  towards 
permanent subsidies that distort competition. Main concerns relate to vehicle availability and lead times 
(supply-chain  constraints),  and  technology  suitability  across  segments.  This  group  requests  stable, 
predictable policy and incentive frameworks to plan production and product roadmaps, and highlight the 
need for grid capacity and infrastructure rollout certainty to synchronise supply with feasible demand.  

The above thematic analysis is predominantly based on the CfE analysis. Section 3 of Annex 2 describes the 
limited data collection in the context of the OPC done in preparation of the Communication “Decarbonise 
Corporate Fleets”. This was mainly due to a high share of non-responses across many questions included in 
the OPC questionnaire.  

While a considerable number of replies (483) was submitted as feedback to the CfE, engagement of specific 
fleet categories was low across the whole stakeholder consultation activities. Many specific fleet categories 

32 

 
saw more than 60% of respondents either not answering or expressing no opinion, limiting the usefulness of 
disaggregated data. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This  section  summarises  the  main  expected  economic,  social  and  environmental  impacts  of  each  policy 
option. The assessment of impacts draws on multiple data sources125, including the targeted stakeholders’ 
consultation  and  open  public  consultation,  and  findings  from  desk  research.  The  proposed  options  are 
assumed to be implemented from 2029 onwards, so the assessment has been undertaken for the 2029-2050 
period and covers the EU Member States. Costs and benefits are expressed as present value over the 2029-
2050 period, using a 3% discount rate. All costs and benefits are expressed in 2023 prices.  

The main model used for developing the baseline scenario and assessing the impacts of the policy options is 
the PRIMES-TREMOVE transport model by E3-Modelling, a specific module of the PRIMES model. The 
PRIMES model has a successful record of use in the Commission's energy, transport and climate policy 
assessments. In particular, it has been used for the impact assessments underpinning the Communication on 
a  2040  climate  target126,  the  “Fit  for  55”  package  (e.g.  for  the  revision  of  the  EU  ETS  Directive,  the 
Alternative Fuels Infrastructure Regulation, the revision of the Regulation setting CO2 standards for cars and 
vans, the revision of the Renewable Energy Directive)127, the impact assessments accompanying the 2030 
Climate Target Plan128 and the Staff Working Document accompanying the Sustainable and Smart Mobility 
Strategy129, the Commission’s proposal for a Long Term Strategy130 as well as for the 2020 and 2030 EU’s 
climate and energy policy framework. It was also used for developing the baseline scenario underpinning the 
impact assessment accomanying the revision of the Clean Vehicles Directive in 2017131. 

The assumptions used for developing baseline scenarios that underpin impact assessments in the energy, 
transport and climate policy ares, are consulted regularly with Member States and other stakeholders in the 
context of the so-called Reference scenario process. The baseline scenario underpining this initiative builds 
on  the  work  on  the  EU  Reference  scenario  process  2025,  that  is  currently  ongoing.  In  this  context,  the 
PRIMES-TREMOVE  model  has  been  calibrated  on  the  latest  available  statistics.  The  macro-economic 
projections, the energy price projections and the technology assumptions have been consulted with Member 
States  during  a  meeting  of  the  Reference  scenario  expert  group  on  5  June  2024.  In  addition,  bilateral 
meetings with Member States took place between September 2024 and April 2025 to discuss the national 
policies to be reflected, based on the updated National Energy and Climate Plans prepared by the Member 
States under the Regulation 2018/1999 on the Governance of the Energy Union and Climate Action and 
submitted to the Commission during 2024-2025. 

The technology assumptions, that drive the magnitude of the impacts on costs and benefits, are based on a 
rigorous literature review carried out by E3-Modelling in collaboration with the JRC and building on studies 
conducted for the Commission and used in previous impact assessments on related topics132. Continuing the 
approach adopted in the long-term strategy in 2018 and for the Reference Scenario 2020, the Commission 
consulted  on  the  technology  assumptions  with  Member  States  and  stakeholders  in  2024.  In  particular, 
technology assumptions were discussed with Member States during a meeting of the Reference scenario 
expert group on 5 June 2024. They also benefited of a dedicated consultation workshop with stakeholders, 

125 Ricardo (2025), Support study on the impacts of an initiative on clean corporate vehicles 
126 EUR-Lex - 52024DC0063 - EN - EUR-Lex (europa.eu) 
127 Delivering the European Green Deal | European Commission (europa.eu) 
128 SWD(2020)176 final 
129 EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu)   
130 Source: 2050 long-term strategy (europa.eu)   
131 Register of Commission Documents - SWD(2017)366 
132 Sources include: ACEA, BloomberNEF, Goldman Sachs, ICCT, IEA, Ricardo, DEA, other scientific publications.  

33 

 
 
held on 22-23 October 2024. It should be noted that the technology assumptions consulted, including costs, 
refer to those related to vehicles but also power generation, production of fuels such as renewable fuels of 
non-biological origin (RFNBO) and biomass production pathways and costs. These assumptions, together 
with  the  policies  included  in  the  baseline  (e.g.  the  Renewable  Energy  Directive),  drive  the  evolution  of 
electricity and RFNBOs prices over the projection period. They also determine, together with the policies 
assumed, the magnitude of the impacts on capital and fuel costs in the baseline and in the policy options.  

The estimates of the total costs and benefits due to this initiative cannot be directly compared to projections 
of other impact assessments on similar topics (e.g. ETS2, Alternative Fuels Infrastructure Regulation, CO2 
standards for cars and vans, Clean Vehicles Directive etc). This is because the policy options of each of these 
impact assessments are different. However, it should be noted that over time (e.g. in 2020 at the time of the 
preparation  of  the  EU  Reference  scenario  2020133,  in  2023  at  the  time  of  the  preparation  of  the  impact 
assessment accompanying the 2040 climate target134 and more recently in 2024 in the context of the EU 
Reference  scenario  process  2025)  the  technology  costs  assumptions  have  been  updated  in  line  with  the 
market developments, accounting for lower technology costs for renewable and zero-emission technologies. 

The  modelling  captures  the  overall  adjustment  costs  and  adjustment  costs  savings  for  businesses  for  the 
implementation  of  the  targets.  However,  the  way  the  adjustment  costs  and  costs  savings  are  distributed 
among different operators within a Member State, and what potential further indirect impacts these might 
have, will depend on what national measures are put in place which is not known at this stage. Therefore, the 
uncertainty related to the distribution of the costs needs to be acknowledged. 

Further details on the methodological approach, together with results by stakeholder group for specific years 
and by Member State, are provided in Annex 4.  

6.1.  Economic impacts 

This section provides the economic impacts of the policy options on businesses,  citizens, national public 
authorities  and the  European  Environment  Agency  (EEA).  It  also provides  an assessment of impacts  on 
competitiveness, small and medium enterprises (SMEs), functioning of the internal market and competition, 
innovation, territorial impacts and digital by default.  

6.1.1.  Impacts on businesses 

This section describes the impacts on affected businesses, which primarily include road transport operators 
but  also  vehicle  manufacturers,  companies  making  use  of  transport  and  logistics  services  and  other 
businesses (i.e. buyers of goods transported by road). 

Impacts on new ZEV registrations. All policy options that set targets on new registrations of corporate 
vehicles  achieve  their  objectives  without  significantly  affecting  the  overall  level  of  ambition  the  CO2 
emission standards for vehicles set for vehicle manufacturers, as reflected in the baseline. For cars and vans, 
the interplay of corporate and private demand is relevant: in all policy options, the higher uptake of ZEV in 
new  registrations  by  large  companies  can  be  compensated  by  lower  uptake  by  SMEs  and  citizens  (i.e. 
private  buyers)  relative  to  the  baseline  until  2035,  so  that  manufacturers  do  not  exceed  their  emission 
reduction targets135.  

133 EU Reference Scenario 2020 - European Commission 
134 https://climate.ec.europa.eu/document/download/e1ae0c6c-aa6a-4757-9c27-
6f8bdc83bcb8_en?filename=policy_strategy_targets_2040ct_technology_assumptions.zip  
135 Vehicle manufacturers’ reaction to the increase in corporate demand for ZEVs coming from the policy options could be two-fold. 
They can keep their share of ZEVs in line with the CO2 emission performance targets, reducing the share of ZEV for citizens and 

34 

 
 
 
As shown in Table 11, the accelerated uptake of zero-emission cars and vans by large companies is highest 
in PO1C and PO2C (around 995,000 additional zero-emission cars in 2029 and 865,000 in 2030, relative to 
the baseline, and around 117,000 additional zero-emission vans in 2029 and 104,000 in 2030), due to the 
higher level of ambition of the targets for large companies in these policy options. From 2035 onwards, all 
new  light-duty  vehicles  (cars  and  vans)  must  achieve  zero  tailpipe  emissions,  due  to  the  CO2  emission 
standards, and thus there is no change in the number of new ZEV registrations relative to the baseline. By 
design, for cars and vans, the impacts of PO2A, PO2B and PO2C are similar to those of PO1A, PO1B and 
PO1C, respectively. For lorries, the targets on new ZEV registrations by large companies have the highest 
acceleration impact in PO1C (around 10,000 additional zero-emission lorries in 2029, 15,000 to 16,000 for 
2030-2035 and 6,000 in 2040), driven by the high ambition targets on new registrations. In PO2A, PO2B 
and  PO2C  the  impact  on  new  ZEV  registrations  is  higher  for  SMEs136  than  for  large  companies  as  the 
burden is shifted to sub-contractors of large companies (mostly SMEs). 

Table 11: Number of ZEV in new registrations by large companies in the policy options relative to the baseline (in 
thousand vehicles) 

Cars 
Vans 
Lorries 
Total 

2029 
493 
28 
3 
525 

PO1A 

2030 
533 
57 
8 
598 

2035 
0 
0 
8 
8 

PO2A 

PO1B 

2040 
0 
0 
6 
6 

2029 
824 
70 
6 
901 

2030 
693 
80 
12 
785 

2035 
0 
0 
12 
12 

2040 
0 
0 
6 
6 

PO2B 

2035 
0 
Cars 
0 
Vans 
15 
Lorries 
Total 
15 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

2040 
0 
0 
2 
2 

2029 
824 
70 
13 
907 

2030 
693 
80 
2 
775 

2035 
0 
0 
30 
30 

2030 
533 
57 
4 
595 

2029 
493 
28 
8 
529 

2040 
0 
0 
9 
9 

PO1C 

2030 
865 
104 
15 
984 

2035 
0 
0 
16 
16 

PO2C 

2030 
865 
104 
5 
973 

2035 
0 
0 
35 
35 

2040 
0 
0 
6 
6 

2040 
0 
0 
14 
14 

2029 
995 
117 
10 
1,122 

2029 
995 
117 
19 
1,132 

Impacts on second-hand ZEV markets. All policy options are expected to lead to higher uptake of ZEV 
in  the  second-hand  market,  thanks  to  the  shorter  initial  ownership  duration  and  faster  turnover  of  the 
corporate vehicles. The uptake of zero-emission second-hand cars and vans is higher in PO1C/PO2C (1.2 
million cars on average per year over 2031-2050 and 193,000 vans) and PO1B/PO2B (899,000 cars and 
145,000 vans) relative to PO1A/PO2A (595,000 cars and 104,000 vans), due to the higher number of new 
ZEV registered by large companies in these options that reach the second-hand market faster (see Table 12). 
For cars, the main group benefiting of the increase is that of citizens (although SMEs also benefit), while for 
vans that of SMEs137. For lorries, the impact is higher in PO2 (121,000 zero-emission lorries on average per 
year over 2031-2050 in PO2A, 159,000 in PO2B and 204,000 in PO2C) relative to PO1 (23,000 lorries in 
PO1A, 34,000 in PO1B and 48,000 in PO1C), due to the broader scope of targets covering large companies’ 
transport activities. The main stakeholder group benefiting is that of SMEs. The overall increase in the zero-

SME sales, or they could maintain the current share of ZEVs in those sales, leading to an overall increase in the share of ZEVs and 
higher emission savings than mandated by the CO2 emission performance standards. In the assessment of the impacts of the policy 
options, a conservative approach has been followed, assuming that the vehicle manufacturers do not increase the overall share of 
ZEVs in their new registrations. This is in line with the related CO2 standards impact assessment and does not carry any risk of a 
negative impact on the overall climate targets because the lower uptake of new ZEV by SMEs and citizens is compensated by a 
higher uptake of new ZEV by the large companies. In addition, as corporate vehicles typically have comparatively high yearly 
mileage, this increases their impact on real-world emissions reductions. 
136 For SMEs, in PO2A, around 22,000 additional zero-emission lorries are estimated for 2029 relative to the baseline, 
20,000 for 2030 and 22,000 for 2040; in PO2B, around 34,000 additional zero-emission lorries are estimated for 2029, 
28,000 for 2030 and 20,000 for 2040; in PO2C, around 50,000 additional zero-emission lorries are projected for 2029, 
41,000 for 2030 and 19,000 for 2040 relative to the baseline. 
137  See  section  4  of  Annex  4  for  more  detailed  results,  including  the  split  of  second-hand  cars  and  vans  between 
citizens, large companies and SMEs and for lorries between large companies and SMEs. 

35 

 
  
  
 
emission second-hand cars, vans and lorries is the highest in PO2C (1.6 million ZEV on average per year 
over 2031-2050), followed by PO1C (1.4 million ZEV), PO2B (1.2 million ZEV) and PO1B (1.1 million), 
while PO1A and PO2A result in lower uptake (721,000 in PO1A and 819,000 in PO2A).  

Table 12: Number of ZEV in second-hand ZEV markets in the policy options relative to the baseline, expressed as 
annual average over 2031-2050 (in thousand vehicles) 

Cars 
Vans 
Lorries 
Total 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO1C 
1,206 
193 
48 
1,448 

PO2A 
595 
104 
121 
819 

PO1A 
595 
104 
23 
721 

PO1B 
899 
145 
34 
1,078 

PO2B 
899 
145 
159 
1,203 

PO2C 
1,206 
193 
204 
1,604 

The increase in the zero-emission second-hand cars, vans and lorries, expressed as annual averages over a 
five-year period relative to the baseline, is provided in Table 13.  

Table 13: Number of ZEV in second-hand ZEV markets in the policy options relative to the baseline, expressed as 
annual averages over 2031-2035, 2036-2040, 2041-2045 and 2046-2050 (in thousand vehicles) 

PO1A 

PO1B 

PO1C 

'31-35 
461 
24 
4 
488 

'36-40 
1,078 
149 
18 
1,245 

'41-45 
688 
162 
28 
878 

'46-50 
152 
81 
40 
273 

'31-35 
715 
44 
6 
764 

'36-40 
1,621 
205 
29 
1,855 

'41-45 
1,027 
220 
45 
1,292 

'46-50 
234 
112 
56 
401 

'31-35 
885 
64 
9 
958 

'36-40 
2,180 
267 
41 
2,488 

'41-45 
1,431 
288 
65 
1,784 

Cars 
Vans 
Lorries 
Total 

PO2A 

PO2B 

'46-50 
152 
Cars 
81 
Vans 
196 
Lorries 
429 
Total 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

'46-50 
234 
112 
254 
599 

'31-35 
715 
44 
40 
798 

'36-40 
1,621 
205 
134 
1,960 

'41-45 
688 
162 
157 
1,007 

'31-35 
461 
24 
30 
514 

'41-45 
1,027 
220 
208 
1,455 

'36-40 
1,078 
149 
100 
1,327 

'31-35 
885 
64 
57 
1,006 

PO2C 

'36-40 
2,180 
267 
175 
2,622 

'41-45 
1,431 
288 
265 
1,985 

'46-50 
328 
154 
77 
559 

'46-50 
328 
154 
319 
802 

Impacts on the uptake of ZEV in the vehicle stock. All policy options are expected to result in overall 
higher uptake of ZEV in the vehicle stock due to the faster deployment of ZEV in the second-hand markets. 
For  cars  and  vans,  the  impact  is  more  pronounced  in  PO1C/PO2C  (around  1.1  million  additional  zero-
emission  cars  in  2030,  2.5  million  cars  in  2040  and  1.5  million  in  2050,  and  111,000  additional  zero-
emission vans in 2030, 358,000 vans in 2040 and 98,000 in 2050) than in PO1A/PO2A and PO1B/PO2B 
due to the higher ambition of the targets. For lorries, the uptake of ZEV in the stock is higher in PO2 relative 
to PO1 for all sub-options due to the broader scope of the targets138. Table 14 shows the increase in the 
number of ZEV in the total stock in the policy options relative to the baseline, of which the increase in the 
corporate vehicle stock. The reason for the lower increase in the zero-emission corporate cars in the stock 
post-2040 relative to the baseline is that by 2040 zero-emission cars already represent 85% of the corporate 
car stock in the baseline.  

Table 14: Number of ZEV in the vehicle stock in the policy options relative to the baseline (in thousand vehicles) 

Cars 

Corporate 

Vans 

Corporate 

PO1A 
2040 
1,019 
333 
182 
192 

2030 
477 
825 
37 
43 

2050 
606 
20 
47 
51 

2030 
852 
1,273 
75 
84 

PO1B 
2040 
1,698 
505 
262 
270 

2050 
1,018 
31 
67 
70 

2030 
1,084 
1,575 
111 
123 

PO1C 
2040 
2,531 
708 
358 
363 

2050 
1,541 
44 
98 
98 

138  See  section  4  of  Annex  4  for  more  detailed  results,  including  the  split  of  total  stock  for  cars  and  vans  between 
citizens, large companies and SMEs and for lorries between large companies and SMEs. 

36 

 
  
  
  
  
 
27 
PO2A 
2040 
1,019 
333 
182 
192 
205 

PO1A 
0.0 
0.0 
24.5 
7.4 
9.9 
7.1 
9.7 
32.9 
14.3 
10.5 
8.0 
17.8 
16.4 

Lorries 

3 

45 

6 

59 

9 

Cars 

Corporate 

2050 
1,018 
31 
67 
70 
332 
Lorries 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

2030 
852 
1,273 
75 
84 
77 

2030 
477 
825 
37 
43 
54 

2050 
606 
20 
47 
51 
267 

Corporate 

Vans 

2030 
1,084 
1,575 
111 
123 
115 

42 
PO2B 
2040 
1,698 
505 
262 
270 
269 

63 
PO2C 
2040 
2,531 
708 
358 
363 
338 

81 

2050 
1,541 
44 
98 
98 
407 

Impacts on costs and costs savings for businesses. PO2A, PO2B and PO2C are expected to result in one-
off  and  recurrent  administrative  costs  and  recurrent  enforcement  costs  for  businesses.  All  policy  options 
would  also  lead  to  adjustment  costs  and  adjustment  cost  savings,  as  well  as  to  changes  in  fuel  tax 
expenditures. Table 15 shows the recurrent and one-off costs and costs savings for businesses and Table 16 
the one-off costs and costs savings, expressed as present value over 2029-2050 relative to the baseline. Each 
category of costs and cost savings is discussed below.  

Table 15: Recurrent and one-off costs and cost savings for businesses in the policy options, expressed as present value 
over 2029-2050 relative to the baseline, in billion EUR (2023 prices) 

Administrative costs 
Enforcement costs 
Adjustment costs 
Capital costs 
Fuel costs 
Other operation costs 
Increase in tax expenditures 
Adjustment costs savings 
Capital costs savings 
Fuel costs savings 
Other operation costs savings 

PO1B 
0.0 
0.0 
32.7 
10.3 
12.4 
10.0 
12.3 
45.7 
19.6 
14.8 
11.3 
25.6 
26.3 

PO1C 
0.0 
0.0 
40.8 
13.4 
14.5 
12.9 
14.3 
59.2 
24.4 
19.9 
14.9 
34.6 
38.7 

PO2A 
41.36 
0.004 
36.6 
22.5 
9.8 
4.3 
5.4 
30.7 
8.8 
13.3 
8.6 
26.5 
-26.1 

PO2B 
41.35 
0.004 
47.9 
31.2 
11.6 
5.1 
6.3 
40.9 
11.9 
18.2 
10.8 
36.3 
-18.4 

PO2C 
41.35 
0.004 
61.7 
41.8 
13.1 
6.8 
6.8 
53.5 
14.9 
24.0 
14.6 
47.8 
-8.6 

Reduction in tax expenditures 
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

Table 16: One-off costs and cost savings for businesses in the policy options, expressed as present value over 2029-2050 
relative to the baseline, in billion EUR (2023 prices) 

Administrative costs 
Adjustment costs (capital costs) 
Adjustment costs savings (capital 
costs savings) 
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

10.9 

9.3 

6.9 

PO1B 
0.0 
10.3 
19.6 

PO1C 
0.0 
13.4 
24.4 

PO1A 
0.0 
7.4 
14.3 

PO2A 
0.06 
22.5 
8.8 

-13.7 

PO2B 
0.06 
31.2 
11.9 

PO2C 
0.06 
41.8 
14.9 

-19.4 

-27.0 

One-off and recurrent administrative costs for businesses. The options based on national targets (PO1A, 
PO1B, PO1C) are not expected to create administrative burden for businesses, as the reporting is done by 
Member States on the basis of existing national vehicle registers. The potential further indirect impacts these 
might have, will depend on what national measures are put in place. Member States that will make use of tax 
policy as the main instrument to achieve the targets will minimise potential indirect negative impacts for 
businesses. For example, adapting the fiscal and financial incentives for corporate fleets, which have proven 
very effective for Member States to rapidly increase the share of ZEVs in new corporate registrations, will 
not  result  in  additional  administrative  burden  for  businesses.  Similarly,  measures  to  reduce  operational 
constraints of ZEVs will not result in administrative burden for businesses. Even in the case where Member 
States  decide  to  set  mandatory  targets  for  businesses,  they  have  the  possibility  to  ensure  the  necessary 

37 

 
  
  
  
monitoring and reporting through existing national measures and reporting frameworks, for example in the 
context of taxation, so as to avoid the need to create dedicated reporting and minimise administrative burden. 
The targets set by France are an example of such measure. Because of national competence on taxation 
regimes,  setting  similar  targets  for  businesses  at  the  EU  level  would  result  in  significantly  higher 
administrative burden than at national level.  

In PO2A, PO2B and PO2C businesses will face administrative costs, both one-off and recurrent, since these 
policy  options  imply  a  new  reporting  activity  for  lorries.  Detailed  explanations  on  the  estimation  of  the 
administrative costs by Member State are provided in Annex 4 (section 3).  

One-off administrative costs  are expected for large companies in PO2A, PO2B and PO2C  for  extending 
their IT systems to include a relevant field to collect the required data from sub-contractors (i.e. tonne-km of 
activity performed and whether the lorry that performed it is a ZEV) and for updating the templates for the 
contracts with the sub-contractors performing transport activities on their behalf. On average, EUR 1,000 per 
large  company  is  assumed  to  be  needed  for  extending  the  IT  systems.  Considering  the  number  of  large 
companies (54,219) in industry, construction and market services in the EU139, the total one-off costs for the 
extension of their IT systems is estimated at EUR 54.22 million in 2029. In addition, half a day is expected 
to be needed per company to update the templates for the contracts with the sub-contractors. Assuming 7.2 
working  hours  per  day  on  average140  and  the  tariff  rates  by  Member  State  for  the  ISCO  3  category 
(technicians and associate professionals) in 2023 prices141, the total one-off costs for updating the templates 
for the contracts are estimated at EUR 6.24 million in 2029. Thus, the total one-off administrative costs for 
large companies in PO2A, PO2B and PO2C are estimated at EUR 60.46 million in 2029. 

Recurrent administrative costs are expected in PO2A, PO2B and PO2C for both large companies and SMEs 
for reporting the activity performed (i.e. tonne-km) and whether the lorry that performed it is a ZEV. As 
explained in section 5.2.3, most large companies perform a relatively low share of their road freight transport 
activity  through  own  fleets  and  generally  rely  on  sub-contracting  for  the  vast  majority  of  their  freight 
transport  needs142.  All  transport  companies,  including  SMEs,  that  directly  or  indirectly  provide  freight 
services by  lorry  to large companies  will need  to monitor  and  report their  activity in terms  of tonne-km 
performed by type of vehicle, in order to allow the large company to monitor and report compliance with its 
target to the national authorities.  

For large companies, it is assumed that one minute per lorry per working day is needed to report the type of 
vehicle  and  activity  performed  (i.e.  tonne-km)  for  the  lorries  that  they  own,  drawing  on  feedback  from 
targeted interviews. Considering the evolution of the number of lorries owned by large companies in each 
policy option143,  assuming 220  working days per  year  and  the tariff  rates  by  Member State  for  ISCO 8 
category (plant and machine operators, and assemblers) in 2023 prices144, the recurrent administrative costs 
are estimated at around EUR 22 to 26 million per year  in all sub-options (PO2A, PO2B and PO2C). In 
addition, 5 working days per year are assumed to be needed for collecting data from different parts of the 
company  and  from  sub-contractors,  quality-check,  validate,  and  submit  the  data  to  the  national  public 
authorities.  Using  the  tariff  rates  by  Member  State  for  ISCO  3  category  (technicians  and  associate 
professionals) in 2023 prices and the number of large companies, the recurrent costs for collecting the data 
from  different  parts  of  the  company  are  estimated  at  EUR  62.43  million  per  year  in  PO2A,  PO2B  and 
PO2C.  

139 Source: Eurostat. Enterprise statistics by size class and NACE Rev. 2 activity [sbs_sc_ovw]  
140 Actual and usual hours of work - Statistics Explained - Eurostat 
141 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.  
142 Typically, above 80% according to industry representatives. 
143 Based on PRIMES-TREMOVE model results.  
144 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.  

38 

 
 
For sub-contractors of large companies, based on  interviews with industry representatives, 5 minutes  per 
working day per lorry are assumed to be needed to report the type of vehicle and activity performed (i.e. 
tonne-km). Considering the tariff rates by Member State for ISCO 8 category (plant and machine operators, 
and assemblers), the recurrent administrative costs for sub-contractors of large companies are estimated at 
around EUR 2.28 billion in 2029 and 2030, EUR 2.46 billion in 2040 and EUR 2.55 billion in 2050 in 
PO2A, PO2B and PO2C.  

Total recurrent administrative costs for businesses (for large companies and SMEs) are estimated at around 
EUR 2.37 billion in 2029 and 2030, EUR 2.55 billion in 2040 and EUR 2.63 billion in 2050 for PO2A, 
PO2B and PO2C. Expressed as present value over 2029-2050, they are estimated at around EUR 41.29 
billion  in  PO2A,  PO2B  and  PO2C,  of  which  EUR  32.13  billion  for  SMEs.  Overall,  total  one-off  and 
recurrent administrative costs for businesses are estimated at EUR 41.36 billion in PO2A and EUR 41.35 
billion in PO2B and PO2C, expressed as present value over 2029-2050, of which EUR 32.13 billion for 
SMEs in PO2A, PO2B and PO2C.  

Recurrent enforcement costs are only expected in PO2A, PO2B and PO2C for cooperating with authorities 
for  verifying  the  correctness  of  companies’  reporting.  One  percent  of  large  companies  is  assumed  to  be 
checked per year on average and the check per company is assumed to take 2 working days. Using the tariff 
rates by Member State for the ISCO 3 category (technicians and associate professionals), the total recurrent 
enforcement costs are estimated at EUR 0.25 million per year or EUR 4.1 million expressed as present value 
over 2029-2050. Details on the enforcement costs by Member State are provided in Annex 4 (section 3). 

One-off  and  recurrent  adjustment  costs  and  costs  savings  for  businesses.  In  all  policy  options,  the 
businesses  within  the  scope  will  face  one-off  and  recurrent  adjustment  costs  (i.e.  one-off  capital  costs, 
recurrent fuel costs and other recurrent operation costs) and adjustment cost savings (i.e. one-off capital costs 
savings, recurrent fuel costs savings and other recurrent operation costs savings) as a result of the targets. 
However,  the  level  and  distribution  of  those  costs  and  cost  savings  differs  between  options.  Details  on 
adjustment costs and costs savings for specific years are provided in Annex 4 (section 5) while details on 
costs by Member State are provided in Annex 4 (section 7). 

In PO1A, PO1B and PO1C the demand of new zero-emission vehicles by large companies is expected to 
increase relative to the baseline (see Table 11). This is projected to result in higher capital costs for large 
companies relative to the baseline, but at the same time also in fuel costs savings (due to electrification) and 
other operation costs savings. The higher uptake of ZEV in the second-hand market (see Table 12 and Table 
13), thanks to  the  shorter initial ownership  duration and  faster turnover of  the corporate  vehicles,  would 
result in capital costs savings (due to the lower cost of second-hand vehicles), fuel costs savings and other 
operation costs savings. In addition, depending on how vehicle manufacturers respond to  the increase in 
demand for new ZEV, different indirect impacts can be expected. The increased demand for new ZEVs by 
large companies might lead to an increase in the total share of ZEVs in new registrations. Alternatively, 
vehicle manufacturers might keep the total share of ZEV relatively unchanged compared to the baseline, by 
reducing the offer of ZEVs in new registrations by SMEs. In this latter case, this might result in reduced 
availability of ZEVs for SMEs and an increase of fuel and other operation costs compared to the baseline, 
because of the higher share of new conventional vehicles bought by SMEs relative to the baseline. These 
costs may  be  lower  if  vehicle  manufacturers  decided  to increase the  overall  share  of  ZEVs in their  new 
registrations. In the assessment of the options, it is conservatively assumed that manufacturers do not exceed 
their emission reduction targets relative to the baseline and in the short to medium term SMEs favour new 
conventional  vehicles  to  new  ZEV.  This  results  in  lower  capital  costs  and  higher  fuel  costs  and  other 
operation costs relative to the baseline. At the same time, SMEs would benefit of the higher uptake of ZEV 
in the second-hand market, as explained above.   

The adjustment costs and costs savings in PO1A, PO1B and PO1C reflect the combined effects described 
above. Total adjustment costs are estimated at EUR 24.5 billion in PO1A, EUR 32.7 billion in PO1B and 

39 

 
EUR  40.8  billion  in  PO1C  (see  Table  15),  expressed  as  present  value  over  2029-2050  relative  to  the 
baseline. Around 30% of these adjustment costs in each option (30% in PO1A, 31% in PO1B and 33% in 
PO1C) are capital costs associated to the uptake of new ZEV by large companies. Fuel costs, related to the 
uptake of new conventional vehicles by SMEs, represent around 40% of adjustment costs in PO1A, 38% in 
PO1B and 35% in PO1C, while other operation costs represent another 29% of total adjustment costs in 
PO1A, 30% in PO1B and 32% in PO1C. Total adjustment costs savings are projected to overcompensate 
the adjustment costs, and are estimated at EUR 32.9 billion in PO1A, EUR 45.7 billion in PO1B and EUR 
59.2 billion in PO1C (see Table 15), expressed as present value over 2029-2050 relative to the baseline. 
Capital costs savings, due to the uptake of new conventional vehicles by SMEs and higher uptake of second-
hand  ZEV  relative  to  the  baseline,  represent  around  40%  of  the  total  adjustment  costs  savings  (44%  in 
PO1A, 43% in PO1B and 41% in PO1C). As explained above, the higher uptake of new ZEV by large 
companies  and  the  higher  uptake  of  second-hand  ZEV  (mostly  by  SMEs)  results  in  fuel  costs  savings 
estimated at EUR 10.5 billion in PO1A, EUR 14.8 billion in PO1B and EUR 19.9 billion in PO1C (32% of 
the total adjustment costs savings in PO1A and PO1B and 34% in PO1C)145. Other operation costs savings 
due  to  the  higher  uptake  of  new  ZEV  by  large  companies  and  second-hand  ZEV,  mostly  by  SMEs, 
represent another 24% of the total adjustment costs savings in PO1A and 25% in PO1B and PO1C.       

In PO1A, PO1B and PO1C the modelling assumes that the targets at Member State level in terms of share of 
ZEV in new registrations of corporate cars, vans, and lorries by large companies in their territory during that 
year  are  met146.  The  modelling  captures  the  overall  adjustment  costs  and  adjustment  costs  savings  for 
businesses for the implementation of the targets. However, the way the adjustment costs and costs savings 
are distributed among different operators within a Member State, and what potential further indirect impacts 
these might have, will depend on what national measures are put in place. Therefore, the uncertainty related 
to the distribution of the costs needs to be acknowledged. Member States that will make use of tax policy as 
the main instrument to achieve the targets will minimise potential indirect negative impacts for businesses. If 
Member States decide to put in place mandatory targets for specific operators or fleet types, on the other 
hand, this can lead to higher risk of indirect impacts for those operators, for example in terms of favouring 
one type of operation over another (e.g. leasing over purchase, or ride-hailing platforms over ride-hailing 
companies  with  ownership  of  their  vehicle  fleet).  Even  in  the  case  of  Member  States  deciding  to  set 
mandatory targets for specific types of companies or fleets, however, the risk of this kind of potential indirect 
and  unexpected  impacts  can  be  considered  lower  than  for  target  setting  at  European  level.  National 
authorities have a better understanding of the fleets operating on their territory, as the complexity is lower 
and information and data are more easily available, and they can make full use of existing monitoring and 

145  Electricity  prices  play  a  role  in  the  monetisation  of  the  net  fuel  costs  savings.  Building  on  the  common  baseline 
scenario,  sensitivity  analysis  on  the  electricity  prices  for  2030  performed  in  the  context  of  the  impact  assessment 
accompanying the revision of the CO2 standards for cars and vans, shows that in comparison to conventional vehicles, 
the total cost of ownership for battery electric cars and vans over a 5-year use period remains lower than that for same-
segment conventional vehicles, for all segments and user perspectives - in the range of electricity price analysed. This 
means  that  the  battery  electric  vehicles  remain  the  least-cost  option  in  terms  of  total  cost  of  ownership  from  2030 
onwards  and  costs  savings  due  to  their  higher  uptake  are  still  expected  to  materialise,  even  under  the  assumption  of 
higher electricity prices. 
146 As modelling technique, a shadow value is used in the model to meet the constraint in terms of share of ZEV in new 
registrations of cars, vans and lorries, while also meeting the CO2 standards for new light-duty and heavy-duty vehicles. 
This  shadow value reflects  measures  that  are  not  specifically  identified  at  this  stage.  The  impacts  on  costs  and  costs 
savings are driven directly by the uptake of ZEV in new registrations. The total cost of ownership encompasses capital 
costs,  fixed  and  variable  operation  costs.  However,  purchase  decisions  are  also  influenced  by  factors  such  as  range 
anxiety  and  shadow  values  (i.e.  non-payable  financial  penalties  or  incentives  representing  measures  to  ensure 
compliance with targets). These shadow values differ across actors because they are defined separately for each target 
type, namely the required share of ZEV in new registrations and the CO₂ standards for manufacturers of light-duty and 
heavy-duty vehicles. This differentiation, combined with differences in variable costs, shapes the choices of corporate 
fleets and other agents. Moreover, differences in variable costs also drive corporate and non-corporate actors to diverge 
in their use-phase decisions.       

40 

 
 
reporting  schemes  –  for  example  in  the  context  of  their  fiscal  system  –  to  minimise  the  additional 
administrative burden.   

In most use cases, the TCO of ZEVs is either already competitive with that of conventional vehicles, or only 
slightly higher – although the initial high investment cost remains a key barrier. In general, ZEVs present a 
higher  initial  purchase  cost,  which  can  be  partly  or  totally  compensated  by  lower  operational  costs. 
However, in cases where they cannot fully meet the specific operational requirements of a given fleet, the 
operational costs may increase – for example because the vehicle has reduced time in operation because of 
the need to recharge – which may decrease the competitiveness of their TCO. In cases where the TCO is still 
higher  than  that  of  conventional  vehicles,  Member  States  intervention  can  help  make  it  competitive  by 
reducing  initial  purchase  costs  (e.g.  through  financial  incentives  such  as  scrappage  schemes  or  financial 
support to new purchase), or operation costs either directly (e.g. through reduced annual vehicle taxation) or 
by ensuring better enabling conditions (e.g. ensuring availability of dedicated recharging points for specific 
fleets at key locations, such as fast chargers for rental fleets at airports) that will allow a more efficient use of 
corporate ZEVs. When such measures are in place and result in the TCO of ZEVs being competitive with 
that of conventional vehicles, fleet operators are generally expected to switch to ZEVs. Given the highly 
competitive  nature  of  the  road  transport  market,  and  the  low  margins  of  most  operators,  once  the  first 
movers start benefiting from the resulting lower TCO of ZEVs, their competitors will rapidly follow to avoid 
the risk of losing important market shares.  By requiring Member States to ensure a certain share of ZEVs in 
new  corporate  registrations  by large  companies, the initiative  will  therefore  encourage  them  to introduce 
changes  in  the  design  of  financial  and  fiscal  incentives;  the  effectiveness  of  such  measures  has  been 
demonstrated by recent examples of Belgium and Germany, and PO1A, PO1B and PO1C are expected to 
lead to other Member Stats taking comparable steps. 

In PO2A, PO2B and PO2C the impacts on adjustment costs and costs savings for businesses owning cars 
and vans are the same as in PO1A, PO1B and PO1C, respectively. They however differ significantly for 
lorries, with adjustment costs estimated at EUR 36.6 billion in PO2A, EUR 47.9 billion in PO2B and EUR 
61.7 billion in PO2C and adjustment costs savings of EUR 30.7 billion in PO2A, EUR 40.9 billion in PO2B 
and EUR 53.5 billion in PO2C (see Table 15), expressed as present value relative to the baseline. Under 
these options, road freight transport operators are effectively required to ensure that a certain share of their 
lorries are ZEVs, in order to be able to continue providing transport services to large companies subject to 
the obligations. Because the target is set based on transport activity – as opposed to new registrations – it 
effectively translates in a requirement for a share in the vehicle stock, leading both to a comparatively higher 
share of ZEV in overall new registrations as well as in a push for earlier fleet renewal. While this is expected 
to lead to higher fuel costs savings (EUR 13.3 billion in PO2A, EUR 18.2 billion in PO2B and EUR 24 
billion in PO2C), the initial capital costs are also more significant than in PO1 (EUR 22.5 billion in PO2A, 
EUR 31.2 billion in PO2B and EUR 41.8 billion in PO2C).  

Especially  for  SMEs  –  which  constitute  more  than  99%  of  road  transport  operators  –  access  to  finance 
required for such initial investment can represent a significant barrier, as banks price high risk premiums for 
debt  finance  of  zero-emission  lorries  in  view  of  the  nascent  status  of  the  market  and  the  lack  of  wide 
recharging infrastructure. In some cases, inability to secure financing for the switch to ZEV or the higher 
costs of financing compared to larger competitors may result in a SME losing important clients in favour of 
larger  operators,  leading  to  a  consolidation  of  the  road  freight  transport  market.  This  impact  could  be 
softened by measures taken by large shippers to support SME sub-contractors147, or by complementary tax 
relief measures in Member States.   

147 For example, some large shippers set up specific funds to support their SME contractors with the higher purchase 
cost of ZEV in the early phase of market growth, noting though that such measures would be time-limited.  

41 

 
 
In some cases, in order for a shipper to meet its target, road transport operators will be required to use ZEVs 
even in use cases where their TCO is still higher than that of diesel lorries. If the resulting additional costs 
are reflected in the transport service contract and either taken on by the shipper or passed on to the final 
customer in the form of an increase in the price of the transported goods, this will not significantly impact 
the transport operator. If the shipper is not ready to pay a higher price, however, the costs will be passed on 
to the road transport operator, effectively increasing their operation costs and reducing their profit margin. 

Changes  in  fuel  tax  expenditures  for  businesses  are  projected  in  all  policy  options  (see  Table  15).  As 
explained  above,  the  higher  uptake  of  new  ZEV  by  large  companies  and  second-hand  ZEV,  mostly  by 
SMEs, are expected to result in fuel costs savings and a reduction in the fuel tax expenditures (EUR 17.8 to 
34.6  billion  in  PO1  and  EUR  26.5  to  47.8  billion  in  PO2).  At  the  same  time,  the  increase  in  the  new 
conventional vehicles by SMEs in the short to medium term in PO1A, PO1B and PO1C and for cars and 
vans in PO2A, PO2B and PO2C is projected to result in some higher fuel costs and an increase in the fuel 
tax expenditures (EUR 9.7 to 14.3 billion in PO1 and EUR 5.4 to 6.8 billion in PO2)148.  

Net  benefits/costs  for  businesses.  PO1A,  PO1B  and  PO1C  are  expected  to  result  in  net  benefits  for 
businesses in the scope. The highest benefits are estimated for PO1C (EUR 38.7 billion), followed by PO1B 
(EUR 26.3 billion) and PO1A (EUR 16.4 billion), expressed as present value over 2029-2050. On the other 
hand, PO2A, PO2B and PO2C are expected to result in net costs (EUR 26.1 billion in PO2A, EUR 18.4 
billion in PO2B and EUR 8.6 billion in PO2C), mainly due to the administrative costs.         

Other impacts on vehicle manufacturers. Vehicle manufacturers are not directly impacted by PO1. While 
they are not directly targeted under PO2 either, they are among the large companies included in its scope, as 
vehicle manufacturers also command significant volumes of shipped goods. As such they are subject to the 
targets and impacted in a similar way to other large companies. At the same time, all options will provide 
indirect benefits to vehicle manufacturers. In order to comply with the emission reduction targets set in the 
CO2 emission performance standards for light- and heavy-duty vehicles, manufacturers need to ensure that a 
certain share of the new vehicles they register every year is zero-emission. By ensuring a minimum level of 
demand for such vehicles from the corporate sector, all options will reduce individual manufacturers’ risk of 
not  meeting  their  targets,  while  at  the  same  time  creating  greater  certainty  and  better  conditions  for 
investment in ZEV manufacturing capacity. This is particularly relevant for manufacturers of lorries, which 
have to meet ambitious CO2 standards for heavy-duty vehicles in 2030, but where the market is less mature 
compared  to  cars  and  also  vans.  While  vehicle  manufacturers  will  benefit  from  improved  demand  for 
corporate  ZEVs  and  greater  certainty  allowing  better  planning  of  investments  in  ZEV  manufacturing 
capacity, EU vehicle manufacturers might miss part of these benefits as a result of competition from third 
country manufacturers. This risk is less pronounced on the market for lorries, where EU manufacturer have 
clearer  advantages  and  higher  market  shares,  while  on  the  cars  and  vans  market  competition  with  third 
countries is stronger. In the car market, EU manufacturers have a comparatively stronger presence in the 
corporate than in the private market. Individual manufacturers will benefit differently depending on their 
respective market position and role in various segments of the automotive market, and how exposed they are 
to direct competition from third countries, but also how broad the presence of those competitors in different 
markets  and  how  strong  the  brand  loyalty  of  fleet  managers.  These  differences  are  reflected  in 
manufacturers’ answers to the CfE and to the targeted stakeholder consultation.  

Other impacts on businesses that are not directly targeted by the proposal. Other businesses that are not 
directly targeted by the proposal – either because they are not active in transport or because they are not 

148 The changes in fuel tax expenditures relative to the baseline are driven by changes in fuel costs. Excise duty rates 
and other tax incentives are kept unchanged relative to the baseline. This is because it is not possible to anticipate the 
type of measures that Member States would put in place under PO1 and for cars and vans under PO2.  

42 

 
 
within the scope of the policy options – will still be indirectly impacted by changes in the prices of goods 
transported by road resulting from the different options.  

The policy options that do not set a mandatory target for individual companies (PO1A, PO1B, PO1C) are 
not expected to bring further impacts on services and goods, as individual companies will retain the ability to 
choose whether and how to switch to ZEV in accordance with their use case and business plan. Meeting the 
targets under these options will largely be done by companies with use cases where the TCO of ZEVs is 
competitive with that of conventional vehicles.  

On the other hand, PO2A, PO2B and PO2C will require all large companies to ensure a minimum share of 
ZEV in the freight transport services performed on their behalf. This means that, in some cases, shippers will 
have to use or require their hauliers to use ZEVs even in use cases where their TCO is still higher than that of 
diesel  lorries,  leading  to  an  overall  increase  in  their  logistics  costs.  The  way  these  additional  costs  are 
distributed  between  the  shippers,  hauliers,  and  final  customers  will  depend  on  the  choices  of  individual 
shippers,  as  described  above.  This  type  of  impact  and  its  distribution  among  different  actors  cannot  be 
adequately captured in modelling, but a recent market assessment estimated that shippers requiring hauliers 
to use ZEVs could face up to a 30% increase in their freight costs in the short term, which in turn would 
translate in a price increase of the transported products of up to 3%, unless large shippers at least partially 
absorbed the higher transport costs in their profit margin149. Given that all large shippers would be faced 
with the same increase in costs, however, their incentive to absorb the costs in their profit margin would be 
limited.   

6.1.2.  Impacts on citizens  

None of the options  are expected to  have direct impacts on citizens,  as they all target corporate vehicles 
purchased  and  used by legal  entities.  However,  all options  are projected  to  have  indirect impacts  on  the 
market for private cars and vans150 – both new and second-hand – and some of the options (PO2A, PO2B 
and PO2C) are also expected to have an indirect impact on the availability and price of services and goods 
that citizens rely on.  

The market for new zero-emission private cars and vans, while not targeted by any of the options, will be 
indirectly impacted by all of them. Under all options, the demand for zero-emission cars and vans by large 
companies is expected to increase relative to the baseline. As explained in section 6.1.1, depending on how 
vehicle manufacturers respond to this increase in demand, different indirect impacts can be expected. The 
increased demand for ZEVs by large companies might lead to an increase in the total share of ZEVs in new 
registrations. Alternatively, vehicle manufacturers might keep the total share of ZEV unchanged relative to 
the baseline, by reducing the offer of ZEVs in new registrations by citizens (and SMEs). In this latter case, 
this might result in an increase of fuel and other operation costs compared to the baseline, because of the 
higher share of new conventional vehicles bought by citizens relative to the baseline. These costs may be 
lower if vehicle manufacturers decided to increase the overall share of ZEVs in their new registration. In the 
assessment  of  the  options,  it  is  conservatively  assumed  that  manufacturers  do  not  exceed  their  emission 
reduction targets relative to the baseline and in the short to medium term citizens favour new conventional 
vehicles to new ZEV. This results in lower capital costs and higher fuel costs, other operation costs and fuel 
tax expenditures relative to the baseline for citizens purchasing new vehicles; these impacts are more likely 
to affect citizens from higher income groups, as they generally have a higher share of new cars151.    

149 https://www.transportenvironment.org/articles/buying-electric-shippers-to-zero-emission-trucking  
150 Around 10% of the vans are owned by citizens according to the Dataforce database.  
151  Gautam,  P.;  Pode,  G.;  Pode,  R.;  Ayetor,  G.K.;  Diouf,  B.  Depreciation  in  the  Electric  Vehicle  Transition: 
2044–2074. 
Second-Hand  Electric  Vehicle  Market.  Vehicles 
Sustainability 

2024, 

the 

of 

6, 

43 

 
 
 
On the other hand, the different options are also expected to have impacts on the second-hand car market, on 
which many citizens152 rely for the purchase of their cars. A faster increase in the share of ZEV in corporate 
fleets, and in particular in those with a fast turnover such as rental car fleets is expected to result in higher 
uptake  of  second-hand  ZEV  by  citizens  and  fuel  costs  and  other  operation  costs  savings  relative  to  the 
baseline, as well as a reduction in the fuel tax expenditures. Since lower income groups are more likely to 
purchase used cars compared to the population average153, they are expected to proportionally benefit more 
from reduction in fuel expenditures coming from a higher availability of zero-emission used cars. 

Citizens represent a significant share of car leasing and rental companies’ clients. For both of these markets, 
the fuel costs are incurred by the client, while the vehicle’s purchase cost and residual value only affect the 
vehicle  owner.  This  means  that  an  increase  in  the  share  of  ZEVs  offered  on  these  markets  will  lead  to 
benefits to citizens in terms of overall fuel cost savings when renting or leasing a vehicle, under all options. 
This  is  because  ZEVs  are  more  energy  efficient  than  conventional  vehicles.  However,  large  rental  and 
leasing  companies  would be  faced  with  the  increased  purchase  cost  of  new  ZEV  and  with uncertainties 
about their residual value, and they are likely to pass through at least part of these costs to their clients, so 
that these fuel savings are likely to be at least partly offset by an increase in the leasing and rental prices.  

Table  17  presents  the  one-off  and  recurrent  costs  and  costs  savings  for  citizens  in  the  policy  options, 
expressed  as  present  value  over  2029-2050  relative to  the baseline154.  The  highest  one-off  and  recurrent 
adjustment  costs  savings  but  also  adjustment  costs  are  projected  in  PO1C  and  PO2C  (EUR  7  billion 
adjustment costs savings and EUR 10.3 billion adjustment costs), due to their higher level of ambition of the 
targets,  followed  by  PO1B  and  PO2B  (EUR  4  billion  adjustment  costs  savings  and  EUR  7.8  billion 
adjustment  costs),  and  PO1A  and  PO2A  (EUR  2.2  billion  adjustment  costs  savings  and  EUR  6  billion 
adjustment costs). This is also the case of changes in fuel tax expenditures, with PO1C and PO2C resulting 
in EUR 4.6 billion reduction and EUR 4.7 billion increase in fuel tax expenditures relative to the baseline155.  

All options result in net costs for citizens, with the lowest net costs in PO1C and PO2C (EUR 3.4 billion 
expressed as present value over 2029-2050), followed by PO1B/PO2B (EUR 6 billion) and PO1A/PO2A 
(EUR 6.9 billion). 

Table 17: Recurrent and one-off costs and cost savings for citizens in the policy options, expressed as present value over 
2029-2050 relative to the baseline, in billion EUR (2023 prices) 
PO1B 
7.8 
0.6 
3.3 
3.9 

Adjustment costs 
Capital costs 
Fuel costs 
Other operation costs 

PO2A 
6.0 
0.6 
2.8 
2.5 

PO2C 
10.3 
0.7 
3.6 
6.0 

PO1C 
10.3 
0.7 
3.6 
6.0 

PO1A 
6.0 
0.6 
2.8 
2.5 

PO2B 
7.8 
0.6 
3.3 
3.9 

https://www.mdpi.com/2624-8921/6/4/101; Kris Vanherle (TML), Robert Vergeer (CE), “Data gathering and analysis 
to improve the understanding of 2nd hand car and LDV markets and implications for the cost effectiveness and social 
equity of LDV CO2 regulations”, Final Report for DG CLIMA, 2 May 2016   
152  Across  the four  largest EU markets  (France  26%,  Germany 34%,  Italy  37%,  Spain  31%),  new  cars  accounted on 
average for around one-third of total annual car sales over the last 15 years—implying the used market is roughly twice 
the size of the new market. European Commission JRC, A review of the used car market in the European Union (2025)  
153 Kris Vanherle (TML), Robert Vergeer (CE), “Data gathering and analysis to improve the understanding of 2nd hand 
car  and  LDV  markets  and  implications  for  the  cost  effectiveness  and  social  equity  of  LDV  CO2  regulations”,  Final 
Report  for  DG  CLIMA,  2  May  2016;  Gautam,  P.;  Pode,  G.;  Pode,  R.;  Ayetor,  G.K.;  Diouf,  B.  Depreciation  in  the 
Electric Vehicle Transition: Sustainability of the Second-Hand Electric Vehicle Market. Vehicles 2024, 6, 2044–2074. 
https://www.mdpi.com/2624-8921/6/4/101  
154 The costs and costs savings for individual years are presented in Annex 4 (section 5) and those by Member State in 
Annex 4 (section 7). 
155 The changes in fuel tax expenditures relative to the baseline are driven by changes in fuel costs.  Excise duty rates 
and other tax incentives are kept unchanged relative to the baseline.  

44 

 
  
 
Increase in tax expenditures 
Adjustment costs savings 
Capital costs savings 
Fuel costs savings 
Other operation costs savings 

PO1A 
3.8 
2.2 
1.7 
0.1 
0.3 
0.6 
-6.9 

PO1B 
4.3 
4.0 
2.4 
1.4 
0.3 
2.1 
-6.0 

PO1C 
4.7 
7.0 
3.1 
3.6 
0.2 
4.6 
-3.4 

PO2A 
3.8 
2.2 
1.7 
0.1 
0.3 
0.6 
-6.9 

PO2B 
4.3 
4.0 
2.4 
1.4 
0.3 
2.1 
-6.0 

PO2C 
4.7 
7.0 
3.1 
3.6 
0.2 
4.6 
-3.4 

Reduction in tax expenditures 
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

Table 18: One-off costs and costs savings for citizens in the policy options, expressed as present value over 2029-2050 
relative to the baseline, in billion EUR (2023 prices) 

Adjustment costs (capital costs) 
Adjustment costs savings (capital 
costs savings) 
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

1.8 

2.5 

1.1 

1.1 

PO1B 
0.6 
2.4 

PO1C 
0.7 
3.1 

PO2A 
0.6 
1.7 

PO1A 
0.6 
1.7 

PO2B 
0.6 
2.4 

PO2C 
0.7 
3.1 

1.8 

2.5 

It should however be noted that although citizens are expected to experience overall net costs, expressed as 
present value over 2029-2050 relative to the baseline, in the medium to longer term in PO1B/PO2B and 
PO1C/PO2C they actually experience net benefits, due to the higher ZEV uptake in the second-hand market. 
In addition, the net costs in the first years of implementation are very limited and estimated at up to EUR 4.8 
per vehicle in PO1C/PO2C, up to EUR 4 per vehicle in PO1B/PO2B and up to EUR 3.1 per vehicle in 
PO1A/PO2A.    

Table 19: Net benefits (+) or net costs (-) for citizens per vehicle in 2030, 2040 and 2050156, relative to the baseline, in 
EUR (2023 prices) 

PO1A/PO2A 

PO1B/PO2B 

PO1C/PO2C 

2030 

2040 

2050 

2030 

2040 

2050 

2030 

2040 

2050 

Net benefits (+) or net costs (-) 

-3.1 

0.9 

-0.4 

-4.0 

2.6 

0.7 

-4.8 

5.5 

2.0 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

Citizens  will  also  be  affected  by  changes  in  the  prices  of  goods  transported  by  road,  similar  to  other 
businesses as described in section 6.1.1 above. The actual impact will depend on how the additional costs are 
distributed between shippers, hauliers, and consumers, but as noted for small businesses, recent publications 
estimate that shippers’ mandate as included in PO2A, PO2B and PO2C could translate into a price increase 
of the transported products unless large shippers at least partially absorb the higher transport costs in their 
profit  margin157.  These  impacts  are  not  expected  for the  other  policy options  (PO1A, PO1B, PO1C), as 
individual companies will retain the ability to switch to ZEV  first in those use cases where their TCO is 
competitive with that of conventional vehicles.  

6.1.3.  Impacts on national public authorities 

One-off and recurrent administrative costs for national public authorities. For PO1A, PO1B and PO1C 
monitoring and reporting on the targets will be ensured directly by the Member States, by extracting the 
relevant data from their vehicle registries and submitting it yearly to the Commission. This is also the case of 
cars  and  vans  under  PO2A,  PO2B  and  PO2C.  While  Member  States  are  already  able  to  differentiate 

156 Net benefits/costs per vehicle are derived by dividing the total net benefits/costs for a specific year by  the private 
vehicle stock in that specific year and policy option, drawing on the PRIMES-TREMOVE results.  
157  Transport  and  Environment  estimates 
https://www.transportenvironment.org/articles/buying-electric-shippers-to-zero-emission-trucking  

this  would  amount 

increase  of  up 

to  a  price 

to  3% 

that 

45 

 
  
  
  
 
corporate  from  private  vehicles  in their  registry, the  exclusion  of  corporate  vehicles  registered  by SMEs 
would require a one-off adaptation of Member States’ registries.  

One-off administrative costs for national public authorities in all policy options are derived assuming an 
effort of 0.2 full time equivalents per Member State for adapting the vehicle registers158. Considering 220 
working days per year and 7.2 working hours per day on average159, and using the tariff rate per hour by 
Member State for the ISCO 3 category (technicians and associate professionals) in 2023 prices160, the total 
one-off  costs  for  public  authorities  at  EU  level  are  estimated  at  EUR  0.23  million  in  2029  in  all  policy 
options.  

Recurrent administrative costs for national public authorities. In PO1A, PO1B and PO1C Member States 
are  expected to  spend  2 working  days  per year  for  extracting,  validating,  and  submitting  the  data to the 
Commission/EEA.  Considering  7.2  working  hours  per  day  on  average  and  the  tariff  rate  per  hour  by 
Member State for the ISCO 3 category (technicians and associate professionals), the recurrent administrative 
costs are estimated at EUR 10,350 per year at EU level. Expressed as present value over 2029-2050 they 
amount to EUR 0.17 million relative to the baseline.  

In  PO2A,  PO2B  and  PO2C,  for  cars  and  vans  the  reporting  is  the  same  as  in  PO1.  For  lorries,  public 
authorities will be required to compile reports from all large companies established on their territory and 
submit them yearly to the Commission. Around 3.5 hours would be needed to receive, quality-check and 
collate information from each one of the reporting companies. In addition, 3 working days would be needed 
per year to compile all information (for cars, vans and lorries), validate, and submit it to the Commission. 
The total recurrent administrative costs for reporting are estimated at EUR 6.09 million per year. Expressed 
as present value over 2029-2050 they amount to EUR 99.89 million relative to the baseline. Furthermore, 
monitoring enforcement will be performed based on sample verification of the correctness of companies’ 
reporting. One percent of large companies is assumed to be checked per year on average and the check per 
company is assumed to take 2 working days, with total costs for monitoring enforcement estimated at EUR 
0.25 million per year, or EUR 4.1 million expressed as present value over 2029-2050. 

Total recurrent administrative costs for public authorities are thus estimated at EUR 10,350 per year at EU 
level for PO1A, PO1B and PO1C and at EUR 6.33 million per year in PO2A, PO2B and PO2C. Expressed 
as present value over 2029-2050 they are estimated at EUR 0.17 million in PO1A, PO1B and PO1C and at 
EUR 103.99 million for PO2A, PO2B and PO2C relative to the baseline.  

Impacts on energy tax revenues for national public authorities. In the baseline scenario the energy tax 
revenues from cars, vans and lorries are projected to decrease from EUR 189.3 billion in 2029 to EUR 54.2 
billion in 2050, driven by the higher uptake of ZEV over time. On one hand, due to the assumed shift from 
new ZEVs to new conventional vehicles in the short to medium term by citizens and SMEs, some additional 
tax revenues are expected relative to the baseline due to an increase in fossil fuel use (EUR 13.5 to 18.9 
billion  in  PO1  and  EUR  9.2  to  11.5  billion  in  PO2)161.  This  is  however  overcompensated  in  all  policy 
options by losses in tax revenues (EUR 18.4 billion to 39.1 billion in PO1 and EUR 27.1 billion to 52.4 
billion in PO2), due to the uptake of new ZEV by large companies (and SMEs in PO2A, PO2B and PO2C) 

158  This  draws  on  the  assumptions  for  adding  new  data  to  the  vehicle  register  used  in  the  impact  assessment 
accompanying the revision of the Roadworthiness Package (SWD(2025) 96 final/2). 
159 Actual and usual hours of work - Statistics Explained - Eurostat 
160 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.  
161 As explained above, in the assessment of the options it is conservatively assumed that manufacturers do not exceed 
their emission reduction targets relative to the baseline and in the short to medium term citizens and SMEs favour new 
conventional  vehicles  to  new  ZEV.  This  is  expected  to  lead  to  some  increase  in  the  fossil  fuel  use  and  energy  tax 
revenues relative to the baseline. However, in net terms, fossil fuel consumption reduces in all policy options relative to 
the baseline due to higher uptake of new ZEV by large companies (and SMEs in PO2A, PO2B and PO2C).   

46 

 
 
and the larger deployment of ZEV in the second-hand market, that results in fossil fuel savings. The impact 
is the highest in PO2C (EUR 52.4 billion) due to its high level of ambition and higher scope.   

All policy options result in net costs for national public authorities (EUR 41 billion in PO2C, followed by 
PO2B with EUR 27.9 billion, PO1C with EUR 20.2 billion, PO2A with EUR 18.1 billion, PO1B with EUR 
11.1 billion and PO1A with EUR 4.9 billion), expressed as present value over 2029-2050. It should however 
be noted that the net costs for national public authorities represent less than 0.02% of the projected EU GDP 
for  2030  and  2040  in  the  baseline,  as  shown  in  Annex  4  (section  7).  This  is  similar  for  the  entire  time 
horizon. 

Table 20: Recurrent and one-off costs and cost savings for national public authorities in the policy options, expressed as 
present value over 2029-2050 relative to the baseline, in billion EUR (2023 prices) 

Administrative costs 
For reporting 
For monitoring enforcement 

PO1A 
0.00 
0.00 

PO1B 
0.00 
0.00 

PO1C 
0.00 
0.00 

Losses in tax revenues 
Additional tax revenues 
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

39.1 
18.9 
-20.2 

27.7 
16.6 
-11.1 

18.4 
13.5 
-4.9 

PO2A 
0.104 
0.100 
0.004 
27.1 
9.2 
-18.1 

PO2B 
0.104 
0.100 
0.004 
38.4 
10.6 
-27.9 

PO2C 
0.104 
0.100 
0.004 
52.4 
11.5 
-41.0 

Table 21: One-off costs for national public authorities in the policy options, expressed as present value over 2029-2050 
relative to the baseline, in million EUR (2023 prices) 

Administrative costs  
Source: Ricardo (2025), Support study 

PO1A 
0.23 

PO1B 
0.23 

PO1C 
0.23 

PO2A 
0.23 

PO2B 
0.23 

PO2C 
0.23 

The  recent  examples  of  Belgium,  Germany,  Poland  and  Portugal  have  demonstrated  the  capacity  of 
Member States to set up effective measures to incentivise demand for zero-emission vehicles. Because the 
national targets are modulated based on GDP per capita and the current share of ZEVs in new registrations, 
they will be set at the same level for Member States with similar starting conditions.  

6.1.4.  Impacts on the European Environment Agency 

Under all options, Member States will be required to submit reports; these will be set in the framework of 
the central register for CO2 standards for vehicles that is maintained by EEA. The EEA will face limited 
one-off and recurrent administrative costs to expand and manage the database under all options. In PO1A, 
PO1B and PO1C the one-off costs are estimated at EUR 25,000 in 2029 and the recurrent administrative 
costs  at EUR  28,831  (0.25  full  time  equivalent  at AD5 level)  per  year.  Expressed  as  present  value over 
2029-2050, the recurrent costs are estimated at EUR 0.44 million and the total one-off and recurrent costs at 
EUR 0.47 million. In PO2A, PO2B and PO2C the one-off costs are estimated at EUR 50,000 in 2029 and 
the recurrent administrative costs at EUR 57,662 (0.5 full time equivalent at AD5 level) per year. Expressed 
as present value over 2029-2050, the recurrent costs are estimated at EUR 0.89 million and the total one-off 
and recurrent costs at EUR 0.94 million. 

6.1.5.  Impacts on competitiveness 

The policy options have different impacts on the cost competitiveness of affected businesses. Overall, as 
shown in section 6.1.1, PO1A, PO1B and PO1C are expected to result in net benefits for businesses. The 
highest  benefits  are  estimated  for  PO1C  (EUR  38.7 billion),  followed  by PO1B  (EUR  26.3  billion)  and 
PO1A (EUR 16.4 billion), expressed as present value over 2029-2050. On the other hand, PO2A, PO2B and 
PO2C are expected to result in net costs (EUR 26.1 billion in PO2A, EUR 18.4 billion in PO2B and EUR 
8.6 billion in PO2C), partly due to the administrative costs for reporting on the compliance with the targets 
(EUR 41.36 billion in PO2A and EUR 41.35 billion in PO2B and PO2C) that fall mostly on SMEs as sub-

47 

 
  
 
 
 
  
contractors  of  large  companies  (EUR  32.13  billion  in  PO2A,  PO2B  and  PO2C).  Large  businesses  are 
expected to increase their cost competitiveness in all policy options as shown in Table 22, with the highest 
net benefits projected in PO1C (EUR 59.2 billion), followed by PO1B (EUR 45 billion) and PO2C (EUR 
40.8 billion). In particular, those with diversified fleets and easier access to capital are better placed to absorb 
upfront investment costs and benefit from lower operation costs. 

Under PO1A, PO1B and PO1C, the directly affected actors include large road transport operators and other 
large businesses owning vehicles. Companies already using or well positioned to use ZEVs are expected to 
become more competitive, due to improved framework conditions for using these vehicles. Lower fuel costs 
(e.g. particularly when it is possible to recharge in own depots with electricity from own photovoltaic or 
other forms of electricity generation) and other operation costs will strengthen the cost competitiveness of 
large companies despite the higher upfront cost for the ZEV purchase, as shown in Table 22.  

While PO1 and PO2 do not differ in their effects on cars and vans,  under PO2A, PO2B and PO2C the 
binding  mandates  for  zero-emission  lorry  use  in  large  companies’  transport  activities  mean  that  a  larger 
share of companies operating lorries would be required to buy and operate ZEVs even though their market 
and business model is not currently well-suited for their use162. All large companies would incur additional 
administrative costs for reporting on the use of zero-emission trucks. Lower fuel costs and other operation 
costs will strengthen the cost competitiveness of large companies despite the higher upfront cost for the ZEV 
purchase, as shown in the  Table 22. However, the burden  is expected to be shifted on sub-contractors – 
mostly SMEs. The impacts on SMEs are discussed in section 6.1.6. 

Table 22: Recurrent and one-off costs and cost savings for large companies in the policy options, expressed as present 
value over 2029-2050 relative to the baseline, in billion EUR (2023 prices) 

Administrative costs 
Enforcement costs 
Adjustment costs 
Capital costs 
Fuel costs 
Other operation costs 
Increase in tax expenditures 
Adjustment costs savings 
Capital costs savings 
Fuel costs savings 
Other operation costs savings 

PO1A 
0.0 
0.0 
8.3 
6.4 
0.2 
1.7 
0.0 
23.4 
7.2 
9.2 
7.0 
16.9 
32.0 

PO1B 
0.0 
0.0 
11.9 
9.3 
0.2 
2.3 
0.0 
32.7 
9.7 
12.9 
10.1 
24.1 
45.0 

PO1C 
0.0 
0.0 
15.6 
12.4 
0.2 
3.0 
0.0 
42.9 
12.2 
17.3 
13.4 
32.0 
59.2 

PO2A 
9.2 
0.004 
6.5 
1.9 
2.0 
2.5 
0.2 
18.1 
7.2 
7.8 
3.1 
13.4 
15.6 

PO2B 
9.2 
0.004 
8.5 
3.7 
2.0 
2.7 
0.1 
25.8 
9.7 
11.5 
4.6 
20.4 
28.4 

PO2C 
9.2 
0.004 
11.7 
5.6 
2.5 
3.6 
0.1 
34.2 
12.2 
15.8 
6.2 
27.6 
40.8 

Reduction in tax expenditures 
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

Table  23:  One-off  costs  and  cost  savings  for  SMEs  in  the  policy  options,  expressed  as  present  value  over  2029-2050 
relative to the baseline, in billion EUR (2023 prices) 

Administrative costs 
Adjustment costs (capital costs) 
Adjustment costs savings (capital 
costs savings) 

PO1A 
0.0 
6.4 
7.2 

PO1B 
0.0 
9.3 
9.7 

PO1C 
0.0 
12.4 
12.2 

PO2A 
0.06 
1.9 
7.2 

PO2B 
0.06 
3.7 
9.7 

PO2C 
0.06 
5.6 
12.2 

162 For example, some companies performing specialised transport such as some long-distance refrigerated transport or 
transport  of  chemicals,  or  primarily  operating  long-distance  transport  in  specific  remote  areas  where  the  recharging 
infrastructure  coverage  is  not  yet  sufficient  to  meet  their  needs,  or  companies  that  are  not  yet  able  to  secure  the 
necessary grid connection for depot charging options that meet their operational requirements. 

48 

 
  
  
 
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO1A 
0.8 

PO1B 
0.4 

PO1C 
-0.2 

PO2A 
5.2 

PO2B 
6.0 

PO2C 
6.6 

Policies boosting ZEV uptake have been a key driver for investments in zero-emission technologies. During 
2017-2018,  when  ambitious  policies  for  the  uptake  of  electric  vehicles  were  implemented  in  China, 
investments in e-mobility were reported to be seven times higher in China (EUR 21.7 billion) than in the EU 
(EUR 3.2 billion). In 2019, with the forthcoming CO2 standards for 2020 at the time, the EU attracted large 
investments (around EUR 60 billion) in electric vehicles and batteries, nearly 20 times more than in 2017-
2018 and 3.5 times more than in China163. Clear regulatory signals sent to the automotive industry have 
therefore proven to be crucial for delivering and boosting timely investment decisions in electric vehicles.  

The automotive industry is expected to benefit in both PO1 and PO2. The competitiveness of the European 
automotive industry has weakened over the past decade, with business profitability dropping from 7.4% in 
2017 to 5.1% in 2023164. Regaining competitiveness, especially in the highly dynamic segment of ZEVs, 
will require significant investments. This is particularly relevant in a context where the sector is undergoing 
rapid technological transformation and where global competition in ZEV markets is intensifying (already in 
2025  every  fourth  vehicle  worldwide  sold  was  electric).The  initiative  provides  greater  certainty  and 
facilitates planning of the necessary investments in ZEV production capacity, innovation, and supply chains 
strengthens the competitive position of EU automotive industry by increasing predictability and long-term 
demand visibility. A stronger and more predictable domestic market directly strengthens the international 
positioning of the EU automotive industry. 

The initiative also improves the functioning of the internal market by fostering a more integrated EU-wide 
market  for  ZEVs.  By  accelerating  ZEV  uptake  in  corporate  fleets,  the  initiative  supports  market  scale 
effects,  strengthens  economies  of  scale  in  production  and  reduces  market  fragmentation  arising  from 
heterogenous national fleet electrification dynamics. This in turn improves cross-border market integration 
and reduces the risk that national markets develop at diverging speeds, thereby contributing to a more level 
playing field among manufacturers and operators across Member States. 

In addition, the initiative contributes to technological diffusion and learning effects. Wider deployment of 
ZEVs in corporate fleets and their subsequent entry into the second-hand market increases exposure to ZEV 
technologies  across  different  regions  and  operational  contexts.  This  in  turn  accelerates  user  acceptance, 
improves operational knowledge and supports innovation, especially in segments where the uptake of ZEVs 
remains low. 

Furthermore,  higher  and  more  predictable  corporate  demand  for  ZEVs  will  help  vehicle  manufacturers 
achieve  their  CO₂  emission  performance  targets  and  improve  capacity  utilisation,  while  also  providing 
greater investment certainty in ZEV production lines. 

The international competitiveness of larger companies is expected to increase, as lower fuel costs and other 
operation costs over the lifetime of the ZEV fleet will impact positively the cost structure of the companies 
and free resources. Importantly, the increased competitiveness of automotive manufacturers due to a more 
predictable planning of the transition to ZEVs will also benefit their ability to better position themselves in 
competitive global markets for ZEVs.  

163 Impact Assessment accompanying the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND 
OF THE COUNCIL amending Regulation (EU) 2019/631 as regards strengthening the CO2 emission performance 
standards for new passenger cars and new light commercial vehicles in line with the Union’s increased climate 
ambition 
164 European automotive industry: What it takes to regain competitiveness, McKinsey, 10 March 2025. 

49 

 
  
 
6.1.6.  Impacts on small and medium enterprises (SMEs) 

The SME check has been performed and is presented in Annex 6. SMEs are not directly affected by PO1. 
However, assuming that vehicle manufacturers maintain the minimum share of ZEVs in new registrations 
required  to  meet  their  emission  reduction  targets  under  the  CO2  emission  performance  standards,  the 
increased demand for new ZEVs by large companies will reduce the availability of new ZEVs for SMEs. 
This in  turn  would  result in  lower  capital  costs  and higher  fuel  and  other  operation  costs  in the short  to 
medium term compared to the baseline, due to the higher share of new conventional vehicles bought by 
SMEs (which have higher fuel costs per kilometre). Actual costs may be lower if vehicle manufacturers 
voluntarily increase the overall share of ZEVs in their new registrations. At the same time, the faster increase 
in the share of ZEVs in corporate fleets, particularly in fleets with high turnover such as rental car fleets, is 
expected to accelerate the uptake of second-hand ZEV for SMEs. This would lead to fuel costs and other 
operation costs savings for SMEs relative to the baseline. Overall, PO1A would result in net costs of EUR 
15.6 billion expressed as present value over 2029-2050, PO1B to net costs of EUR 18.7 billion and PO1C to 
net costs of EUR 20.5 billion.  

In  PO2,  the  targets  for  shippers  will  indirectly  affect  SMEs,  which  represent  the  majority  of  operators 
providing freight transport services to large companies. To comply with the targets, shippers will require 
their  sub-contractors  to  provide  a  share  of  their  services  using  ZEVs.  SMEs  providing  freight  transport 
services to large companies will therefore face higher capital costs, which may pose serious barrier in terms 
of  access  to  finance,  alongside  reductions  in  fuel  and  operational  costs.  In  addition,  due  to  the  need  to 
monitor and report activity in tonne-km for individual vehicles with sub-contracting arrangements, affected 
SMEs would face substantial administrative costs, estimated at EUR 32.1 billion in present value over 2029-
2050. Overall, PO2 is expected to result in significantly  higher net costs than PO1 (EUR 41.7 billion  in 
PO2A, EUR 46.8 billion in PO2B and EUR 49.4 billion in PO2C, expressed as present value over 2029-
2050 relative to the baseline).  

Table 24: Recurrent and one-off costs and cost savings for SMEs in the policy options, expressed as present value over 
2029-2050 relative to the baseline, in billion EUR (2023 prices) 
PO1B 
0.0 
20.9 
1.0 
12.2 
7.7 
12.2 
12.9 
9.9 
1.9 
1.2 
1.5 
-18.7 

Administrative costs 
Adjustment costs 
Capital costs 
Fuel costs 
Other operation costs 
Increase in tax expenditures 
Adjustment costs savings 
Capital costs savings 
Fuel costs savings 
Other operation costs savings 

Reduction in tax expenditures 
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO2C 
32.1 
50.0 
36.3 
10.6 
3.1 
6.8 
19.2 
2.7 
8.2 
8.4 
20.2 
-49.4 

PO2A 
32.1 
30.1 
20.6 
7.8 
1.8 
5.2 
12.6 
1.6 
5.6 
5.5 
13.1 
-41.7 

PO1A 
0.0 
16.1 
1.0 
9.7 
5.4 
9.7 
9.5 
7.1 
1.3 
1.0 
0.8 
-15.6 

PO1C 
0.0 
25.2 
1.0 
14.3 
9.9 
14.3 
16.3 
12.2 
2.6 
1.5 
2.6 
-20.5 

PO2B 
32.1 
39.4 
27.4 
9.6 
2.4 
6.2 
15.1 
2.1 
6.7 
6.3 
15.9 
-46.8 

Table  25:  One-off  costs  and  cost  savings  for  SMEs  in  the  policy  options,  expressed  as  present  value  over  2029-2050 
relative to the baseline, in billion EUR (2023 prices) 

Adjustment costs (capital costs) 
Adjustment costs savings (capital 
costs savings) 

PO1A 
1.0 
7.1 

PO1B 
1.0 
9.9 

PO1C 
1.0 
12.2 

PO2A 
20.6 
1.6 

PO2B 
27.4 
2.1 

PO2C 
36.3 
2.7 

50 

 
  
  
Net benefits (+) or net costs (-) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO1A 
6.1 

PO1B 
8.9 

PO1C 
11.2 

PO2A 
-19.0 

PO2B 
-25.3 

PO2C 
-33.6 

It should however be noted that although SMEs are expected to experience overall net costs, expressed as 
present value over 2029-2050 relative to the baseline, in the medium to longer term in PO1B/PO2B and 
PO1C/PO2C they are projected to experience net benefits, due to the higher ZEV uptake in the second-hand 
market. In addition, the net costs are estimated at up to EUR 83.8 per vehicle per year in PO2C, up to EUR 
73.7 per vehicle per year in PO2B and up to EUR 63.1 per vehicle per year in PO2A. For PO1A, PO1B and 
PO1C the costs per vehicle are projected to be lower (up to EUR 21.1 in PO1A, EUR 29.6 in PO1B and 
EUR 38.5 in PO1C per vehicle per year).   

Table 26: Net benefits (+) or net costs (-) for SMEs per vehicle in 2030, 2040 and 2050165, relative to the baseline, in 
EUR (2023 prices) 

Net benefits (+) or net costs (-) 

PO1A 

PO1B 

PO1C 

2030 

-21.1 

2040 

2050 

-3.0 

3.7 

2030 

-29.6 

2040 

2050 

2030 

2040 

2050 

1.9 

3.4 

-38.5 

9.9 

3.7 

PO2A 

PO2B 

PO2C 

2030 

2040 

2050 

2030 

2040 

2050 

2030 

2040 

2050 

Net benefits (+) or net costs (-) 

-63.1 

-32.3 

-10.1 

-73.7 

-30.5 

-7.8 

-83.8 

-24.7 

-3.6 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

6.1.7.  Impact on the functioning of the internal market and competition 

Impacts  on  the  functioning  of the  internal  market  and  competition  have been  assessed qualitatively.  The 
policy options are expected to have a positive impact on the functioning of the internal market. All policy 
options  contribute  to  a  positive  development  of  EU  corporate  fleet  markets,  by  increasing  the  spread  of 
ZEVs across all markets, including second-hand markets, and by creating an environment that supports the 
implementation  of  transition  strategies  of  EU  automotive  manufacturers.  The  faster  uptake  of  ZEV  in 
second-hand markets (see Table 12 in section 6.1.1) is expected to improve the functioning of the internal 
market by increasing the availability of affordable second-hand vehicles to citizens and SMEs across the 
Union. The positive impacts on the second-hand market are expected to be the highest in PO2C (1.6 million 
additional ZEV on average per year over 2031-2050 relative to the baseline), followed by PO1C (1.4 million 
ZEV), PO2B (1.2 million ZEV) and PO1B (1.1 million), while PO1A and PO2A result in lower uptake 
(721,000 in PO1A and 819,000 in PO2A). The targets are also expected to support achieving the objectives 
of other existing instruments under the transport acquis, such as road charging and the exemption for ZEVs 
under the revised Eurovignette Directive, thereby enhancing the coherence of the internal transport market. 
In addition, any national support measures for the implementation of the policy options will be assessed 
under  the  State  aid  rules,  if  applicable  (e.g.  the  General  Block  Exemption  Regulation  or  the 
Climate, Energy and Environmental Aid Guidelines). 

All policy options are expected to create a better level playing field and competition among large companies, 
facilitated by the requirement for all Member States to establish improved enabling conditions for the uptake 
of zero-emission corporate vehicles. 

6.1.8.  Impacts on innovation and technological development 

All options will have a positive impact on innovation and technological development. By stimulating the 

165 Net benefits/costs per vehicle are derived by dividing the total net benefits/costs for a specific year by  the vehicle 
stock owned by SMEs in that specific year and policy option, drawing on the PRIMES-TREMOVE results.  

51 

 
  
  
  
 
deployment  of  zero-emission  technologies  in  new  corporate  vehicle  registrations,  they  create  long-term 
demand  certainty  and  establish  a  more  stable  environment  for  vehicle  manufacturers  to  invest  in  ZEV 
innovation and technological development. While innovation in technologies for road transport vehicles is 
primarily  driven  by  the  CO2  emission  performance standards,  the  options  will  play  a  supporting  role  by 
stimulating  demand  in  specific  corporate  fleets  use  cases  and  by  incentivising  the  deployment  of  ZEV 
models suited to their operational requirements. The wider deployment of ZEVs in the second-hand vehicle 
markets is also expected to increase their visibility in markets with currently low market penetration rates 
and  to  enhance  understanding  of  ZEV  use  across  a  broader  range  of  operational  contexts.  This  broader 
exposure is likely to provide additional impetus for technological development, particularly in the case of 
lorries.  The positive impacts  on innovation  and  technological development  are  expected to  be  highest in 
PO1C and PO2C, due to the highest impacts on the ZEV corporate fleets and second-hand market, followed 
by PO1B and PO2B, and PO1A and PO2A.  

6.1.9.  Territorial impacts 

There is no inherent bias (positive or negative) of the proposed options towards specific regions or territories 
of the EU. Differences in economic capacity and ZEV market readiness and maturity across Member States 
are addressed through the modulation of the national targets for cars and vans under PO1 and PO2. Targets 
for lorries under both PO1 and PO2 are uniform across Member State. This prevents potential unintended 
territorial impacts, where different targets might create incentives to register a vehicle used for cross-border 
freight  transport  in  a  different  Member  State  for  avoidance  purposes.  The  shares  of  different  types  of 
corporate fleets – as well as the share of private and corporate cars – vary across Member States, typically 
due to differences in national fiscal measures, which may lead to some differences in scope and impacts 
across  Member  States.  Due  to  the  structure  of  the  cross-border  second-hand  vehicle  market,  the  faster 
availability of ZEVs on the second-hand market is expected to bring slightly higher benefits to Eastern and 
Southern Member States under all options, with the highest positive impacts in PO1C and PO2C (due to the 
higher positive impact on the ZEV second-hand market), followed by PO1B and PO2B, and PO1A and 
PO2A.        

6.1.10. Digital by default 

All  policy  options  are  expected  to  have  a  positive  impact  on  the  application  of  the  ‘digital  by  default’ 
principle, as the reporting activities by Member States will be facilitated through the extension of the central 
register on CO2 standards for vehicles, maintained by European Environment Agency.  

6.2.  Social impacts 

This section describes the impacts on health, employment and fundamental rights. 

6.2.1.  Impacts on health 

All options are expected to have positive impacts on the health of the citizens, due to the decrease in air 
pollutant emissions (NOx and PM2.5) resulting from the replacement of conventional vehicles with zero-
emission vehicles, thereby decreasing the health impacts of ambient air pollution. Noise emissions are also 
expected  to  slightly  decrease,  as  a  greater  share  of  vehicle  activity  shifts  to  zero-emissions  vehicles. 
Overall, the external costs savings related to air pollutant emissions and noise are estimated at EUR 1.9 
billion in PO2C, followed by PO1C and PO2B (EUR 1.2 billion), PO1B (EUR 0.7 billion), PO2A (EUR 
0.6  billion),  and  PO1A  (EUR  0.3  billion)  expressed  as  present  value  over  2029-2050  relative  to  the 
baseline (see Table 27).  

52 

 
 
Table  27:  External  costs  savings  of  air  pollution  and  noise  emissions  in  the  policy options, expressed as present 
value over 2029-2050 relative to the baseline, in billion EUR (2023 prices) 

Air pollution emissions 
Noise emissions 
Air pollution and noise emissions 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO1A 
0.2 
0.1 
0.3 

PO1B 
0.5 
0.2 
0.7 

PO1C 
0.8 
0.4 
1.2 

PO2A 
0.2 
0.4 
0.6 

PO2B 
0.5 
0.7 
1.2 

PO2C 
1.0 
1.0 
1.9 

6.2.2.  Impacts on employment 

None  of  the  options  are  expected  to  have  significant  impacts  on  the  level  of  employment.  There  is  no 
measurable  change  in  the  level  of  activity  performed  by  corporate  vehicles  and  their  operators;  vehicle 
manufacturers are expected to balance the increased demand for ZEV in corporate fleets with a lower share 
in private registrations, so that the overall market share of ZEVs and conventional vehicles are not expected 
to  change  significantly,  meaning  that  there  are  no  measurable  changes  in  the  automotive  supply  chain 
deriving from any of the options. The business operation of corporate fleets is also not expected to change 
substantially under any of the options, so that no option will result in measurable changes in employment in 
the road transport sector either. 

6.2.3.  Impacts on fundamental rights 

The policy options were assessed to determine if they have an impact on the fundamental rights and/or equal 
treatment of EU citizens. The starting point of the assessment of the fundamental rights is the Charter of 
Fundamental  Rights  of  the  European  Union166.  All  policy  options  were  assessed  having  regard  to  the 
relevant EU instrument and it was concluded that they maintain full respect for human and fundamental 
rights, and none will have any negative impact thereon.  

6.3.  Environmental impacts 

The  analysis  of  environmental  impacts  covers  impacts  on  fossil  fuel  consumption,  CO2  emissions,  air 
pollutant emissions and noise emissions. 

Impacts on fossil fuel consumption. All options result in a decrease in the fossil fuel consumption with the 
highest impacts identified for PO2C due to the high ambition of the target and broader scope of this option. 
The decrease in the fossil fuel consumption is a consequence of the higher uptake of the ZEV in the fleet. In 
cumulative  terms  over  2029-2050,  relative  to  the  baseline,  the  fossil  fuel  consumption  is  expected  to 
decrease by 3.4 to 14.6 million of tonnes of oil equivalent (Mtoe) in PO1 (3.4 Mtoe in PO1A, 8 Mtoe in 
PO1B and 14.6 Mtoe in PO1C) and by 15.8 to 35.3 Mtoe in PO2 (15.8 Mtoe in PO2A, 24.2 Mtoe in PO2B 
and 35.3 Mtoe in PO2C). The impacts for specific years are provided in Annex 4 (section 4).  

Table  28:  Cumulative  impacts  on  fossil  fuel  consumption  over  2029-2050  in  the  policy  options  relative  to  the 
baseline (in million tonnes of oil equivalent and % change to the baseline) 
PO1C 
-14.6 
-0.8% 

Fossil fuel (Mtoe) 
% change to baseline 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO2C 
-35.3 
-1.9% 

PO1A 
-3.4 
-0.2% 

PO2A 
-15.8 
-0.9% 

PO2B 
-24.2 
-1.3% 

PO1B 
-8.0 
-0.4% 

Impacts on CO2 emissions, air pollutants and noise. All options are also expected to result in savings in 
CO2 emissions and air pollutant emissions, as well as the external costs of noise emissions. PO2C shows the 
highest impact due to the higher uptake of ZEV in this option. In cumulative terms over 2029-2050, relative 
to the baseline, the CO2 emissions savings are estimated at 10 to 43.4 million tonnes (Mt) in PO1 and at 48 

166 https://commission.europa.eu/aid-development-cooperation-fundamental-rights/your-rights-eu/eu-charter-
fundamental-rights_en  

53 

 
  
  
 
to 107.1 Mt in PO2. For NOx, the cumulative savings over 2029-2050 are estimated at 15 to 40.2 thousand 
tonnes (kt) for PO1 and 20.5 to 63.3 kt for PO2. For particulate matter (PM2.5) emissions, the cumulative 
savings over 2029-2050 relative to the baseline are projected at 0.3 to 1.6 kt in PO1 and 0.6 to 2.4 kt in PO2. 
The impacts for specific years are provided in Annex 4 (section 4). 

Table 29: Cumulative impacts on CO2 emissions and air pollution emissions over 2029-2050 in the policy options 
relative to the baseline (in thousand tonnes and % change to the baseline) 
PO1A 
-9,983.9 
-0.2% 
-15.0 
-0.2% 
-0.3 
-0.1% 

PO2A 
-47,999.2 
CO2 emissions (kt) 
-0.9% 
% change to baseline 
-20.5 
NOx emissions (kt) 
-0.3% 
% change to baseline 
-0.6 
PM2.5 emissions (kt) 
% change to baseline 
-0.1% 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO2C 
-107,105.5 
-1.9% 
-63.3 
-0.9% 
-2.4 
-0.5% 

PO1B 
-23,693.1 
-0.4% 
-25.0 
-0.3% 
-0.8 
-0.2% 

PO1C 
-43,392.1 
-0.8% 
-40.2 
-0.6% 
-1.6 
-0.3% 

PO2B 
-73,546.4 
-1.3% 
-37.0 
-0.5% 
-1.3 
-0.3% 

The savings in external costs of CO2 emissions,  for each policy option relative to the baseline, expressed as 
present value over 2029-2050, are estimated at EUR 1.6 to 6.8 billion in PO1 (EUR 1.6 billion in PO1A, 
EUR 3.7 billion in PO1B and EUR 6.8 billion in PO1C) and at EUR 7.8 to 16.9 billion in PO2 (EUR 7.8 
billion in PO2A, EUR 11.7 billion in PO2B and EUR 16.9 billion in PO1C). The impacts for specific years 
are provided in Annex 4 (section 4). 

Table 30: External costs savings of CO2 emissions in the policy options, expressed as present value over 2029-2050 
relative to the baseline, in billion EUR (2023 prices) 

CO2 emissions  
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO1A 
1.6 

PO1B 
3.7 

PO1C 
6.8 

PO2A 
7.8 

PO2B 
11.7 

PO2C 
16.9 

For air pollution and noise emissions, the savings in external costs expressed as present value over 2029-
2050 relative to the baseline, are provided in Table 27 and those for individual years in Annex 4 (section 4).  

Regarding  the  impact  on  biodiversity,  it  is  considered  that  the  reduction  of  NOx  emissions  from  road 
transport may also have positive impact on the health of ecosystems, due to their reduced indirect exposure 
related to chronic accumulation of nitrogen. This impact, while established in various studies and reviews167, 
was however not analysed and quantified for this initiative since it is expected to be indirect and limited.  

All policy options are consistent with the environmental objectives of the European Green Deal (though 
contributing to these objectives at varying degrees as outlined above) and the European Climate Law168. All 
policy  options  contribute  towards  Sustainable  Development  Goals  SDG 3  and  indirectly support SDG  3 
‘Ensure healthy lives and promote well-being for all at all ages’. No significant harm is expected on the 
environment in any of the policy options. 

The table below provides a summary of the comparison of the options against the baseline scenario in terms 
of economic, social and environmental impacts. The following ranking symbols have been used: from ‘0’ 
(no impact relative to the baseline), to '+' (more positive than the baseline) and '+++' (much more positive 
than the baseline), and from '-' (less positive than the baseline) to '---' (much less positive than the baseline). 

167  Ricardo  (Ricardo-AEA),  2016.  The  ecological  effects  of  air  pollution  from  road  transport:  an  updated  review 
(NECR199) 
168 Regulation (EU) 2021/1119 

54 

 
  
  
 
Table 31: Summary of economic, social and environmental impacts of options relative to the baseline 

PO1A 

PO1B 

PO1C 

PO2A 

PO2B 

PO2C 

Economic impacts  
Businesses  
Net benefits (+) / net costs (-) for 
businesses (in EUR billion, expressed as 
present value over 2029-2050 relative to 
the baseline) 
Citizens  
Net costs (-) for citizens (in EUR 
billion, expressed as present value over 
2029-2050 relative to the baseline) 
Net benefits (+) / net costs (-) for 
citizens (in EUR per vehicle, in 2030 
and 2040 relative to the baseline) 

National public authorities  
Net costs (-) for national authorities (in 
EUR billion, expressed as present value 
over 2029-2050 relative to the baseline) 
Net costs (-) for national authorities 
relative to the baseline (% of projected 
GDP in 2030 and 2040) 

European Environmental Agency 
(EEA) 
Net costs (-) for EEA (in EUR million, 
expressed as present value over 2029-
2050 relative to the baseline) 
Impacts on competitiveness 
SMEs 
Net costs (-) for SMEs (in EUR billion, 
expressed as present value over 2029-
2050 relative to the baseline) 
Net benefits (+) / net costs (-) for SMEs 
(in EUR per vehicle, in 2030 and 2040 
relative to the baseline) 

Impacts on the functioning of the 
internal market and competition 
Impacts on innovation and 
technological development 
Territorial impacts 
Digital by default 
Social impacts 
Impacts on health 
External costs savings related to air 
pollution and noise emissions (in EUR 
billion, expressed as present value over 
2029-2050 relative to the baseline) 
Impacts on employment 
Impacts on fundamental rights 
Environmental impacts 
Fossil fuel savings (cumulative over 
2029-2050 relative to the baseline, in 
million tonnes of oil equivalent) 
CO2 emissions savings (cumulative over 
2029-2050 relative to the baseline, in 
million tonnes)  
Air pollution emissions savings 
(cumulative over 2029-2050 relative to 
the baseline, in thousand tonnes) 

+ 
++ 
16.4 

- 
-6.9 

-3.1  
(in 2030) 
0.9  
(in 2040) 
- 
-4.9 

-0.001%  
(in 2030) 
-0.002%  
(in 2040) 
-/0 

++ 
++ 
26.3 

- 
-6.0 

-4.0  
(in 2030) 
2.6  
(in 2040) 
- 
-11.1 

-0.002%  
(in 2030) 
-0.004%  
(in 2040) 
-/0 

+++ 
+++ 
38.7 

- 
-3.4 

-4.8  
(in 2030) 
5.5  
(in 2040) 
-- 
-20.2 

-0.003%  
(in 2030)  
-0.01%  
(in 2040) 
-/0 

-- 
-- 
-26.1 

- 
-6.9 

-3.1  
(in 2030) 
0.9  
(in 2040) 
-- 
-18.1 

-0.001%  
(in 2030) 
-0.01%  
(in 2040) 
-/0 

- 
-- 
-18.4 

- 
-6.0 

-4.0  
(in 2030) 
2.6  
(in 2040) 
-- 
-27.9 

-0.003%  
(in 2030) 
-0.01%  
(in 2040) 
-/0 

0/+ 
- 
-8.6 

- 
-3.4 

-4.8  
(in 2030) 
5.5  
(in 2040) 
--- 
-41.0 

-0.005%  
(in 2030) 
-0.02%  
(in 2040) 
-/0 

-0.47 

-0.47 

-0.47 

-0.94 

-0.94 

-0.94 

++ 
-- 
-15.6 

++ 
-- 
-18.7 

+++ 
-- 
-20.5 

-- 
--- 
-41.7 

-- 
--- 
-46.8 

- 
--- 
-49.4 

-21.1  
(in 2030) 
-3.0  
(in 2040) 
+ 

-29.6  
(in 2030) 
1.9  
(in 2040) 
++ 

-38.5  
(in 2030) 
9.9  
(in 2040) 
+++ 

-63.1  
(in 2030) 
-32.3  
(in 2040) 
+ 

-73.7  
(in 2030) 
-30.5  
(in 2040) 
++ 

-83.8  
(in 2030) 
-24.7  
(in 2040) 
+++ 

+ 

+ 
+ 
+ 
+ 
0.3 

0 
0 
+ 
3.4 

10 

++ 

++ 
+ 
+ 
+ 
0.7 

0 
0 
+ 
8 

+++ 

+++ 
+ 
++ 
+ 
1.2 

0 
0 
++ 
14.6 

+ 

+ 
+ 
+ 
+ 
0.6 

0 
0 
++ 
15.8 

++ 

++ 
+ 
++ 
+ 
1.2 

0 
0 
+++ 
24.2 

+++ 

+++ 
+ 
+++ 
+ 
1.9 

0 
0 
+++ 
35.3 

23.7 

43.4 

48 

73.5 

107.1 

15.0 
(NOx) 
0.0.33.3 
(PM2.5)3 

25.0 
(NOx) 
0.8 
(PM2.5) 

40.2 
(NOx) 
1.6 
(PM2.5) 

20.5 
(NOx) 
0.6 
(PM2.5) 

37.0 
(NOx) 
1.3 
(PM2.5) 

63.3 
(NOx) 
2.4 
(PM2.5) 

55 

 
  
 
 
 
 
 
 
PO1A 

PO1B 

PO1C 

PO2A 

Noise emissions (external costs savings 
expressed as present value over 2029-
2050 relative to the baseline, in billion 
EUR) 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

0.2 

0.4 

0.1 

0.4 

PO2B 

0.7 

PO2C 

1.0 

7.  HOW DO THE OPTIONS COMPARE? 

7.1.  Effectiveness 

The assessment of effectiveness looks at the extent to which the policy options meet the general and specific 
objectives  (SO)  of  the  intervention.  Table  32  presents  the  link  between  the  policy  objectives  and  the 
assessment criteria.  

Table 32: Link between objectives and assessment criteria 

General objective 

Specific objective 

Assessment criteria 

Support the decarbonisation of 
the road transport sector, while 
safeguarding the 
competitiveness of the EU 
automotive industry and 
ensuring a fair transition 

SO1 – Stimulate the demand for 
ZEVs in the corporate segment 
SO2 – Reduce fossil fuels 
expenditures in the road transport 
sector 

•  Increase in the number of ZEV in the 

corporate segment 

•  Reduction in the fossil fuels used by cars, 

vans and lorries 

SO3 – Accelerate ZEV availability 
on the second-hand market 

•  Increase in the number of ZEV on the 

second-hand market 

Concerning SO1 (Stimulate the demand for ZEVs in the corporate segment), both PO1 and PO2 show an 
increase in the  number of ZEV in the corporate segment, particularly in the time period 2030-2040 (see 
Table 34). PO2C and PO1C show the highest increase relative to the baseline (1.8 million additional ZEV in 
2030  and  1.4  million in  2040  in PO2C;  1.7 million  additional ZEV  in  2030 and  1.1  million  in  2040 in 
PO1C). PO2B and PO1B also significantly contribute towards SO1 (1.4 million additional ZEV in 2030 and 
1 million in 2040 in PO2B; 1.4 million additional ZEV in 2030 and 0.8 million in 2040 in PO1B). The 
contribution of PO2A and PO1A towards SO1 is more limited (0.9 million additional ZEV in 2030 and 0.7 
million in 2040 in PO2A; 0.9 million additional ZEV in 2030 and 0.6 million in 2040 in PO1A). 

Concerning SO2 (Reduce fossil fuels expenditures in the road transport sector), all policy options result in a 
reduction of the fossil fuels use in the road transport sector, with a greater contribution from lorries under 
PO2. PO2C and PO2B contribution towards SO2 is the highest (35.3 million tonnes of oil equivalent (Mtoe) 
saved  in  PO2C  and  24.2  Mtoe  saved  in  PO2B,  cumulative  over  2029-2050  relative  to  the  baseline), 
followed by PO2A and PO1C (15.8 Mtoe saved in PO2A and 14.6 Mtoe saved in PO1C). PO1B and PO1A 
show a more limited contribution (8 Mtoe saved in PO1B and 3.4 Mtoe saved in PO1A). 

All policy options are expected to contribute towards SO3 (Accelerate ZEV availability on the second-hand 
market) as the number of ZEVs in the second-hand market is projected to increase in all options relative to 
the  baseline.  PO2C  and  PO1C  show  the  highest  contribution  towards  SO3  (1.6  million  additional  zero-
emission cars, vans and lorries on average per year over 2031-2050 relative to the baseline in PO2C and 1.4 
million in PO1C), followed by PO2B and PO1B (1.2 million additional ZEV on average per year in PO2B 
and 1.1 million in PO1B). PO2A and PO1A also contribute towards SO3 (0.8 million additional ZEV on 
average per year in PO2A and 0.7 million in PO1A), although their contribution is more limited.   

In addition,  regarding  the general objective, all policy options result in  a reduction in the CO2 emissions 
relative to the baseline as shown in section 6.3. By ensuring a consistent framework across the EU for the 
uptake of corporate ZEV and reducing the current fragmentation, they provide certainty and thus promote 

56 

 
  
 
the competitiveness of the EU automotive industry. Finally, they all promote a fairer transition by increasing 
the availability of second-hand ZEVs across the EU. 

There is a trade-off between certainty and flexibility. Setting rigid targets for individual fleets or operators 
would result in the highest certainty, but it would not provide sufficient flexibility, and it would risk setting 
targets that cannot be met by certain operators with specific requirements and use cases. Setting national 
targets for Member States brings less certainty, but significantly more flexibility, compared to targets for 
individual entities. At the same time, this approach –  while not bringing as much certainty as a stronger 
intervention with targets for individual fleets – still improves certainty and predictability compared to the 
current  situation,  where there  is  no mandatory target  either  at  national  or individual  fleet  level.  Member 
States will set their own measures, but there will be certainty about the trajectory for the transition towards 
ZEVs in corporate fleets across each Member State. 

It is acknowledged that as the national measures necessary to meet the targets for cars, vans and lorries in 
PO1 and for cars and vans in PO2 are not identified, and that it is presently unknown how effective they will 
be in reaching the targets, there is uncertainty regarding the level of effectiveness of both PO1 and PO2. The 
level of uncertainty is higher in PO1 than in PO2 because PO1 focuses on Member States targets for lorries 
while PO2 sets mandates on shippers.  

7.2.  Efficiency 

Efficiency concerns the ‘extent to which objectives can be achieved for a given cost (cost effectiveness)’. 
The estimates of costs and benefits are summarised in Table 33.  

Table 33: Summary of costs and benefits of policy options - present value over 2029-2050 compared to the baseline (in 
billion EUR, 2023 prices) 

PO1A 

PO1B 

PO1C 

PO2A 

PO2B 

PO2C 

Businesses  
Administrative costs 
Enforcement costs 
Adjustment costs 
Increase in tax expenditures 
Adjustment costs savings 
Reduction in tax expenditures 
Citizens 
Adjustment costs 
Increase in tax expenditures 
Adjustment costs savings 
Reduction in tax expenditures 
National authorities 
Administrative costs 
Losses in tax revenues 
Additional tax revenues 
European Environmental Agency 
Administrative costs  
External costs savings 
External costs related to CO2 emissions  
External costs related to air pollution emissions 
External costs related to noise emissions 
Total costs 
Total benefits 
Net benefits (+) or net costs (-) 

0.00 
0.00 
24.5 
9.7 
32.9 
17.8 

6.0 
3.8 
2.2 
0.6 

0.00 
18.4 
13.5 

0.00 
0.00 
32.7 
12.3 
45.7 
25.6 

7.8 
4.3 
4.0 
2.1 

0.00 
27.7 
16.6 

0.00 
0.00 
40.8 
14.3 
59.2 
34.6 

10.3 
4.7 
7.0 
4.6 

0.00 
39.1 
18.9 

41.36 
0.004 
36.6 
5.4 
30.7 
26.5 

6.0 
3.8 
2.2 
0.6 

0.10 
27.1 
9.2 

41.35 
0.004 
47.9 
6.3 
40.9 
36.3 

7.8 
4.3 
4.0 
2.1 

0.10 
38.4 
10.6 

41.35 
0.004 
61.7 
6.8 
53.5 
47.8 

10.3 
4.7 
7.0 
4.6 

0.10 
52.4 
11.5 

0.0005 

0.0005 

0.0005 

0.0009 

0.0009 

0.0009 

3.7 
0.5 
0.2 
84.8 
98.3 
13.6 

6.8 
0.8 
0.4 
109.2 
132.2 
23.0 

7.8 
0.2 
0.4 
120.3 
77.6 
-42.7 

11.7 
0.5 
0.7 
146.1 
106.8 
-39.4 

16.9 
1.0 
1.0 
177.4 
143.2 
-34.2 

1.6 
0.2 
0.1 
62.3 
68.8 
6.5 

57 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Benefits to costs ratio 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

PO1A 
1.10 

PO1B 
1.16 

PO1C 
1.21 

PO2A 
0.65 

PO2B 
0.73 

PO2C 
0.81 

Total costs are projected to be the lowest in PO1A, estimated at EUR 62.3 billion expressed as present value 
over the period 2029-2050 compared to the baseline, followed by PO1B (EUR 84.8 billion), and PO1C 
(EUR 109.2 billion). The sub-options of option PO2 all present higher total costs: PO2A is projected to 
result  in  EUR  120.3  billion  total  costs,  PO2B  in  EUR  146.1  billion,  and  PO2C  in  EUR  177.4  billion. 
Adjustment  costs  for  businesses  represent  the  main  cost  component  in  PO1A  (39.2%),  PO1B  (38.6%), 
PO1C (37.4%), PO2B (32.8%) and PO2C (34.8%). Administrative costs for businesses represent the main 
cost  component  in PO2A (34.4%),  followed  by  adjustment  costs  for businesses  (30.4%).  Administrative 
costs for businesses also represent a significant share of the total costs in PO2B (28.3%) and PO2C (23.3%). 
The large share of administrative costs for businesses in PO2A, PO2B, and PO2C is due to the need to 
monitor and report road freight transport activity performed on behalf of large companies, either  by their 
own fleets or by sub-contractors.  

Total benefits are estimated at EUR 68.8 billion for PO1A, EUR 98.3 billion for PO1B, EUR 132.2 billion 
for PO1C, EUR 77.6 billion for PO2A, EUR 106.8 billion for PO2B, and EUR 143.2 billion for PO2C, 
expressed as present value over the period 2029-2050 compared to the baseline. For all options, the main 
benefits come from adjustment cost  savings for businesses (47.7% in PO1A, 46.5% in PO1B, 44.8% in 
PO1C, 39.6% in PO2A, 38.3% in PO2B and 37.3% in PO2C). 

Overall, PO1A, PO1B, and PO1C result in net benefits compared to the baseline. PO1C shows the highest 
net benefits, estimated at EUR 23 billion expressed as present value over the period 2029-2050, followed by 
PO1B (EUR 13.6 billion) and PO1A (EUR 6.5 billion). PO1C also shows the highest benefits to costs ratio 
(1.21), followed by PO1B (1.16) and PO1A (1.10). All sub-options of PO2 result in net costs, with PO2A 
showing the highest net costs (EUR 42.7 billion), followed by PO2B (EUR 39.4 billion), and PO2C (EUR 
34.2 billion). Thus, all sub-options of PO2 result in benefits to costs ratios lower than 1.  

It should be acknowledged that as the national measures necessary to meet the targets for cars, vans and 
lorries in PO1 and for cars and vans in PO2 are not identified, there is uncertainty regarding the efficiency of 
both  PO1  and  PO2.  In  particular,  as  explained  in  section  6.1.1,  the  way  the  adjustment  costs  and  costs 
savings are distributed among different operators within a Member State, and what potential further indirect 
impacts these might have, will depend on what national measures are put in place.  

7.3.  Coherence 

Internal  coherence  assesses  how  the  various  elements  of  the  proposed  options  are  expected  to  work 
together  to  achieve  the  objectives.  All  policy  options  address  the  identified  specific  objectives  and 
underlying  problem  drivers  and  ensure  internal  coherence.  PO1  performs  better  in  terms  of  internal 
coherence,  as  it  covers  all  market  segments of  passenger  cars,  vans,  and  lorries  in  a  consistent  way  and 
provides  certainty  to  markets  while  allowing  Member  States  sufficient  flexibility  to  adjust  the 
implementation of the targets to their particular circumstances and activate the most relevant national policy 
levers. On the other hand, PO2 introduces a different approach for lorries, which increases the certainty of 
the implementation pathway for shippers and hauliers but result in a slightly lower coherence across the road 
freight  transport  sector,  as  vans  and  lorries  –  which  are  often  used  together  as  part  of  large  companies’ 
logistics chains – are subject to substantially different measures.    

External coherence concentrates on the compliance of the initiative with other EU instruments and relevant 
EU policies.  This initiative has a  direct link with the  CO2 emission performance standards for light- and 
heavy-duty vehicles. There are clear synergies and complementarities between all policy options assessed 
and  the  CO2  emission  performance  standards  for  light-  and  heavy-duty  vehicles.  All  policy  options  will 
facilitate  the  implementation  of  the  CO2  standards  as  they  increase  corporate  demand  for  ZEV,  in  full 

58 

 
  
alignment with the scope and ambition of the CO2 standards. Accelerated ZEV demand under any of the 
policy  options  will  also  help  the  implementation  of  the  Alternative  Fuels  Infrastructure  Regulation,  as 
increased demand improves the profitability of recharging and refuelling stations. The proposed targets will 
also support the implementation of key provisions under other policy instruments aimed at decarbonising 
transport, such as the Eurovignette Directive with the possibility to exempt zero-emission lorries. There are 
also synergies between this initiative and the ETS2. On one hand, this initiative is expected to drive a higher 
uptake of zero-emission vehicles relative to the baseline from 2029, avoiding pressure on the carbon prices. 
On the other hand, the carbon price set by the ETS2 will provide a market incentive for investments in zero-
emission mobility. Both co-legislators have introduced a postponement of ETS2 by one year, to 2028, in 
their respective positions on the 2040 climate target proposal, amending the European Climate Law. The 
clean corporate vehicles initiative is planned to be implemented starting in 2029 and the synergies between 
the two initiatives remain the same, even if the start of the ETS2 is postponed by one year. Even with one 
year delay for ETS2, Member States remain legally obliged to meet their binding 2030 targets under the 
Effort  Sharing  Regulation,  ensuring  that  the  EU  stays  on  course  to  climate  neutrality.  Thus,  all  policy 
options are consistent with relevant EU legal instruments and contribute to EU policy priorities. 

7.4.  Subsidiarity and proportionality 

Regarding subsidiarity, as explained in sections 3.2 and 3.3, EU action is justified since action at the national 
level  alone  would  not  lead  to  the  stimulus  required  to  accelerate  the  uptake  of  ZEVs  in  the  corporate 
segment in support of the competitiveness of the EU automotive industry, and would not accelerate the ZEV 
availability on the second-hand market to the extent necessary to ensure a fair and just transition.   

All policy options are assessed to be proportionate, as action at EU level is limited to what is necessary to 
support the decarbonisation of the EU road transport sector, while safeguarding the competitiveness of the 
EU automotive industry and  ensuring a fair transition. PO1 leaves  full flexibility for decisions by public 
authorities at national level as regards the necessary measures to spur the uptake of ZEV, while ensuring that 
the  proposal’s  objectives  are  met169.  By  setting  specific  targets  for  large  companies,  PO2  goes  however 
somewhat beyond what is strictly necessary to ensure that the relevant targets in the road freight transport 
segment are met because it leads to high administrative costs for businesses (EUR 41.4 billion expressed as 
present value over 2029-2050 relative to the baseline) for reporting compliance with the targets set.    

Table 34 provides a summary of the comparison of the options against the baseline scenario in terms of 
effectiveness, efficiency, coherence, subsidiarity, and proportionality. The following ranking symbols have 
been used: from '+' (more effective/efficient/coherent/proportionate than the baseline) to '+++' (much more 
effective/efficient/coherent/proportionate  than  the  baseline);  from  '-'  less  effective/efficient/coherent/ 
proportionate  than  the  baseline)  to  '---'  (much  less  effective/efficient/coherent/proportionate  than  the 
baseline). 

169 While complying with State aid rules, if applicable. 

59 

 
 
Table 34: Comparison of options in terms of effectiveness, efficiency, coherence, subsidiarity and proportionality relative 
to the baseline 
Objective 

Policy option 

Effectiveness 

PO1A 
+ 

PO1B 
++ 

PO1C 
+++ 

PO2A 
+ 

PO2B 
++ 

PO2C 
+++ 

Specific Objective 1: Stimulate the demand for ZEVs in the corporate segment 
+  
Increase in the number of ZEV in 
(0.9 million 
the corporate segment (increase in 
in 2030, 0.6 
the  stock of cars, vans and lorries 
million in 
relative to the baseline) 
2040 and 0.1 
million in 
2050) 

++  
(1.4 million 
in 2030, 0.8 
million in 
2040 and 0.2 
million in 
2050) 

+++  
(1.7 million 
in 2030, 1.1 
million in 
2040 and 0.2 
million in 
2050) 

+  
(0.9 million 
in 2030, 0.7 
million in 
2040 and 0.3 
million in 
2050) 

+  
(8 Mtoe) 

++  
(14.6 Mtoe) 

Specific Objective 2: Reduce fossil fuels expenditures in the road transport sector 
++  
+  
Reduction in the fossil fuels used 
(15.8 Mtoe) 
(3.4 Mtoe) 
by cars, vans and lorries 
(cumulative over 2029-2050 
relative to the baseline, in millions 
of tonnes of oil equivalent) 
Specific Objective 3: Accelerate ZEV availability on the second-hand market 
Increase in the number of ZEV on 
the  second-hand  market  (average 
annual  increase  in  the  number  of 
ZEV  cars,  vans  and  lorries  over 
the 
2031-2050, 
baseline) 
Efficiency 

++  
(1.1 million) 

+++  
(1.4 million) 

+   
(0.7 million) 

+ 
(0.8 million) 

relative 

to 

++ 

++ 

--- 

+ 

Coherence 

Subsidiarity and proportionality 

++ 

++ 

++ 

++ 

++ 

++ 

+ 

+ 

7.5.  Sensitivity analysis 

++ 
(1.4 million 
in 2030, 1 
million in 
2040 and 0.4 
million in 
2050) 

+++ 
(1.8 million 
in 2030, 1.4 
million in 
2040 and 0.5 
million in 
2050) 

+++ 
(24.2 Mtoe) 

+++ 
(35.3 Mtoe) 

++  
(1.2 million) 

+++  
(1.6 million) 

-- 

+ 

+ 

-- 

+ 

+ 

As the administrative costs for businesses represent the main cost component in PO2A (34.4% of the total 
costs) and a significant share of the total costs in PO2B (28.3%) and PO2C (23.3%), a sensitivity analysis 
has been performed in relation to these costs. In the base case, used in the efficiency table in section 7.2, for 
large companies it is assumed that one minute per lorry per working day is needed to report the type of 
vehicle  and  activity  performed  (i.e.  tonne-km)  for  the  lorries  that  they  own,  drawing  on  feedback  from 
targeted interviews. In addition, for sub-contractors of large companies, based on interviews with industry 
representatives, 5 minutes per working day per lorry are assumed to be needed to report the type of vehicle 
and activity performed (i.e. tonne-km). The effort required per lorry per working day is estimated based on a 
series  of  targeted  interviews,  summarised  in  Annex  2.  For  the  sensitivity  analysis,  two  cases  have  been 
considered in addition to the base case: 

-  Low case 1, where the time required for reporting per lorry per working day is 50% lower than in the 
base case (i.e. for large companies, 0.5 minutes per lorry per working day for the lorries that they own; 
for sub-contractors of large companies, 2.5 minutes per lorry per working day);   

-  High case 1, where the time required for reporting per lorry per working day is 50% higher than in the 
base case (i.e. for large companies, 1.5 minutes per lorry per working day for the lorries that they own; 
for sub-contractors of large companies, 7.5 minutes per lorry per working day).  

60 

 
 
 
 
The table below presents the impacts on total benefits, total costs, net benefits and benefits to costs ratio by 
policy option in the base case,  low  case  1  and  high  case  2.  It  shows that this  assumption has important 
impacts on the total costs of PO2 and no impact on the total benefits of PO2, and on the costs and benefits of 
PO1. The table shows that PO2 is expected to result in net costs under the two additional cases considered. It 
also shows that the ranking of the policy options is not expected to change in the low case 1 and high case 2 
relative to the base case estimates.  

Table  35: Summary  of  costs  and  benefits  of  the  policy  options  in  the  base  case,  low  case  1  and  high  case  2, 
expressed as present value over 2029-2050 compared to the baseline (in million EUR, in 2023 prices) 
PO2B 

PO1C 

PO1A 

PO2C 

PO2A 

PO1B 

Total benefits 

Base case  

Low case 1  

High case 2  

Total costs 

Base case  

Low case 1  

High case 2  

Net benefits (+) or net costs (-) 

Base case  

Low case 1  

High case 2  

Benefits to costs ratio 

Base case  

Low case 1  

High case 2  

68.8 

68.8 

68.8 

62.3 

62.3 

62.3 

6.5 

6.5 

6.5 

1.10 

1.10 

1.10 

98.3 

98.3 

98.3 

84.8 

84.8 

84.8 

13.6 

13.6 

13.6 

1.16 

1.16 

1.16 

132.2 

132.2 

132.2 

109.2 

109.2 

109.2 

23.0 

23.0 

23.0 

1.21 

1.21 

1.21 

77.6 

77.6 

77.6 

120.3 

100.2 

140.5 

-42.7 

-22.6 

-62.8 

0.65 

0.77 

0.55 

106.8 

106.8 

106.8 

146.1 

126.0 

166.3 

-39.4 

-19.2 

-59.5 

0.73 

0.85 

0.64 

143.2 

143.2 

143.2 

177.4 

157.3 

197.5 

-34.2 

-14.1 

-54.3 

0.81 

0.91 

0.73 

7.6.  Assessment of the impacts of EU content requirements 

In order to strengthen domestic industrial production, support decarbonisation in key industry sectors and 
also  promote  clean  technology  products,  minimum  EU  content  requirements  in  public  procurement  and 
public  support  schemes  for  energy  intensive  industries  and  certain  products,  including  e.g.  for  steel  and 
aluminium contained in vehicles produced in the EU, for batteries manufactured in the EU and for other key 
vehicle  components,  have  been  considered  in  this  assessment.  Since  the  transition  to  ZEVs  in  corporate 
fleets is subject to public financial support in Member States, there is a potential for using this form of public 
support to help support strengthening domestic value chains in the automotive sector. The role of EU content 
requirements for public procurement or public support schemes is therefore considered for the policy options 
under assessment.  

Battery electric cars display greater dependence on third countries for any segment or component (inputs) 
compared to conventional cars. A JRC analysis170 on the EU value content in the EU automotive production 
shows that while the European automotive industry primarily relies on EU manufactured input, the latter’s 
share dropped from 92% in 2010 to 89% in 2022. In particular, the production of motor vehicles shows that 
87% of the value of an EU-made conventional car comes from the EU, while this value is only 72% for 
battery electric vehicles171. The increased dependency on China in battery electric production compared to 

170  For  this  specific  analysis,  ICE  includes  mild  hybrids.  EV  includes  battery  electric  and  plug-in  hybrid  electric 
vehicles. 
171 McKinsey & Company (2024). Europe's economic potential in the shift to electric vehicles. 

61 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
conventional vehicles is particularly relevant. In the absence of EU content requirements, there is a risk that 
companies would buy a higher share of non-EU produced corporate vehicles. 

An assessment has been performed to show the impact of applying EU content requirements to the new 
corporate ZEVs counted for meeting the targets under PO1 and PO2.  More specifically,  the EU content 
requirements considered in this assessment are the following: 

•  A minimum percentage of Made in EU steel (85% from adoption) and aluminium (70% from adoption) 

for vehicles in public procurement and subject to public support schemes placed on the EU market; 

•  Mandatory EU content requirements for batteries of at least four components from adoption (including 
the  battery  cell),  increasing  to  6  components  from  2030  (including  the  battery  management  system 
(BMS) and the cathode active material (CAM)); 

•  A minimum percentage of the value of the vehicle, other than battery, is manufactured in the EU (70% 

from adoption and 75% from 2030).  

According to analysis performed by JRC with FIDELIO model, introducing EU content requirements for 
steel and aluminium in the automotive sector for public procurement and support schemes would lead to a 
0.53%  reduction  of  the  EU  automotive  sector’s  gross  value  added  for  2025-2030,  relative  to  a  baseline 
scenario without EU content requirements172.  

The impacts of including EU content requirements  for batteries and other vehicle components  under the 
different policy options have been calculated using the unit cost assumptions provided in Annex 4 (section 
8), and applying them to the number of additional corporate ZEVs required to meet the targets under each 
option compared to the baseline.  

Table  36  provides  the  estimated  costs  of  applying  EU  content  criteria  to  new  zero-emission  vehicles  in 
corporate  fleets,  associated  to  the  policy  options,  assuming  100%  pass  through  of  the  costs  to  vehicle 
owners. It distinguishes between the costs associated to the battery requirements, presented as a range, and 
those related to other vehicle components.  

The highest costs associated to the EU content requirements are projected in PO2C (EUR 5.5 to 8.6 billion 
expressed  as present value  over  2029-2050  relative  to  the baseline)  and PO2B  (EUR 5.4  to 8.3  billion), 
followed by PO2A (EUR 4.3 to 6.5 billion) and PO1C (EUR 3.1 to 5.5 billion). The higher costs in these 
options are due to the relatively higher number of ZEV in the scope and in PO2 also the higher number of 
lorries,  that  bear  higher  costs  per  vehicle  associated  to  the  requirements  on  batteries  and  other  vehicle 
components. More details about the vehicles in scope, and costs estimates for specific years are provided in 
Annex 4 (section 8).    

Table 36: Adjustment costs for businesses due to the  EU content requirements, expressed as present value over 2029-
2050 relative to the baseline (in billion EUR, 2023 prices) 

Costs related to vehicle components 
Costs related to batteries - low estimates 
Costs related to batteries - high estimates 

PO1A 
0.9 
0.9 
2.2 

PO1B 
1.2 
1.3 
3.1 

PO1C 
1.5 
1.6 
3.9 

PO2A 
2.6 
1.7 
3.9 

PO2B 
3.3 
2.1 
5.1 

PO2C 
3.3 
2.2 
5.3 

172  FIDELIO  stands  for  Fully  Interregional  Dynamic  Econometric  Long-term  Input-Output  model.  It  is  a  dynamic 
general  equilibrium  model  developed  by  the  JRC  that  has  been  used  to  model  the  economic  and  competitiveness 
impacts  of  introducing  local  content  requirements  for  steel  and  aluminium  in  the  construction,  machinery  and 
automotive  industries  in  the  EU.  For  simulating  the  impacts  of  local  content  requirements  for  aluminium  and  steel, 
FIDELIO  was  used  in  combination  with  the  FIGARO-E3  database  (Cazcarro  et  al.,  2025);  a  disaggregation  of  the 
Eurostat’s  global  FIGARO  input-output  tables  (Remond-Tiedrez  and  Rueda-Cantuche,  2019)  that  includes  such 
materials explicitly represented. 

62 

 
  
 
Total costs for businesses - low estimates 
Total costs for businesses - high estimates 

PO1A 
1.8 
3.1 

PO1B 
2.5 
4.4 

PO1C 
3.1 
5.5 

PO2A 
4.3 
6.5 

PO2B 
5.4 
8.3 

PO2C 
5.5 
8.6 

The  summary  of  the  total  costs  and  benefits,  including  the  adjustment  costs  for  businesses  (i.e.  vehicle 
owners)  due  to  the  EU  content  requirements,  are  further  compared  with  the  central  case,  excluding  EU 
content requirements. The analysis shows that even when considering the EU content requirements PO1A, 
PO1B and PO1C are expected to result in net benefits while PO2A, PO2B and PO2C in net costs, and the 
ranking of the policy options does not change. 

Table 37: Summary of costs and benefits of policy options in the central case, Case 1 and Case 2 expressed as present 
value over 2029-2050 relative to the baseline (in billion EUR, 2023 prices) 

PO1A 

PO1B 

PO1C 

PO2A 

PO2B 

PO2C 

Central case – excluding EU content requirements  
Total costs 
Total benefits 
Net benefits (+) or net costs (-) 
Benefits to costs ratio 
Case 1 – including EU content requirements (low estimates) 
Total costs 
Total benefits 
Net benefits (+) or net costs (-) 
Benefits to costs ratio 
Case 2 – including EU content requirements (high estimates) 
Total costs 
Total benefits 
Net benefits (+) or net costs (-) 
Benefits to costs ratio 

62.3 
68.8 
6.5 
1.10 

64.1 
68.8 
4.7 
1.07 

65.4 
68.8 
3.4 
1.05 

84.8 
98.3 
13.6 
1.16 

87.3 
98.3 
11.0 
1.13 

89.1 
98.3 
9.2 
1.10 

109.2 
132.2 
23.0 
1.21 

112.3 
132.2 
19.9 
1.18 

114.6 
132.2 
17.5 
1.15 

120.3 
77.6 
-42.7 
0.65 

124.6 
77.6 
-47.0 
0.62 

126.8 
77.6 
-49.2 
0.61 

146.1 
106.8 
-39.4 
0.73 

151.5 
106.8 
-44.8 
0.70 

154.5 
106.8 
-47.7 
0.69 

177.4 
143.2 
-34.2 
0.81 

182.9 
143.2 
-39.7 
0.78 

186.0 
143.2 
-42.8 
0.77 

Overall, the EU content requirements are expected to contribute to the creation of a stable lead market for 
European  steel  and  aluminium  manufacturers,  battery  manufacturers  and  electric  vehicle  component 
manufacturers,  enhancing  their  competitiveness  and  helping  attract  new  investments  in  EU  production 
capacity  in  those  sectors.  EU  production  of  all  key  components  of  zero-emissions  vehicles  diversifies 
critical-mineral  and  component  supply  chains  and  thereby  reduce  strategic  dependence  on  third-country 
production, and keeps know-how, and jobs in Europe. In this way, it would also help increase decarbonised 
and resilient industrial production in the EU manufacturing industry.  

8.  PREFERRED OPTION 

8.1.  Identification of the preferred policy options and stakeholder views 

All the policy options address the problems identified, their drivers and the specific objectives. However, 
some options are more effective in achieving the specific and general objectives than others.  

The analysis above identifies PO1 as the preferred policy option, as it is considered effective in reaching the 
policy  objectives,  it  presents  net  benefits,  and  it  avoids  the  risk  of  imposing  significant  administrative 
burdens.  

PO1 also performs better in terms of subsidiarity and proportionality, as it allows Member States to set the 
measures that are best suited for the specific market conditions in their territory and enable markets to ramp-
up  ZEVs  in  corporate  fleets  in  the  most  cost-efficient  manner  while  avoiding  the  administrative  cost  of 
setting  stringent  targets  on  individual  fleets.  This  policy  option  is  fully  coherent  with  other  relevant 
legislation in the field, particularly the CO2 standards for light and heavy-duty vehicles.  

63 

 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
PO1 sets  clear targets  for the  share  of ZEVs  in  new  registrations of  corporate vehicles,  as  supported  by 
NGOs, public authorities, mobility service providers, infrastructure providers, and vehicle manufacturers in 
the  context  of  the  CfE  and  of  targeted  stakeholders’  consultation,  while  meeting  the  requirements  of 
sufficient flexibility for individual operators and fleets expressed by transport operators, companies making 
use of transport services, and SMEs. By setting binding national targets but leaving flexibility to the Member 
States  on  what  measures  to  put  in  place  in  order  to  meet  them,  this  option  mobilises  the  most  relevant 
national  policy levers  and expectedly  particularly those  of  fiscal  and  financial support,  which have  been 
consistently identified as the most effective by stakeholders. In particular, road hauliers, logistics companies, 
leasing  and  rental  companies,  SMEs,  and  their  respective  associations,  generally  expressed  opposition  to 
mandatory  targets  for  individual  fleets  while  highlighting  the  benefits  of  incentives  and  other  fiscal  and 
financial support measures. More details on stakeholder views are provided in Annex 2. 

The preferred policy option is therefore PO1; the choice between PO1A, PO1B, and PO1C, which only 
differ in terms of level of ambition of the national targets, will require a political decision. This choice will 
have implications in terms of the overall costs and benefits for large companies, SMEs, citizens and national 
authorities. PO1A, PO1B and PO1C would all result in net economic, social, and environment benefits – 
albeit to varying degrees. The analysis shows that PO1C is the most effective in addressing the objectives, 
has the highest net benefits, shows the highest benefits to costs ratio and leads to the lowest indirect net costs 
for citizens among PO1A, PO1B and PO1C. It however also leads to the highest indirect net costs for SMEs 
and highest losses in tax revenues for national authorities. PO1B also shows relatively high effectiveness and 
similar benefits to costs ratio with PO1C, leads to somewhat lower indirect net costs for SMEs and lower 
losses  in  tax  revenues  for  national  authorities  and  only  somewhat  higher  indirect  net  costs  for  citizens. 
Finally, PO1A has the lowest net benefits and benefits to costs ratio out of PO1A, PO1B and PO1C, but it is 
still effective in addressing the objectives, and comes with the lowest net costs for SMEs and lowest losses 
in tax revenues for national authorities while the net costs for citizens are relatively similar to those of PO1B.  

Including EU content criteria would increase total costs but PO1A, PO1B and PO1C would still result in net 
benefits (EUR 3.4 to 4.7 billion in PO1A, EUR 9.2 to 11 billion in PO1B and EUR 17.5 to 19.9 billion in 
PO1C).  Overall,  the  EU  content  requirements  are  expected  to  contribute  to  the  creation  of  a  stable  lead 
market  for  European  steel  and  aluminium  manufacturers,  battery  manufacturers  and  electric  vehicle 
component  manufacturers,  enhancing  their  competitiveness  and  helping  attract  new  investments  in  EU 
production capacity in those sectors. 

8.2.  REFIT (simplification and improved efficiency) 

While the initiative introduces a new obligation for Member States in the form of targets for the share of new 
ZEVs for large companies, the additional administrative burden for public authorities is kept to a minimum. 
The  proposal  builds  on  existing  vehicle  datasets  and  modalities  that  Member  States  already  operate  for 
vehicle registration and statistics, including business and fiscal statistics. While all Member States already 
have the necessary systems in place to identify new registrations of corporate vehicles, for distinguishing 
vehicle registered by SMEs or large companies in place, one-off administrative costs are expected. These are 
estimated at EUR 0.23 million at EU level. This would also allow to improve the ability of Member States to 
tailor policies to their national market without recurring to ad hoc data requests or bespoke reporting formats. 
In  addition,  recurrent  administrative  costs  for  reporting  by  the  Member  States  the  compliance  with  the 
targets are estimated at EUR 10,350 per year at EU level.  

8.3.  Application of the ‘one in, one out’ approach  

PO1 is not expected to lead to additional administrative costs for businesses or citizens.  

64 

 
9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The  Commission  services  will  monitor  the  implementation  and  effectiveness  of  this  initiative  through  a 
number of actions and a set of core indicators that will measure progress towards achieving the objectives. 
Five years after the implementation date of the legislation, the Commission services should carry out an 
evaluation to verify to what extent the objectives of the initiative have been reached. 

The  monitoring  of  specific  objective  1  (Stimulate  the  demand  for  ZEVs  in  the  corporate  segment)  is 
straightforward. The Commission will monitor this objective based on the reporting of registration figures 
by Member States under this initiative, based on their vehicle registers.  

The monitoring of specific objective 2 (Reduce fossil fuels expenditures in the road transport sector) will be 
done on the basis of Eurostat statistics regarding final energy consumption in road transport, which are well 
established and regularly reported.  

For the monitoring of specific objective 3 (Accelerate the ZEV availability on the second-hand market), after 
the adoption of the legal instrument the Commission will initiate a specific study to analyse the progress per 
Member  State.  Results  of  this  assessment  will  be  made  available  through  the  Commission’s  European 
Alternative  Fuels  Observatory  and  hence  enable  a  full  access  and  comparability  of  the  results  of  the 
assessment.   

The list of indicators and data sources is presented in Annex 9. 

65 

 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1. LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The lead DG is the Directorate General for Mobility and Transport DG MOVE, Unit B4: Sustainable and 
Intelligent Transport. 

DECIDE reference number: PLAN/2025/477. 

The  2020  Sustainable  and  Smart  Mobility  Strategy30  announced  the  Commission’s  intention  to propose 
actions  to  boost  the  uptake  of  ZEV  in  corporate  fleets. The  Commission  Work  Programme  202331 
included  a  legislative  or  non-legislative  initiative  under  item  9  in  Annex  I.  Consequently,  the 
Communication  “Decarbonise  Corporate  Fleets”34  was  published  on  5  March  2025,  announcing  the 
Commission’s  intention to  present  a  legislative  proposal  on greening  corporate  fleets in the  course  of 
2025 (reiterating a commitment included in the Clean Industrial Deal33 of 26 February 2025). 

2. ORGANISATION AND TIMING 

The impact assessment accompanying this initiative started in 2025. The CfE was published on 25 July and 
remained open for feedback until 8 September 2025173. 

The  impact  assessment  was  coordinated  by  an  Inter-Service  Group  (ISG).  The  Commission  Services 
participating in the ISG were: the Secretariat-General, the Legal Service, DG for Budget, DG for Climate 
Action,  DG  for  Communications  Networks,  Content  and  Technology,  DG  for  Competition,  DG  for 
Economic and Financial Affairs, DG for Employment, Social Affairs & Inclusion, DG for Energy, DG for 
Environment, Eurostat, DG for Financial Stability, Financial Services and Capital Markets Union, DG for 
Internal Market, Industry, Entrepreneurship and SMEs, Joint Research Centre (JRC), DG for Justice and 
Consumers, DG for Regional and Urban Policy, DG for Research and Innovation, DG for Taxation and 
Customs Union, DG for Trade.  

The Inter-Service Steering Group met 3 times: on 9 April 2025, 16 July 2025, and 24 October 2025. It was 
consulted throughout the different steps of the impact assessment process: notably on the draft CfE and on 
the draft Staff Working Document. 

3. CONSULTATION OF THE RSB 

The draft report was submitted to the RSB on 3 December 2025. The Board issued a positive opinion with 
reservations on 10 December 2025. The recommendations from the Board have been addressed in this final 
version of the impact assessment report as detailed in the table below. 

Table 38: Modifications of the impact assessment report in response to RSB recommendations 

RSB recommendations 

Modifications to the impact assessment report 

Main considerations 

(1)  The  report  does  not  sufficiently  assess  the 
magnitude  and  persistence  of 
identified 
problems  and  their  root  causes  in  view  of  the 

the 

The  magnitude  and  persistence  of  the  identified 
problems and drivers has been further clarified and 
the  section  5.1  on  the  dynamic  baseline  has  been 

173 Clean corporate vehicles 

66 

 
 
RSB recommendations 

Modifications to the impact assessment report 

dynamic baseline of the existing climate legislation 
in  force.  The  report  is  not  clear  on  whether  the 
competitiveness  of  the  EU  automotive  sector  is 
part of the problem. 

(2) It is not explained how discretion of Member 
States  to  determine  the  specific  measures  for 
achieving  the  targets  will  address  the  fragmented 
support 
report  does  not 
sufficiently analyse the total cost of ownership of 
ZEVs  including  those  related  to  the  operational 
constraints; it is also not clear how the intervention 
proposes to tackle them. 

framework.  The 

in  particular  as 

(3) The analysis of expected costs and benefits is 
not  sufficiently  robust, 
the 
potentially significant costs linked to the different 
choices taken at national level are not established. 
In terms of analysis of expected impacts, the report 
lacks  evidence  regarding  the  improvement  of 
competitiveness  and  improved  functioning  of  the 
internal market. 

reinforced,  including  explanations  on  the  existing 
legislation in force and their dynamics over time.  

Further  explanations  have been  added  in  sections 
2.1 and in section 5.2.3, including on the why the 
chosen measures for meeting the proposed targets 
address 
identified  problem  driver  of  a 
fragmented  support  framework  and  the  problem 
driver  linked  to  operational  constraints  of  zero 
emission vehicles. 

the 

Further explanations on the modelling of national 
measures and acknowledging the uncertainty have 
been  added  in  section  6.1.1.  Clarifications  on  the 
administrative costs have also been added in 6.1.1. 
The  uncertainty  regarding  the  costs  and  costs 
savings is highlighted in section 7.2 on efficiency 
and  a  sensitivity  analysis  has  been  performed  on 
the  administrative  costs  for  businesses  and  added 
in section 7.5. Further analysis on competitiveness 
and the functioning of the internal market has been 
added in section 6.1.5 of the report. 

Adjustment requirements 

(1)  The  report  should  be  clearer  on  what  the 
intervention is supposed to achieve in addition to 
the  existing  framework,  which  also  includes  the 
Effort  Sharing  Regulation  (ESR).  It  should  also 
better substantiate the statement that the identified 
problems  are  likely  to  persist  under  the  dynamic 
baseline  including  EU  climate  targets,  ETS2  and 
all climate measures already in place. 

The  relation  between  this  initiative,  ETS2  and  the 
Effort  Sharing  Regulation  has  been  explained  in 
section 1.2. Section 2.3 has been amended to clarify 
that the problems are expected to subside over time. 
In addition, section 5.1 has been reinforce to explain 
how the problems identified are expected to develop 
over time, and a discussion related to the EU climate 
targets, ETS2 and other climate measures already in 
place has been included.   

to 

(2)  The  report  should  clarify  whether 
the 
intervention  does  also  aim  to  address  problems 
the  EU 
the  competitiveness  of 
related 
automotive industry. If competitiveness of the EU 
automotive  industry  is  added  as  a  problem  the 
report  should  analyse  it,  also  considering  the  EU 
content 
Industrial 
Accelerator  Act  in  preparation.  It  should  also 
consider  whether 
that 
companies will buy primarily EU-produced ZEVs 
as company cars. 

the  assumption  holds 

requirements  under 

the 

Sections 2 and 4.2 have been amended to explain 
that this is a targeted initiative and other initiatives 
Industrial 
under  preparation, 
Accelerator Act, are better placed for addressing the 
competitiveness  of 
the  European  automotive 
industry. Further explanations have been added in 
section 7.6 related to the EU-produced ZEVs.  

such  as 

the 

67 

 
RSB recommendations 

Modifications to the impact assessment report 

(3)  Regarding  the  underlying  causes,  the  report 
should thoroughly analyse factors that may affect 
purchasing  choices  and  the  uptake  of  ZEVs,  for 
example,  purchase  prices  of  ZEVs,  relative 
depreciation of value, and operational constraints, 
including mileage and the availability of charging 
infrastructure.  The  report should better  explain to 
what  extent  and  how  the  problems  are  related  to 
regulatory or market failures and to what extent the 
initiative could address the identified problems. 

(4) The report should clarify how discretion of the 
Member States to choose measures for meeting the 
set  targets  will  address  the  identified  problem 
driver  of  a  fragmented  support  framework.  The 
report  should  also  explain  how  the  intervention 
addresses  the  identified  problem  driver  linked  to 
operational  constraints  of  zero  emission  vehicles. 
The analysis of effectiveness of intervention needs 
to  reflect  that  the  national  measures  necessary  to 
meeting  targets  are  not  identified,  and  that  it  is 
presently  unknown  how  effective  they  will  be  in 
reaching the targets. 

Sections 2.1 and 2.2 have been reinforced to better 
explain 
the  problems  and  problem  drivers 
identified. In Section 2.1 it is further explained that 
problem 2 is affected by a number of other factors 
addressed  by  other  initiatives  that  are  outside  the 
scope and explains the specific aspects that are not 
sufficiently  addressed  by  these  other  initiatives. 
Explanations are added on the extent the initiative 
could address the identified problems.  

the 

Further  explanations  have  been  added  in  sections 
2.1 and in section 5.2.3, including on the why the 
chosen measures for meeting the proposed targets 
identified  problem  driver  of  a 
address 
fragmented  support  framework  and  the  problem 
driver  linked  to  operational  constraints  of  zero 
emission  vehicles.  An  analysis  of  the  uncertainty 
related to the effectiveness of the policy options has 
been added in section 7.1. 

(5)  Taking  into  account  the  improved  problem 
definition,  the  report  should  analyse  a  broader 
range of options as the 2 options presented appear 
identical  except  for  the  target  for  lorries  and 
explain  how  option  2  is  realistic  considering  the 
high administrative and likely adjustment costs for 
SMEs. 

A broader set of policy options has been assessed as 
explained  in  section  5.2.2  and  Annex  7  but 
discarded.  Section  5.2.2  has  been  reinforced  to 
further explain the reason these options have been 
discarded.  In  addition,  an  explanation  has  been 
added in section 5.2.3 on the reasons for retaining 
option 2 for further analysis.  

(6) The national targets should be presented in the 
main report and the costs of achieving them should 
be  further  analysed  and  explained.  The  report 
should explain the modelling of national measures 
for  each  policy  option.  Taking  into  account  the 
diversity  of  actions  that  Member  States  might 
choose  to  comply  with  the  target  as  well  as  the 
related  potentially  significant  cost  (divergences), 
the report should be clear on the robustness of the 
figures on costs and cost savings and consequently 
the benefit-cost ratios. The total cost of ownership 
and how it likely affects the actions and choices of 
the  actors  involved  should  be  assessed  in  more 
detail.  Considering  the  impact  analysis  is  largely 
based  on  modelling,  it  should  better  factor  in 
uncertainties. 

The  approach  for modulating national  targets  has 
been  added  in  the  section  5.2.3  of  the  report. 
Further explanations on the modelling of national 
measures and acknowledging the uncertainty have 
been  added  in  section  6.1.1.  Clarifications  on  the 
administrative costs have also been added in 6.1.1. 
Costs per Member State are presented in Annex 4 
(section 7) and an explanation on their magnitude 
has  been  added  in  the  same  section.  Further 
explanations on the total costs of ownership have 
been  added  in  section  6.1.1.  The  uncertainty 
regarding the costs and costs savings is highlighted 
in  section  7.2  on  efficiency  and  a  sensitivity 
analysis has been performed on the administrative 
costs for businesses and added in section 7.5.  

(7)  The  report  should  further  clarify  how  it  Further  analysis  on  competitiveness,  improved 

68 

 
RSB recommendations 

Modifications to the impact assessment report 

assessed  the  impact  on  competitiveness,  the 
improved level playing field and the functioning of 
the internal market. 

level  playing  field  and  the  functioning  of  the 
internal market has been added in section 6.1.5 of 
the report.  

(8) In terms of coherence, the report should clarify 
how the intervention will interplay with the ETS2, 
ESR 
Infrastructure 
Regulation and allocative efficiency. 

and  Alternative  Fuels 

(9)  Stakeholder  views  should  be  presented 
systematically  throughout  the  report  in  a  detailed 
manner  by  stakeholder  group,  including  where 
there are dissenting views and why. 

Further  explanations  on  coherence  have  been 
added in section 7.3. 

A summary of different stakeholder groups’ views 
in terms of (a) overall attitude towards the need to 
act  and  the  ZEV  transition  in  general,  (b)  ZEV 
mandates,  and  (c)  vehicle  tax/financial  incentives 
has been added in section 5.2.3. 

4. EVIDENCE, SOURCES AND QUALITY 

The impact assessment is based on several sources, using both quantitative and qualitative data, collected 
from Member States and industry. This includes: 

•  A support study carried out by an external, independent consultant (Ricardo); 
•  The Commission’s own knowledge in the area, based on continuous dialogue with both Member 

States and companies active in the sector; 

•  Stakeholder consultation activities (see Annex 2). 

69 

 
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

In  accordance  with  the  Tool  #54  (analysing  data  and  informing  policymaking)  of  the  Better  Regulation 
Toolbox, this synopsis report provides an overview of the consultation activities carried out in the context of 
this initiative. 

This annex should only be regarded as an overview of the contributions received during the stakeholder 
consultation activities in the context of greening corporate fleets initiative and cannot be regarded as the 
official position of the Commission or of its services. Responses to the consultation activities reflect the views 
of participating stakeholders and cannot be considered as a representative sample of the views of the EU 
population. 

Section  1  explains  the  stakeholder  consultation  strategy,  providing  an  overview  of  the  objective  of  the 
consultation activities and the various consultation activities carried out between 2024 and 2025. Section 2 
describes the stakeholder mapping strategy, outlining the different groups and interests of the stakeholders, 
as well as their responsiveness to the consultation activities. Section 3 lists the limitations of the consultation 
strategy and its related activities. Finally, Section 4 summarises the outcome of the consultation activities, 
laying out stakeholder views on the identified problems, problem drivers and the proposed policy options. 

1.   STAKEHOLDER CONSULTATION STRATEGY 

The main objective of the stakeholder consultation process was to collect information, data, evidence, and 
opinions  of  stakeholders  on  key  issues  related  to  this  initiative.  These  included  the  state  of  play  of  the 
corporate  fleet  market,  the  challenges  and  possible  areas  of  action,  and  best  practice  examples  for 
accelerating  the  transition  to  zero-emissions.  By  considering  the  stakeholders’  views,  their  practical 
experience and the data provided, the stakeholder consultation process improves the overall understanding 
of the issues at stake, thus leading to better quality and credibility of the initiative. 

The stakeholder consultation strategy consisted of several activities carried out between 2024 and 2025. The 
data, evidence and opinions of stakeholders were collected via the following consultation activities: 

A Call for Evidence37 (CfE) was open between 25 July and 8 September 2025174 on the Commission’s 
centralised platform ‘Have your say’. It aimed to collect information and views to support the preparation of 
the present impact assessment. The Commission received 483 responses from 25175 EU Member States as 
well as the United Kingdom, United States, Norway, Switzerland, and Brazil. 7 of those were campaigns, 
and 476 were unique responses. Most answers came from Poland and Belgium, followed by Romania and 
Germany. 

An  Open  Public  Consultation176  (OPC)  was  open  from  6  February  2024  to  8  July  2024  on  the 
Commission’s centralised platform ‘Have your say’. It allowed the collection of information and views on 
the state of play of the corporate fleet market and whether the current pace of zero-emission vehicles take-up 
in corporate fleets is sufficient in the broader context of the transition to zero-emission mobility, as well as 
aspects  related  to  the  overall  affordability  of  zero-emission  vehicles  and  competitiveness  of  EU  market 
actors. In total, 268 participants responded to the OPC and 111 provided written contributions and position 

174  Clean  corporate  vehicles.  The  Call  for  evidence  was  published  initially  in  English  with  all  the  other  language 
translations published on 11 August 2025. 
175 MT and LU did not provide feedback. 
176 Greening corporate fleets 

70 

 
 
papers. Most respondents were from businesses and business associations (72%; 192), followed by NGOs 
(11%; 29), citizens (9%; 23) and public authorities (3%; 9). See the table below for more details on the 
responses.  

Respondents came from 26 EU Member States, with no responses being recorded from Luxembourg. Most 
replies correspond to Belgium (17.5%; 47), followed by Germany (16%; 43), France (12%; 32), and the 
Netherlands (8%; 21), Italy (6.5%; 17) with all other Member States having 15 replies or less. There were 
also participants from non-EU countries, namely Norway (5), the UK (4), the United States (2), Colombia 
(1) and Switzerland (1). More details on the OPC results are available on the Commission’s ‘Have your 
Say’177 website. 

Table 39: OPC and CfE respondents by stakeholder category 
Stakeholder category 

OPC responses 

CfE responses 

Company/Business 

Business association 

Non-governmental organisation (NGO) 

EU Citizen 

Public authority 

Other  

Academic/research institution  

Trade union  

Environmental organisation  

TOTAL 

118 

74 

29 

23 

9 

5 

3 

1 

1 

179 

156 

27 

96 

9 

6 

1 

5 

5 

268 

483 

Targeted stakeholder interviews were carried out between July and October 2025. These served to collect 
factual information and contextual data on current business practices, operational use-cases, and available 
data  on  vehicles  and  operations  from  most  affected  stakeholders.  This  evidence  supports  the  problem 
definition  and  helps  to  establish  the  baseline  scenario  for  the  impact  assessment.  21  interviews  were 
conducted, with 5 large logistics companies, 7 transport operators and associations (of which 5 representing 
primarily or  exclusively  SMEs),  5 vehicle leasing  and  rental  companies  and  associations  (3  representing 
leasing, 2 representing rental), 2 NGOs, 1 consumer organisation and 1 Original Equipment Manufacturer 
(OEM) association.   

In addition to collecting stakeholders’ views on the identified problems, different policy options, and their 
expected  impacts,  the  targeted  stakeholder  interviews  provided  detailed  information  about  the  market 
structure and business practices in the different corporate fleet segments, which helped confirm available 
information  from  previous  studies,  and  inform  the  modelling  assumptions  and  analysis.  These  covered 
aspects such as: typical fleet composition, vehicle mileage and retention rates for different types of corporate 
fleets;  use  cases  and  operational  requirements  of  different  fleets;  use  of  different  vehicle  types  and 
interactions between own fleet and sub-contractors in the different parts of the logistics chains (e.g. pick up 
and delivery, line haul, specialised transport of goods); typical contractual arrangements and types of sub-
contracting  along  the  different  steps  of  the  logistics  chains  (e.g.  long-term  contracts  and  spot  contracts, 
possibility  of  further  sub-contracting,  type  of  contractual  requirements  concerning  type  of  vehicle  and 
operations,  monitoring  reporting  requirements),  share  and  role  of  SMEs  in  different  types  of  fleets  and 
contractual arrangements. 

177 Greening corporate fleets 

71 

 
 
A  Strategic  dialogue  took  place  on  17  July  2025.  Counting  15  participating  stakeholders,  it  allowed 
representatives from the automotive industry associations, fleet operators, ride-hailing platforms, component 
suppliers, leasing companies, and other relevant parties to discuss with representatives from the Commission 
and establish a common position on some aspects of the electrification of corporate fleets and the broader 
push towards decarbonisation of road transport. The dialogue emphasized the need for a mix of intelligent 
policy  measures,  fiscal  incentives,  infrastructure  investment,  and  non-binding  national  targets,  while 
expressing a general preference against binding legislative mandates for light-duty vehicles. 

2.   STAKEHOLDER GROUPS 

The  consultation  activities  listed  above  targeted  a  wide  range  of  stakeholders  who  are  concerned  by  the 
regulatory intervention into the corporate fleets market. The following classification of major stakeholder 
groups was identified to support the participation of respondents to the various consultation activities, and 
are referred to in the rest of the annex: 

•  Public authorities. Member States’ ministries responsible for corporate fleets related policies in national 

governments. As such, they will be responsible for the overall implementation of this initiative.  

•  Automotive  Manufacturers  and  Suppliers.  Automotive  manufacturers  and  suppliers  are  key 
contributors  to  the  design,  production,  and  supply  of  vehicles  and  their  components.  They  play  a 
significant role in advancing vehicle technology and promoting innovations such as electrification and 
decarbonisation. Their insights are crucial in shaping industry standards and ensuring that policies align 
with technological capabilities and market readiness. 

•  Logistics  and  Mobility Service Operators:  Companies  operating  commercial  transport  and delivery 
fleets across various segments (e.g. freight, parcel, urban logistics), as well as providers of shared or on-
demand mobility services. They are key potential users of corporate ZEV fleets and contribute directly to 
the demand-side uptake under this initiative. 

•  Vehicle Rental and Leasing. Companies offering vehicles to corporate and individual clients through 
rental  or  leasing  contracts.  They  act  as  intermediaries  in  fleet  management  and  renewal,  and  can 
significantly influence the pace and scale of ZEV integration in corporate fleets. 

•  Mobility service operators. Mobility service operators provide shared mobility solutions such as car-
sharing,  ride-hailing,  and  on-demand  transport  services.  They  manage  dynamic  fleets  and  play  an 
important role in promoting the adoption of ZEV. 

•  NGOs.  Non-governmental  organizations  provide  advocacy  and  expertise  on  sustainable  mobility  and 
environmental issues. They contribute to policy discussions and help raise awareness by engaging with 
stakeholders and the broader public. 

The table below summarises the participation of these groups in the various consultation activities as well as 
both  EU  and  non-EU  countries  represented  by  the  respondents.  The  category  “others”  includes  those 
stakeholder groups who are only indirectly affected by the initiative or those who were less active in the 
consultation activities, i.e., NGOs, citizens, and academia/research institutes. 

Table 40: Participation of main stakeholder groups in the consultation activities 
Automotive 
Consultation 
Manufacturers 
activity 
and Suppliers 
including 
organisations 

Logistics 
and 
Mobility 
Service 
Operators 

Vehicle 
Rental 
and 
Leasing 

Public 
authorities 

Others  Total 

Geographical 
coverage 

Call for 
Evidence 
(CfE) 

10 

44 

97 

43 

282 

483  AT, BE, BG, CY, 

CZ, DE, DK, EE, ES, 
FI, FR, GR, HR, HU, 
IE, IT, LT, LV, NL, 
PL, PT, RO, SE, SI, 

72 

 
SK 

Non-EU: BR, CH, 
NO, UK, US 

192 

66 

268  AT, BE, BG, HR, 

4 

1 

5 

12 

2 

5 

4 

3 

CY, CZ, DK, EE, FI, 
FR, DE, GR, HU, IE, 
IT, LV, LT, MT, NL, 
PL, PT, RO, SK, SI, 
ES, SE  

Non-EU: UK, US, 
NO, CO, CH  

15 

Global 

21 

Global (EU-level 
associations, multi-
national 
organisations) 

Open Public 
Consultation 
(OPC) 

Strategic 
Dialogue 
Targeted 
interviews 

9 

– 

– 

3.   LIMITATIONS 

There are several limitations to the stakeholder consultation process that warrant being mentioned: 

•  The initial stakeholder consultation phase (beginning with the OPC in 2024) took place in preparation of 
the Communication “Decarbonise Corporate Fleets” 178 and did not allow to collect sufficient data on 
the direct and indirect costs arising from a legislative initiative in this area. Therefore, complementary 
targeted consultation activities had to be carried out subsequently.  

•  The policy options under this initiative were refined after the OPC related to the Communication, and 
some meetings with stakeholders had taken place. Consequently, some early consultations did not fully 
reflect the final policy design. Nonetheless, a CfE was conducted to specifically support this legislative 
initiative, allowing stakeholders to share their views on the policy intervention logic and the nature of the 
possible policy options that could address the problems identified. 

•  There was a high share of non-responses and uncertainty across many questions included in the 
OPC questionnaire. There was a very high proportion of “no opinion” or non-responses, particularly on 
the questions related to heavy-duty vehicles and specific fleet types. This suggests significant uncertainty 
or lack of knowledge among stakeholders, reducing the depth of the collected views.  

•  There was a low engagement on specific fleet categories. The granularity of the OPC questionnaire 
(e.g. different fleet subtypes like large logistics vans or corporate coaches) was not matched by equally 
detailed input. Many specific fleet categories saw more than 60% of respondents either not answering or 
expressing no opinion, limiting the usefulness of disaggregated data. 

4.   OUTCOME OF THE CONSULTATION ACTIVITIES 

The following sections  present a description of stakeholder views on the  problems this initiative aims to 
address, on the problem drivers that have been identified, as well as on the policy options analysed in the 
context of this initiative.  

A)  Problems targeted by this initiative 

178 Greening corporate fleets 

73 

 
 
 
 
 
 
i.  The uptake of zero-emission vehicles in corporate fleets (cars, vans and lorries) is 

low 

Stakeholders broadly agree that the uptake of ZEVs in corporate fleets remains too limited to align with the 
EU’s climate and industrial policy goals. According to 49% of respondents to the OPC (131 out of 267 that 
responded to this question), increasing the share of ZEVs in the total number of vehicles registered in the 
EU, compared to what would result from the CO2 emission performance standards alone, is very relevant or 
relevant.   

When asked about the expected impacts of a faster shift towards ZEVs in corporate fleets, many respondents 
who replied to the question identified potential very positive or positive benefits in terms of emission savings 
(59%; 157) and decrease in price of new and second-hand ZEVs (48%; 112).  

In the CfE, 72.3% of respondents (344 of 483) identified high upfront costs and uncertainty over total cost of 
ownership as major obstacles to the uptake of ZEVs in corporate fleets, while 54.4% of respondents (259 of 
483) cited insufficient access to reliable public and depot charging infrastructure. Other barriers include the 
limited  availability  of  suitable  ZEV  models  for  certain  operational  needs  (38.7%;  184  respondents)  and 
uncertainty  over  vehicle  resale  values  (24.6%;  117  respondents)  (especially  SMEs,  logistics  operators, 
electric  vehicles  and  alternative-fuels  refuelling  and  charging  infrastructure  providers,  logistics  services 
companies, rental companies, road haulage operators, and passenger transport services). Around one-third of 
the  CfE  respondents  highlighted  fiscal  measures  as  a  key  barrier,  with  many  SMEs  and  fleet  operators 
stressing  that  short-term  or  fragmented  incentives  undermine  investment  predictability.  These  challenges 
make corporate transition to ZEVs slow and uneven across market segments and Member States, reducing 
the pace at which cleaner vehicles are deployed.  

In  the  targeted  stakeholders  interviews,  this  problem  was  highlighted  particularly  by  NGOs,  OEM  and 
consumer organisations, but all other participants also recognised it. Targeted interviews also showed that 
some companies are already moving quicker towards ZEV than the overall market, but this is generally the 
case of few more tightly integrated companies, while those engaged in more distributed business are moving 
slower. At the same time, some of the logistics companies and transport associations expressed scepticism 
about the current operational and economic viability of using ZEV for some use cases. Leasing and rental 
companies associations noted the current uncertainty about ZEV residual values as one of the main barriers 
preventing a higher share of ZEVs in corporate fleets. 

ii.  The  availability  of  affordable  zero-emission  vehicles  is  insufficient  to  ensure  a 

fair transition  

Stakeholders also emphasised that limited affordability and accessibility of ZEVs hinder a fair and inclusive 
transition. Many respondents highlighted that the higher purchase price of ZEVs, coupled with uncertain 
residual values and immature second-hand markets, keeps total ownership costs high particularly for SMEs 
and smaller operators.  

In the 2024 OPC, up to 67% of respondents out of the 247 who answered the relevant questions for specific 
fleets indicated that cost-related factors - including purchase price, operational expenses, and total cost of 
ownership - are very important or important in determining fleet operators’ willingness to include ZEVs in 
their fleets, especially for goods operation fleets such as vans and lorries179. Some respondents to the CfE 
(5.6%; 27 of 483) expect that, as supply increases and remarketing becomes routine, entry prices and lease 

179  Fiscal  factors  –  including  vehicle  registration  tax,  annual  vehicle  tax  and  fiscal  treatment  of  vehicles  –  were 
considered  important  by  up  to  65%  of  respondents,  across  nearly  all  fleets.  The  availability  of  infrastructure  (both 
public and private in depots) was considered important by up to 60% of respondents.  

74 

 
 
rates for second-hand ZEVs will decrease. However, most caution that without stronger policy support and 
market maturity, affordable options for citizens and small businesses will remain scarce. This situation risks 
widening  disparities  between  large  corporate  fleets  able  to  electrify  early  and  smaller  operators  or 
households that depend on affordable used vehicles. 

This problem was highlighted in particular by consumer and transport operators associations representing 
SMEs. Leasing companies and associations highlighted the option of second lease of vehicles as a possible 
solution to address uncertainties about ZEV residual value while providing more affordable leasing options.   

B)  Problem drivers 

i.  Fragmented support framework at national level for corporate ZEV 

One of the main problem drivers contributing to the low uptake of zero-emission vehicles in corporate fleets 
is the fragmented and inconsistent support framework across Member States. National, regional, and local 
policies  vary  widely  in  scope  and  ambition,  leading  to  regulatory  uncertainty  and  limiting  cross-border 
consistency. Moreover, the CO₂ standards for new light- and heavy-duty vehicles focus on the supply side 
(vehicle manufacturers), with no comparable EU-level legislation targeting the demand for ZEVs.  

Out of the respondents to the CfE, 36.6% (174 of 483) reported that existing tax rules and incentives are 
either insufficient, inconsistent across Member States, or volatile, undermining business cases and long-term 
fleet planning.   

These  views  were  echoed  in  the  responses  to  the  OPC.  Several  stakeholders,  including  vehicle 
manufacturers  and  fleet  operators,  reported  that  national  policy  levers  -  such  as  fiscal  and  non-fiscal 
incentives  supporting  fleet  purchase  decisions  -  are  unevenly  applied  and  often  underutilised  in  many 
Member States. This results in inconsistent demand signals for ZEVs, despite improvements in larger fleets 
and among leading companies.  

As shown in Figure 3, around half of the 267 respondents to the OPC (47.6% for cars, 50% for vans, 49% 
for lorries, and 39.7% for coaches) indicated that the current share of ZEV registered by corporate entities is 
not sufficient to meet the European Green Deal targets. The share of respondents who did not answer or 
expressed  no  opinion  was  significantly  higher  for  heavy-duty  vehicles  compared  to  light-duty  vehicles, 
indicating greater uncertainty for these vehicle types and further highlighting the fragmented landscape. 

Figure  3:  Views  on  whether  the  share  of  zero-emission  vehicles  currently  registered  by  corporate  entities  is 
sufficient to fulfil European Green Deal targets (267 OPC respondents)  

As  shown  in  Figure  4Table  16,  when  asked  whether  corporate  vehicles  should  switch  to  zero-emission 
options faster than private vehicles, between 38% and 47% of respondents to the OPC (depending on the 

75 

 
 
type  of  vehicle)  agreed  or  strongly  agreed  with  this  statement.  Between  15%  and  33%  of  respondents 
disagreed  or  strongly  disagreed.  Notably, the share of  respondents  who  did not  answer or  expressed  no 
opinion was significantly higher for heavy-duty vehicles compared to light-duty vehicles. 

Figure 4: Views on the need to switch faster towards zero-emission vehicles in corporate registrations than in private 
ones (267 OPC respondents) 

Participants in the targeted stakeholders interviews also highlighted this issue; in particular, OEM, NGO and 
transport operators associations highlighted the need to ensure a positive TCO and better access to finance in 
order to allow an economically viable transition to ZEV in corporate fleets. 

ii.  High  purchase  costs  and  operational  constraints  of  ZEVs  compared  to 

conventional vehicles  

Corporate vehicles are typically driven more intensively and replaced more frequently than privately owned 
vehicles. As a result, economic and operational considerations weigh heavily on fleet managers’ decisions. 
While the costs of ZEVs are decreasing, their higher upfront purchase prices remain a significant barrier, 
particularly in the absence of tailored financing solutions. This is especially true for SMEs, which often face 
limited access to financial products that could help cover initial investment costs.  

A majority of respondents to the CfE (72.3%; 344 of 483) stated that ZEVs still have higher purchase prices 
and uncertain total cost of ownership (e.g., residual values, financing terms), especially in use cases with 
specific operational requirements. 8.7% of respondents to the CfE (26 of 483) mentioned that SMEs would 
be disproportionately affected by ZEV costs.  

Operational  constraints  also  play  a  role.  The  limited  driving  range  of  some  ZEV  models,  charging 
availability, and specific operational requirements - such as high daily mileage or payload capacity  - can 
limit  the  suitability  of  ZEVs  for  certain  use  cases,  particularly  for  commercial  and  high-mileage  fleets. 
Moreover, 38.7% of respondents to the CfE (184 of 483), mostly heavy- and medium-duty operators (e.g. 
coach),  emphasise  that  current  ZEV  options  for  long-haul  and demanding duty  cycles  remain limited  or 
operationally challenging. For specific routes or high-payload missions, current ZEV range or weight trade-
offs are challenging. Some also report model gaps or long delivery times for specific configurations.  

These  economic  and  operational  barriers  hinder  a  stronger  uptake  of  ZEVs  in  corporate  fleets  and 
consequently  delay  the  trickle-down  of  ZEVs  to  the  second-hand  market.  This  limits  the  availability  of 
affordable clean vehicles for citizens and SMEs. In the absence of effective EU-level demand-side measures 
and  clear  market  signals,  these  issues  are  likely  to  persist  and  will  continue  to  undermine  both  the 
decarbonisation of transport fleets and the EU’s broader climate and industrial policy objectives. 

76 

 
 
This  problem  driver  was  consistently  highlighted  by  large  logistics  companies,  transport  operators  and 
associations, and leasing and rental companies and associations in the context of the targeted stakeholder 
consultations.  Logistics  companies  noted  in  particular  barriers  and  delays  in  the  availability  of  sufficient 
recharging  options  for  their  fleets,  both  at  the  depot  and  on  the  road;  rental  companies  highlighted  the 
operational constraints of recharging vehicles in a short time between rentals in peak season, as well as the 
higher purchase costs (which are not compensated by fuel and operational costs savings, as these benefit the 
clients rather than the rental company) and apparent low demand from customers; leasing companies and 
associations generally focused on the uncertainty about residual value rather than the purchase cost itself; 
transport  operators  noted  both  the  high  purchase  costs  and  specific  operational  constraints,  such  as 
insufficient recharging infrastructure availability for taxi and ride-hailing vehicles.  

C)  Stakeholder positions on the proposed policy options 

The following section summarises stakeholder inputs and views on several policy options aimed to address 
the problem drivers described in the previous section. The section focuses on three themes that emerged as 
critical from stakeholder responses: benefits of the policy options, impacts on the second-hand market, and 
monitoring and reporting. 

1.  Overall position towards policy options 

45.4% of respondents to the CfE (216 of 483) emphasise that firm EU signals would strengthen European 
manufacturing and supply chains, support job creation, and sustain industrial leadership in zero-emission 
technologies.  Among  those  expressing  a  clear  position,  financial-incentive-based  options  were  broadly 
supported,  while  support  for  ZEV  mandates  was  more  limited.  Opposition  to  mandates  was  particularly 
strong among leasing, rental, and haulage/logistics stakeholders, who cited residual-value risks, operational 
feasibility, and competitiveness concerns. Conversely, NGOs, public authorities, mobility service providers, 
infrastructure  providers,  and  OEMs  were  generally  supportive  of  ZEV  mandates,  particularly  at  the 
corporate level, which they considered as credible demand signals for accelerating fleet decarbonisation. 

The  analysis  indicates  that  infrastructure  providers  and  civil  society  representatives  exhibited  the  highest 
share of support, albeit still below 50% within each group (44% and 38%, respectively). By contrast, final 
customers (mostly EU citizen) and rental associations expressed the highest share of critical views (71%). 
SMEs  consistently  highlighted  risks  associated  with  rigid  mandates  applied  before  sufficient  supply  and 
charging  availability,  while  expressing  strong  support  for  predictable  and  technology-neutral  financial 
incentives. 

During the  targeted  interviews,  stakeholders  repeated  their  positions on  the broader  options  expressed  as 
feedback on the CfE, but specifically NGOs were strongly favourable to the proposal, OEM and consumer 
associations  were  generally  supportive  with  caveats.  Opinions  expressed  by  large  logistics  companies, 
transport operators and associations were mixed, with some opposing any initiative and others indicating 
support  for  some  measures,  with  caveats  such  as  requiring  flexibility  or  avoiding  stringent  mandates. 
Leasing and rental companies and their associations generally expressed doubts about the need for an EU 
intervention  and  its  potential  impacts,  mostly  opposing  the  idea  of  mandates.  Freight  transport  operators 
specifically expressed concerns about possible mandates on shippers, noting that they would not expect to be 
able to pass on the extra costs of switching to ZEV to the shippers. 

2.  Policy options: benefits, second-hand market, monitoring and reporting 

i.  Benefits of the policy options 

Stakeholders  widely  acknowledged  that  the  options  could  contribute  to  strengthening  European 
manufacturing and supply chains, supporting jobs and demonstrating industrial leadership in zero-emission 
technologies. Most stakeholder groups highlighted that corporate fleets account for a significant share of 

77 

 
new  vehicle  registrations  and  mileage,  and  therefore  accelerated  fleet  electrification  could  generate 
meaningful reductions in transport-related CO₂ emissions. 40.3%  of those that provided feedback to the CfE 
(192  of  483)  see  the  proposed  policy  options  as  directly  accelerating  fleet  decarbonisation  and  helping 
Member States meet climate goals. Civil society and urban passenger transport stakeholders also noted co-
benefits in terms of air quality and noise reduction. 

Some  SME  respondents  indicated  that  well-designed  options,  including  continued  fiscal  support,  could 
soften investment costs and bring total cost of ownership closer to parity with conventional vehicles. Several 
also emphasised that clear policy direction could stimulate infrastructure deployment and give smaller fleets 
more certainty when planning fleet renewals. 

ii. 

Impacts on the second-hand market 

Several stakeholders expect that ZEV mandates would increase corporate fleet turnover and, in turn, release 
greater volumes of used ZEVs into the second-hand market.  

10.5% of respondents to the CfE (50 of 483) expect that corporate ZEV targets will accelerate new-vehicle 
uptake and, after the first ownership cycle, release larger volumes of used electric vehicles into the market, 
expanding  choice  and  buyer  confidence. These  effects  were  expected  to  broaden  choice,  improve 
confidence, and enable wider adoption among cost-sensitive buyers, notably SMEs and citizens. According 
to 26.1% of respondents to the CfE (124 of 483), faster new-vehicle uptake is expected to deepen used-
market supply, stabilise residual values, and improve affordability for SMEs and citizens. Stakeholders also 
highlighted that greater market scale could lead to lower entry prices and leasing costs in the second-hand 
channel, and, over time, more stable residual values, particularly if battery health reporting and warranties 
become standardised. 

However, many respondents, particularly rental and leasing companies, cautioned that the used-ZEV market 
remains  immature  in  the  short  term.  Limited  availability  and  price  volatility  may  persist  until  turnover 
accelerates and remarketing practices become routine. SMEs highlighted that extended lease durations and 
‘second-life’ contracts further delay the entry of ZEVs into the second-hand market, which could undermine 
affordability and confidence among smaller operators. In targeted interviews, the same was confirmed by 
several stakeholders. 

iii.  Monitoring and reporting 

Monitoring and reporting requirements arising from ZEV mandates at company level were highlighted as 
potential  sources  of  administrative  burden  and  cost.  Stakeholders  expressed  concern  regarding  reporting 
frequency, system development, and ongoing submission costs. 16.2% of respondents to the CfE (77 of 483) 
anticipated  additional  paperwork  and  ongoing  compliance  overhead  (collection,  validation,  submissions), 
warning that new requirements could be disproportionate to the policy gains if not carefully designed. SMEs 
emphasised  that  alignment  with  existing  EU  frameworks  (e.g.,  CSRD/ESRS,  AFIR,  CO₂  standards,  EU 
ETS2)  and  standardised  reporting  templates  would  be  necessary  to  avoid  duplication.  Some  CfE 
respondents (4.2%; 20) warned against burdensome reporting and changing rules and reporting burdens that 
add  risk  or  cost.  Phased  implementation,  use  of  digital  tools,  and  proportionate  verification  rules  were 
frequently cited as important to avoid disproportionate burdens for smaller operators. 

78 

 
  
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

The  primary  objective  of  the  initiative  is  to  support  the  decarbonisation  of  the  road  transport  sector  by 
accelerating  the  shift  to  zero-emission  vehicles  in  corporate  fleets,  thereby  reducing  greenhouse  gas 
emissions  and  air  pollutant  emissions,  supporting  the  market  uptake  of  zero-emission  vehicles  and 
safeguarding the competitiveness of the European automotive industry. 

The costs and benefits of the preferred policy option are expected to fall on different stakeholder groups: 
businesses, citizens and national public authorities. 

Businesses will mainly benefit from reduced fuel and other operation costs resulting from the higher share 
of ZEVs in their fleets in the case of large companies; the reduction in fuel consumption will also lead to 
lower  fuel  tax  expenditures.  Assuming  vehicle  manufacturers  do  not  exceed  the  share  of  ZEV  in  new 
registrations  required  to  meet  their  emission  reduction  targets  under  the  CO2  standards,  SMEs  will  be 
indirectly affected by a lower availability of new ZEVs, deriving from  the increased ZEV demand  from 
large  companies.  A  higher  share  of  new  conventional vehicles  will  lead  to  an increase in  fuel  and  other 
operation costs for SMEs, which will be partly offset by reductions in fuel and other operation costs deriving 
from  the  higher  uptake  of  ZEV  in  the  second-hand  market.  Businesses  will  not  incur  direct  additional 
administrative burdens, as reporting under the preferred policy option will be done by Member States based 
on the existing national vehicle registers.  

Citizens are not directly affected by the preferred policy option, but they may be indirectly affected by the 
resulting  evolution  of  the  ZEVs  in  different  market  segments.  Assuming  vehicle  manufacturers  do  not 
exceed the share of ZEV in new registrations required to meet their emission reduction targets under the CO2 
standards, the increased demand of zero-emission corporate vehicle will result in a lower number of new 
ZEVs  available  for  citizens.  As  a  result,  citizens  that  purchase  new  vehicles  will  favour  conventional 
vehicles, facing lower capital costs but higher fuel costs and fuel tax expenditures relative to the baseline. On 
the other hand, citizens that purchase second-hand vehicles will benefit from a higher uptake of second-hand 
ZEV relative to baseline, resulting in fuel and other operation costs savings. Citizens will also experience 
overall fuel cost savings when renting or leasing a vehicle, resulting from an increased share of ZEVs in 
leasing and rental markets; these are likely to be partially offset by increased leasing and rental prices as 
large rental and leasing companies may face higher purchase costs for new ZEVs and uncertainties about 
their residual values, which are likely to be partially passed on to their customers.  

National  public  authorities  will  be  able  to  monitor  and  report  on  their  national  targets  by  extracting 
relevant data from vehicle registers and submitting it annually to the Commission, which will entail limited 
one-off and recurrent administrative costs. Energy tax revenues collected by national public authorities will 
also be affected. The increased uptake of ZEV by large companies will result in a reduction of tax revenues 
relative to the baseline, due to the decrease in fossil fuel use. This will be partly offset by some additional tax 
revenues due to the shift from new ZEV to new conventional vehicles for citizens and SMEs.  The faster 
deployment of ZEV in the second-hand market will also lead to additional fossil fuel savings and associated 
losses in tax revenues.  

79 

 
 
From a societal perspective, the initiative brings benefits in terms of reductions in greenhouse gas emissions, 
air pollutant emissions and noise emissions. These result both from the increase in new ZEVs in vehicle 
fleets  with  higher  yearly  mileage  –  leading  to  a  higher  reduction  in  real-world  fuel  consumption  and 
emissions per vehicle – and from the faster availability of second-hand ZEVs, leaving to an overall increase 
of the share of ZEVs on the roads. 

2.  SUMMARY OF COSTS AND BENEFITS  

2.1.  PREFERRED OPTION (PO1A) 

I. Overview of Benefits (total for all provisions) – Preferred Option (PO1A) 

Description 

Amount 

Comments 

Direct benefits 

Adjustment costs 
savings for large 
companies, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in fuel tax 
expenditures for large 
companies, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Adjustment costs 
savings for SMEs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Reduction in fuel tax 
expenditures for 
SMEs, expressed as 
present value over 
2029-2050 relative to 
the baseline 

Adjustment costs 
savings for citizens, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Reduction in fuel tax 
expenditures for 
citizens, expressed as 
present value over 
2029-2050 relative to 
the baseline 

Additional fuel tax 
revenues for national 
public authorities, 
expressed as present 
value over 2029-2050 
relative to the baseline 

EUR 23.4 
billion 

Adjustment costs savings due to an increase in the number of new ZEVs in 
corporate  fleets  by  large  companies.  Adjustment  cost  savings  for  large 
companies  are  estimated  at  EUR  23.4  billion  expressed  as  present  value 
over 2029-2050, relative to the baseline. 

EUR 16.9 
billion  

Reduction  in  fuel  tax  expenditures  due  to  the  reduction  in  fossil  fuel 
consumption resulting from the higher uptake of new ZEVs. The reduction 
in  fuel  tax  expenditures  for  large  companies  is  estimated  at  EUR  16.9 
billion expressed as present value over 2029-2050, relative to the baseline. 

EUR 9.5 
billion 

EUR 0.8 
billion 

EUR 2.2 
billion  

EUR 0.6 
billion  

Indirect benefits 

Adjustment  costs  savings  due  to  higher  uptake  of  second-hand  ZEV  by 
SMEs, as a result of faster uptake of new ZEV in corporate fleets by large 
companies.  Adjustment  cost  savings  for  SMEs  are  estimated  at  EUR  9.5 
billion expressed as present value over 2029-2050 relative to the baseline. 

Reduction  in  fuel  tax  expenditures  for  SMEs  due  to  the  higher  uptake  of 
second-hand  ZEVs.  The  reduction  in  tax  expenditures  for  SMEs  is 
estimated  at  EUR  0.8  billion  expressed  as  present  value  over  2029-2050 
relative to the baseline. 

Adjustment  costs  savings  due  to  higher  uptake  of  second-hand  ZEV  by 
citizens, as a result of faster uptake of new ZEV in corporate fleets by large 
companies. Adjustment cost savings for citizens are  estimated at EUR  2.2 
billion expressed as present value over 2029-2050 relative to the baseline.  

Reduction in fuel tax expenditures for citizens due  to the higher uptake of 
second-hand  ZEVs.  The  reduction  in  tax  expenditures  for  citizens  is 
estimated  at  EUR  0.6  billion  expressed  as  present  value  over  2029-2050 
relative to the baseline. 

EUR 13.5 
billion 

Additional  tax  revenues  for  public  authorities  due  to  an  increase  in  fossil 
fuel use, following the assumed shift from new ZEVs to new conventional 
vehicles in the short to medium term by citizens and SMEs. The additional 
tax  revenues  for  public  authorities  are  estimated  at  EUR  13.5  billion, 
expressed as present value over 2029-2050 relative to the baseline. 

80 

 
 
 
 
 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO1A) 

Description 

Savings in external 
costs of CO2 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in CO2 
emissions (cumulative 
over 2029-2050 
relative to the 
baseline) 

Savings in external 
costs of air pollution 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in air 
pollution emissions 
(cumulative over 
2029-2050 relative to 
the baseline) 

Savings in external 
costs of noise 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Indirect benefits to 
vehicle manufacturers 

Amount 

EUR 1.6 
billion  

Comments 

Indirect  benefit  to  society  at  large.  Savings  in  external  costs  of  CO2 
emissions  due  to  the  higher  uptake  of  ZEV  in  the  fleet.  The  savings  in 
external costs of CO2 emissions are estimated at EUR 1.6 billion expressed 
as present value over 2029-2050 relative to the baseline. 

10 million 
tonnes 

Indirect  benefit  to  society  at  large.  The  reduction  in  CO2  emissions  is 
estimated at 10 million tonnes, cumulatively over 2029-2050 relative to the 
baseline. 

EUR 0.2 
billion  

Indirect benefit to society at large. Savings in external costs of air pollution 
emissions  due  to  the  higher  uptake  of  ZEV  in  the  fleet.  The  savings  in 
external  costs  of  air  pollution  emissions  are  estimated  at  EUR  0.2  billion 
expressed as present value over 2029-2050 relative to the baseline.  

15 thousand 
tonnes of NOx 
and 0.3 
thousand 
tonnes of 
PM2.5 

EUR 0.1 
billion 

Indirect  benefit  to  society  at  large.  Cumulatively  over  2029-2050,  the 
reduction in NOx and PM2.5 emissions is estimated at 15 thousand tonnes 
and 0.3 thousand tonnes, respectively (relative to the baseline). 

Indirect  benefit  to  society  at  large.  Savings  in  external  costs  of  noise 
emissions due to the higher uptake of ZEV. The savings in external costs of 
noise emissions are estimated at EUR 0.1 billion expressed as present value 
over 2029-2050 relative to the baseline. 

Not quantified  Create  greater  certainty  and  better  conditions  for  investment  in  ZEV 
manufacturing  capacity,  and  reduce  individual  manufacturers’  risk  of  not 
meeting their targets under CO2 standards Regulations.  

II. Overview of costs – Preferred option (PO1A) 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct adjustment costs 
(expressed as present value 
over 2029-2050 relative to 
the baseline) 

- 

- 

- 

- 

For large 
companies:  
EUR 6.4 
billion 
(capital 
costs) 

For large 
companies: 
EUR 1.9 
billion (fuel 
costs and 
other 
operation 
costs)  

Direct administrative costs 
(expressed as present value 
over 2029-2050 relative to 
the baseline) 

- 

- 

- 

- 

For national 
administrations: 
EUR 0.23 
million  

For national 
administrations: 
EUR 0.17 
million  

For EEA:          

For EEA:          
EUR 0.44 

81 

 
 
 
 
 
II. Overview of costs – Preferred option (PO1A) 

Indirect costs (expressed 
as present value over 
2029-2050 relative to the 
baseline) 

For 
citizens: 
EUR 0.6 
billion 
capital 
costs 

For SMEs: 
EUR 1 
billion 
capital costs 

For citizens: 
EUR 9.1 
billion of 
which: 
-  EUR 5.3 
billion fuel 
costs and 
other 
operation 
costs 

- EUR 3.8 
billion 
increase in 
fuel tax 
expenditures 

For SMEs: 
EUR 24.8 
billion of 
which: 
- EUR 15.1 
billion fuels 
costs and 
other 
operation 
costs 

- EUR 9.7 
billion 
increase in 
fuel tax 
expenditures 

EUR 25,000 

million 

- 

For national 
administrations: 
EUR 18.4 
billion losses in 
tax revenues  

III. Application of the ‘one in, one out’ approach – Preferred option (PO1A) 

[M€] 

One-off 

Recurrent 

Total 

(annualised total net present 
value over the relevant period) 

(nominal values per year) 

Businesses 

New administrative 
burdens (INs) 

Removed 
administrative burdens 
(OUTs) 

Net administrative 
burdens 

Adjustment costs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Citizens 

New administrative 
burdens (INs) 

Removed 
administrative burdens 
(OUTs) 

Net administrative 
burdens 

- 

- 

- 

- 

- 

- 

For large companies:  
EUR 6.4 billion capital costs  

For SMEs (indirect costs): 
EUR 1 billion capital costs  

For large companies: 
EUR 1.9 billion fuel costs and 
other operation costs  
For SMEs (indirect costs):  
EUR 24.8 billion of which: 
- EUR 15.1 billion fuels costs 
and other operation costs 
- EUR 9.7 billion increase in 
fuel tax expenditures 

- 

- 

- 

- 

- 

- 

82 

- 

- 

- 

- 

- 

- 

 
 
 
 
 
 
 
 
 
III. Application of the ‘one in, one out’ approach – Preferred option (PO1A) 

Adjustment costs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Total administrative 
burdens 

For citizens (indirect costs): 
EUR 0.6 billion capital costs 

For citizens (indirect costs): 
EUR 9.1 billion of which: 
-  EUR 5.3 billion fuel costs and 
other operation costs 
- EUR 3.8 billion increase in 
fuel tax expenditures 

- 

- 

- 

Note: Adjustment costs and other indirect costs are reported for transparency but are not included in the calculation of 
the net administrative burden, in line with the ‘one in, one out’ approach. 

2.2.  PREFERRED OPTION (PO1B) 

I. Overview of Benefits (total for all provisions) – Preferred Option (PO1B) 

Description 

Amount 

Comments 

Direct benefits 

Adjustment costs 
savings for large 
companies, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in fuel tax 
expenditures for large 
companies, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Adjustment costs 
savings for SMEs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Reduction in fuel tax 
expenditures for 
SMEs, expressed as 
present value over 
2029-2050 relative to 
the baseline 

Adjustment costs 
savings for citizens, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Reduction in fuel tax 
expenditures for 
citizens, expressed as 
present value over 
2029-2050 relative to 
the baseline 

Additional fuel tax 
revenues for national 

EUR 32.7 
billion 

Adjustment costs savings due to an increase in the number of new ZEVs in 
corporate  fleets  by  large  companies.  Adjustment  cost  savings  for  large 
companies  are  estimated  at  EUR  32.7  billion  expressed  as  present  value 
over 2029-2050, relative to the baseline. 

EUR 24.1 
billion  

Reduction  in  fuel  tax  expenditures  due  to  the  reduction  in  fossil  fuel 
consumption resulting from the higher uptake of new ZEVs. The reduction 
in  fuel  tax  expenditures  for  large  companies  is  estimated  at  EUR  24.1 
billion expressed as present value over 2029-2050, relative to the baseline. 

Indirect benefits 

EUR 12.9 
billion 

Adjustment  costs  savings  due  to  higher  uptake  of  second-hand  ZEV  by 
SMEs, as a result of faster uptake of new ZEV in corporate fleets by large 
companies.  Adjustment  cost  savings  for  SMEs  are  estimated  at  EUR  12.9 
billion expressed as present value over 2029-2050 relative to the baseline. 

EUR 1.5 
billion 

Reduction  in  fuel  tax  expenditures  for  SMEs  due  to  the  higher  uptake  of 
second-hand  ZEVs.  The  reduction  in  tax  expenditures  for  SMEs  is 
estimated  at  EUR  1.5  billion  expressed  as  present  value  over  2029-2050 
relative to the baseline. 

EUR 4 billion   Adjustment  costs  savings  due  to  higher  uptake  of  second-hand  ZEV  by 
citizens, as a result of faster uptake of new ZEV in corporate fleets by large 
companies.  Adjustment  cost  savings  for  citizens  are  estimated  at  EUR  4 
billion expressed as present value over 2029-2050 relative to the baseline.  

EUR 2.1 
billion  

Reduction in fuel tax expenditures for citizens due to the higher uptake of 
second-hand  ZEVs.  The  reduction  in  tax  expenditures  for  citizens  is 
estimated  at  EUR  2.1  billion  expressed  as  present  value  over  2029-2050 
relative to the baseline. 

EUR 16.6 

Additional  tax  revenues  for  public  authorities  due  to  an  increase  in  fossil 
fuel use, following the assumed shift from new ZEVs to new conventional 

83 

 
 
 
 
 
 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO1B) 

Description 

Amount 

Comments 

public authorities, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Savings in external 
costs of CO2 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in CO2 
emissions (cumulative 
over 2029-2050 
relative to the 
baseline) 

Savings in external 
costs of air pollution 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in air 
pollution emissions 
(cumulative over 
2029-2050 relative to 
the baseline) 

Savings in external 
costs of noise 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Indirect benefits to 
vehicle manufacturers 

billion 

vehicles in the short to medium term by citizens and SMEs. The additional 
tax  revenues  for  public  authorities  are  estimated  at  EUR  16.6  billion, 
expressed as present value over 2029-2050 relative to the baseline. 

EUR 3.7 
billion  

Indirect  benefit  to  society  at  large.  Savings  in  external  costs  of  CO2 
emissions  due  to  the  higher  uptake  of  ZEV  in  the  fleet.  The  savings  in 
external costs of CO2 emissions are estimated at EUR 3.7 billion expressed 
as present value over 2029-2050 relative to the baseline. 

23.7 million 
tonnes 

Indirect  benefit  to  society  at  large.  The  reduction  in  CO2  emissions  is 
estimated  at  23.7  million  tonnes,  cumulatively  over  2029-2050  relative  to 
the baseline. 

EUR 0.5 
billion  

Indirect benefit to society at large. Savings in external costs of air pollution 
emissions  due  to  the  higher  uptake  of  ZEV  in  the  fleet.  The  savings  in 
external  costs  of  air  pollution  emissions  are  estimated  at  EUR  0.5  billion 
expressed as present value over 2029-2050 relative to the baseline.  

25 thousand 
tonnes of NOx 
and 0.8 
thousand 
tonnes of 
PM2.5 

EUR 0.2 
billion 

Indirect  benefit  to  society  at  large.  Cumulatively  over  2029-2050,  the 
reduction in NOx and PM2.5 emissions is estimated at 25 thousand tonnes 
and 0.8 thousand tonnes, respectively (relative to the baseline). 

Indirect  benefit  to  society  at  large.  Savings  in  external  costs  of  noise 
emissions due to the higher uptake of ZEV. The savings in external costs of 
noise emissions are estimated at EUR 0.2 billion expressed as present value 
over 2029-2050 relative to the baseline. 

Not quantified  Create  greater  certainty  and  better  conditions  for  investment  in  ZEV 
manufacturing  capacity,  and  reduce  individual  manufacturers’  risk  of  not 
meeting their targets under CO2 standards Regulations.  

II. Overview of costs – Preferred option (PO1B) 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct adjustment costs 
(expressed as present value 
over 2029-2050 relative to 
the baseline) 

- 

- 

- 

- 

For large 
companies:  
EUR 9.3 
billion 
(capital 
costs) 

For large 
companies: 
EUR 2.6 
billion (fuel 
costs and 
other 
operation 
costs)  

Direct administrative costs 
(expressed as present value 

- 

- 

- 

- 

For national 
administrations: 

For national 
administrations: 

84 

 
 
 
 
II. Overview of costs – Preferred option (PO1B) 

over 2029-2050 relative to 
the baseline) 

Indirect costs (expressed 
as present value over 
2029-2050 relative to the 
baseline) 

For 
citizens: 
EUR 0.6 
billion 
capital 
costs 

For SMEs: 
EUR 1 
billion 
capital costs 

For citizens: 
EUR 11.5 
billion of 
which: 
-  EUR 7.2 
billion fuel 
costs and 
other 
operation 
costs 

- EUR 4.3 
billion 
increase in 
fuel tax 
expenditures 

For SMEs: 
EUR 32.1 
billion of 
which: 
- EUR 19.9 
billion fuels 
costs and 
other 
operation 
costs 

- EUR 12.2 
billion 
increase in 
fuel tax 
expenditures 

EUR 0.23 
million  

EUR 0.17 
million  

For EEA:          
EUR 25,000 

- 

For EEA:          
EUR 0.44 
million 

For national 
administrations: 
EUR 27.7 
billion losses in 
tax revenues  

III. Application of the ‘one in, one out’ approach – Preferred option (PO1B) 

[M€] 

One-off 

Recurrent 

Total 

(annualised total net present 
value over the relevant period) 

(nominal values per year) 

Businesses 

New administrative 
burdens (INs) 

Removed 
administrative burdens 
(OUTs) 

Net administrative 
burdens 

Adjustment costs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Citizens 

New administrative 
burdens (INs) 

Removed 
administrative burdens 

- 

- 

- 

- 

- 

- 

For large companies:  
EUR 9.3 billion capital costs  

For large companies: 
EUR 2.6 billion fuel costs and 
other operation costs  

For SMEs (indirect costs): 
EUR 1 billion capital costs  

For SMEs (indirect costs):  
EUR 32.1 billion of which: 
- EUR 19.9 billion fuels costs 
and other operation costs 
- EUR 12.2 billion increase in 
fuel tax expenditures 

- 

- 

85 

- 

- 

- 

- 

- 

- 

- 

 
 
 
 
 
 
 
 
 
 
III. Application of the ‘one in, one out’ approach – Preferred option (PO1B) 

(OUTs) 

Net administrative 
burdens 

Adjustment costs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

- 

- 

For citizens (indirect costs): 
EUR 0.6 billion capital costs 

For citizens (indirect costs): 
EUR 11.5 billion of which: 
-  EUR 7.2 billion fuel costs and 
other operation costs 
- EUR 4.3 billion increase in 
fuel tax expenditures 

Total administrative 
burdens 

- 

- 

- 

- 

Note: Adjustment costs and other indirect costs are reported for transparency but are not included in the calculation of 
the net administrative burden, in line with the ‘one in, one out’ approach. 

2.3.  PREFERRED OPTION (PO1C) 

I. Overview of Benefits (total for all provisions) – Preferred Option (PO1C) 

Description 

Amount 

Comments 

Direct benefits 

Adjustment costs 
savings for large 
companies, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in fuel tax 
expenditures for large 
companies, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Adjustment costs 
savings for SMEs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Reduction in fuel tax 
expenditures for 
SMEs, expressed as 
present value over 
2029-2050 relative to 
the baseline 

Adjustment costs 
savings for citizens, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Reduction in fuel tax 
expenditures for 
citizens, expressed as 
present value over 

EUR 42.9 
billion 

Adjustment costs savings due to an increase in the number of new ZEVs in 
corporate  fleets  by  large  companies.  Adjustment  cost  savings  for  large 
companies  are  estimated  at  EUR  42.9  billion  expressed  as  present  value 
over 2029-2050, relative to the baseline. 

EUR 32 billion  

Reduction  in  fuel  tax  expenditures  due  to  the  reduction  in  fossil  fuel 
consumption resulting from the higher uptake of new ZEVs. The reduction 
in fuel tax expenditures for large companies is estimated at EUR 32 billion 
expressed as present value over 2029-2050, relative to the baseline. 

Indirect benefits 

EUR 16.3 
billion 

Adjustment  costs  savings  due  to  higher  uptake  of  second-hand  ZEV  by 
SMEs, as a result of faster uptake of new ZEV in corporate fleets by large 
companies.  Adjustment  cost  savings  for  SMEs  are  estimated  at  EUR  16.3 
billion expressed as present value over 2029-2050 relative to the baseline. 

EUR 2.6 
billion 

Reduction  in  fuel  tax  expenditures  for  SMEs  due  to  the  higher  uptake  of 
second-hand  ZEVs.  The  reduction  in  tax  expenditures  for  SMEs  is 
estimated  at  EUR  2.6  billion  expressed  as  present  value  over  2029-2050 
relative to the baseline. 

EUR 7 billion   Adjustment  costs  savings  due  to  higher  uptake  of  second-hand  ZEV  by 
citizens, as a result of faster uptake of new ZEV in corporate fleets by large 
companies.  Adjustment  cost  savings  for  citizens  are  estimated  at  EUR  7 
billion expressed as present value over 2029-2050 relative to the baseline.  

EUR 4.6 
billion  

Reduction in fuel tax expenditures for citizens due to  the higher uptake of 
second-hand  ZEVs.  The  reduction  in  tax  expenditures  for  citizens  is 
estimated  at  EUR  4.6  billion  expressed  as  present  value  over  2029-2050 
relative to the baseline. 

86 

 
 
 
 
 
I. Overview of Benefits (total for all provisions) – Preferred Option (PO1C) 

Description 

Amount 

Comments 

2029-2050 relative to 
the baseline 

Additional fuel tax 
revenues for national 
public authorities, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Savings in external 
costs of CO2 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in CO2 
emissions (cumulative 
over 2029-2050 
relative to the 
baseline) 

Savings in external 
costs of air pollution 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Reduction in air 
pollution emissions 
(cumulative over 
2029-2050 relative to 
the baseline) 

Savings in external 
costs of noise 
emissions, expressed 
as present value over 
2029-2050 relative to 
the baseline 

Indirect benefits to 
vehicle manufacturers 

EUR 18.9 
billion 

Additional  tax  revenues  for  public  authorities  due  to  an  increase  in  fossil 
fuel use, following the assumed shift from new ZEVs to new conventional 
vehicles in the short to medium term by citizens and SMEs. The additional 
tax  revenues  for  public  authorities  are  estimated  at  EUR  18.9  billion, 
expressed as present value over 2029-2050 relative to the baseline. 

EUR 6.8 
billion  

Indirect  benefit  to  society  at  large.  Savings  in  external  costs  of  CO2 
emissions  due  to  the  higher  uptake  of  ZEV  in  the  fleet.  The  savings  in 
external costs of CO2 emissions are estimated at EUR 6.8 billion expressed 
as present value over 2029-2050 relative to the baseline. 

43.4 million 
tonnes 

Indirect  benefit  to  society  at  large.  The  reduction  in  CO2  emissions  is 
estimated  at  43.4  million  tonnes,  cumulatively  over  2029-2050  relative  to 
the baseline. 

EUR 0.8 
billion  

Indirect benefit to society at large. Savings in external costs of air pollution 
emissions  due  to  the  higher  uptake  of  ZEV  in  the  fleet.  The  savings  in 
external  costs  of  air  pollution  emissions  are  estimated  at  EUR  0.8  billion 
expressed as present value over 2029-2050 relative to the baseline.  

40.2 thousand 
tonnes of NOx 
and 1.6 
thousand 
tonnes of 
PM2.5 

EUR 0.4 
billion 

Indirect  benefit  to  society  at  large.  Cumulatively  over  2029-2050,  the 
reduction  in  NOx  and  PM2.5  emissions  is  estimated  at  40.2  thousand 
tonnes and 1.6 thousand tonnes, respectively (relative to the baseline). 

Indirect  benefit  to  society  at  large.  Savings  in  external  costs  of  noise 
emissions due to the higher uptake of ZEV. The savings in external costs of 
noise emissions are estimated at EUR 0.4 billion expressed as present value 
over 2029-2050 relative to the baseline. 

Not quantified  Create  greater  certainty  and  better  conditions  for  investment  in  ZEV 
manufacturing  capacity,  and  reduce  individual  manufacturers’  risk  of  not 
meeting their targets under CO2 standards Regulations.  

II. Overview of costs – Preferred option (PO1C) 

Citizens/Consumers 

Businesses 

Administrations 

One-off  Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Direct adjustment costs 
(expressed as present value 
over 2029-2050 relative to 
the baseline) 

- 

- 

- 

- 

For large 
companies:  
EUR 12.4 
billion 
(capital 
costs) 

For large 
companies: 
EUR 3.2 
billion (fuel 
costs and 
other 

87 

 
 
 
 
 
II. Overview of costs – Preferred option (PO1C) 

- 

- 

- 

- 

operation 
costs)  

Direct administrative costs 
(expressed as present value 
over 2029-2050 relative to 
the baseline) 

Indirect costs (expressed 
as present value over 
2029-2050 relative to the 
baseline) 

For 
citizens: 
EUR 0.7 
billion 
capital 
costs 

For SMEs: 
EUR 1 
billion 
capital costs 

For citizens: 
EUR 14.3 
billion of 
which: 
-  EUR 9.7 
billion fuel 
costs and 
other 
operation 
costs 

- EUR 4.6 
billion 
increase in 
fuel tax 
expenditures 

For SMEs: 
EUR 38.4 
billion of 
which: 
- EUR 24.2 
billion fuels 
costs and 
other 
operation 
costs 

- EUR 14.3 
billion 
increase in 
fuel tax 
expenditures 

For national 
administrations: 
EUR 0.23 
million  

For national 
administrations: 
EUR 0.17 
million  

For EEA:          
EUR 25,000 

- 

For EEA:          
EUR 0.44 
million 

For national 
administrations: 
EUR 39.1 
billion losses in 
tax revenues  

III. Application of the ‘one in, one out’ approach – Preferred option (PO1C) 

[M€] 

One-off 

Recurrent 

Total 

(annualised total net present 
value over the relevant period) 

(nominal values per year) 

Businesses 

New administrative 
burdens (INs) 

Removed 
administrative burdens 
(OUTs) 

Net administrative 
burdens 

Adjustment costs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

Citizens 

- 

- 

- 

- 

- 

- 

- 

- 

- 

For large companies:  
EUR 12.4 billion capital costs  

For large companies: 
EUR 3.2 billion fuel costs and 
other operation costs  

For SMEs (indirect costs): 
EUR 1 billion capital costs  

For SMEs (indirect costs):  
EUR 38.4 billion of which: 
- EUR 24.2 billion fuels costs 
and other operation costs 
- EUR 14.3 billion increase in 
fuel tax expenditures 

88 

 
 
 
 
 
 
 
 
 
 
III. Application of the ‘one in, one out’ approach – Preferred option (PO1C) 

New administrative 
burdens (INs) 

Removed 
administrative burdens 
(OUTs) 

Net administrative 
burdens 

Adjustment costs, 
expressed as present 
value over 2029-2050 
relative to the baseline 

- 

- 

- 

- 

- 

- 

For citizens (indirect costs): 
EUR 0.7 billion capital costs 

For citizens (indirect costs): 
EUR 14.3 billion of which: 
-  EUR 9.7 billion fuel costs and 
other operation costs 
- EUR 4.6 billion increase in 
fuel tax expenditures 

Total administrative 
burdens 

- 

- 

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS  

3.1.  PREFERRED OPTION (PO1A) 

IV. Overview of relevant Sustainable Development Goals – Preferred Option (PO1A) 
Comments 
Relevant SDG 

Expected progress towards the Goal 

- 

- 

- 

- 

SDG 13 (Take urgent 
action to combat climate 
change and its impacts) 

10 million tonnes of CO2 emissions avoided 
cumulatively over 2029-2050 relative to the 
baseline 

reduction 

The 
in  greenhouse  gas 
emissions  will  result  in  cost  savings 
associated  with  lower  climate-related 
externalities, 
avoided 
such 
environmental  damage  and  health 
impacts 
change. 
Expressed  as  present  value  over  2029-
2050,  these  costs  savings  are  estimated 
at  EUR  1.6  billion  relative  to  the 
baseline.  

climate 

from 

as 

SDG 3 (Ensure healthy 
lives and promote well-
being for all at all ages, 
including target 3.9: By 
2030, substantially reduce 
the number of deaths and 
illnesses from hazardous 
chemicals and air, water 
and soil pollution and 
contamination.) 

15 thousand tonnes of NOX and 0.3 
thousand tonnes of PM2.5 avoided, 
cumulatively over 2029-2050 relative to the 
baseline 

In addition, the savings in external costs of 
noise emissions are estimated at EUR 0.1 
billion, expressed as present value over 
2029-2050 relative to the baseline. 

The reduction of air pollutant emissions 
and  of  noise  emissions  will  result  in 
cost  savings  associated  with  improved 
air quality, reduced health  impacts, and 
enhanced  well-being.  Expressed  as 
present  value  over  2029-2050,  these 
costs  savings  are  estimated  at  EUR  0.2 
billion  for  air  pollutant  emissions,  and 
at  EUR  0.1  billion  for  noise  emissions 
relative to the baseline. 

3.2.  PREFERRED OPTION (PO1B) 

IV. Overview of relevant Sustainable Development Goals – Preferred Option (PO1B) 
Comments 
Relevant SDG 

Expected progress towards the Goal 

SDG 13 (Take urgent 
action to combat climate 
change and its impacts) 

23.7 million tonnes of CO2 emissions 
avoided cumulatively over 2029-2050 
relative to the baseline 

89 

reduction 

The 
in  greenhouse  gas 
emissions  will  result  in  cost  savings 
associated  with  lower  climate-related 
avoided 
such 
externalities, 

as 

 
 
 
 
 
 
 
 
IV. Overview of relevant Sustainable Development Goals – Preferred Option (PO1B) 
Comments 
Relevant SDG 

Expected progress towards the Goal 

from 

climate 

environmental  damage  and  health 
impacts 
change. 
Expressed  as  present  value  over  2029-
2050,  these  costs  savings  are  estimated 
at  EUR  3.7  billion  relative  to  the 
baseline.  

SDG 3 (Ensure healthy 
lives and promote well-
being for all at all ages, 
including target 3.9: By 
2030, substantially reduce 
the number of deaths and 
illnesses from hazardous 
chemicals and air, water 
and soil pollution and 
contamination.) 

25 thousand tonnes of NOX and 0.8 
thousand tonnes of PM2.5 avoided, 
cumulatively over 2029-2050 relative to the 
baseline 

In addition, the savings in external costs of 
noise emissions are estimated at EUR 0.2 
billion, expressed as present value over 
2029-2050 relative to the baseline. 

The reduction of air pollutant emissions 
and  of  noise  emissions  will  result  in 
cost  savings  associated  with  improved 
air quality, reduced health  impacts, and 
enhanced  well-being.  Expressed  as 
present  value  over  2029-2050,  these 
costs  savings  are  estimated  at  EUR  0.5 
billion  for  air  pollutant  emissions,  and 
at  EUR  0.2  billion  for  noise  emissions 
relative to the baseline. 

3.3.  PREFERRED OPTION (PO1C) 

IV. Overview of relevant Sustainable Development Goals – Preferred Option (PO1C) 
Comments 
Relevant SDG 

Expected progress towards the Goal 

SDG 13 (Take urgent 
action to combat climate 
change and its impacts) 

43.4 million tonnes of CO2 emissions 
avoided cumulatively over 2029-2050 
relative to the baseline 

reduction 

The 
in  greenhouse  gas 
emissions  will  result  in  cost  savings 
associated  with  lower  climate-related 
externalities, 
avoided 
such 
environmental  damage  and  health 
change. 
impacts 
Expressed  as  present  value  over  2029-
2050,  these  costs  savings  are  estimated 
at  EUR  6.8  billion  relative  to  the 
baseline.  

climate 

from 

as 

SDG 3 (Ensure healthy 
lives and promote well-
being for all at all ages, 
including target 3.9: By 
2030, substantially reduce 
the number of deaths and 
illnesses from hazardous 
chemicals and air, water 
and soil pollution and 
contamination.) 

40.2 thousand tonnes of NOX and 1.6 
thousand tonnes of PM2.5 avoided, 
cumulatively over 2029-2050 relative to the 
baseline 

In addition, the savings in external costs of 
noise emissions are estimated at EUR 0.4 
billion, expressed as present value over 
2029-2050 relative to the baseline. 

The reduction of air pollutant emissions 
and  of  noise  emissions  will  result  in 
cost  savings  associated  with  improved 
air quality, reduced health  impacts, and 
enhanced  well-being.  Expressed  as 
present  value  over  2029-2050,  these 
costs  savings  are  estimated  at  EUR  0.8 
billion  for  air  pollutant  emissions,  and 
at  EUR  0.4  billion  for  noise  emissions 
relative to the baseline. 

90 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

1.  DESCRIPTION OF THE ANALYTICAL METHODS USED  

The main model used for developing the baseline scenario for this initiative is the PRIMES-TREMOVE 
transport model by E3Modelling, a specific module of the PRIMES models. The model has a successful 
record of use in the Commission's energy, transport and climate policy assessments. In particular, it has been 
used for the impact assessments underpinning the Communication on a 2040 climate target180, the “Fit for 
55”  package181,  the  impact  assessments  accompanying  the  2030  Climate  Target  Plan182  and  the  Staff 
Working  Document  accompanying  the  Sustainable  and  Smart  Mobility  Strategy183,  the  Commission’s 
proposal for a Long Term Strategy184  as well as for the 2020 and 2030 EU’s climate and energy policy 
framework.  

For the assessment of the impacts of the policy options, the PRIMES-TREMOVE model has been used for 
quantifying the impacts on number of ZEV, on CO2 emissions, on air pollutant and noise emissions, and on 
adjustment  costs/costs  savings.  An  Excel-based  tool  has  been  additionally  developed  in  the  context  of  a 
support study185, to quantify the impacts on the administrative costs and perform the cost-benefit analysis. 
The  Excel-based  tool  draws  on  the  Standard  Cost  Model.  The  proposed  options  are  assumed  to  be 
implemented from 2029 onwards, so that the assessment has been undertaken for the 2029-2050 period and 
refers to EU27. Costs and benefits are expressed as present value over the 2029-2050 period, using a 3% 
discount rate. 

PRIMES-TREMOVE model  

The  PRIMES-TREMOVE  transport  model  projects  the  evolution  of  demand  for  passengers  and  freight 
transport,  by  transport  mode,  and  transport  vehicle/technology,  following  a  formulation  based  on 
microeconomic  foundation  of  decisions  of  multiple  actors.  Operation,  investment  and  emission  costs, 
various policy measures, utility factors and congestion are among the drivers that influence the projections of 
the  model.  The  projections  of  activity,  equipment  (fleet),  usage  of  equipment,  energy  consumption  and 
emissions (and other externalities) constitute the set of model outputs.  

The PRIMES-TREMOVE transport model can therefore provide the quantitative analysis for the transport 
sector in the EU, candidate and neighbouring countries covering activity, equipment, energy and emissions. 
The  model  accounts  for  each  country  separately  which  means  that  the  detailed  long-term  outlooks  are 
available both for each country and in aggregate forms (e.g. EU level). 

In  the  transport  field,  PRIMES-TREMOVE  is  suitable  for  modelling  soft  measures  (e.g.  eco-driving, 
labelling);  economic  measures  (e.g.  subsidies  and  taxes  on  fuels,  vehicles,  emissions;  ETS  for  transport 
when linked with PRIMES; pricing of congestion and other externalities such as air pollution, accidents and 
noise; measures supporting R&D); regulatory measures (e.g. CO2 emission performance standards for new 
light-duty  vehicles  and  heavy-duty  vehicles;  EURO  standards  on  road  transport  vehicles;  technology 
standards  for  non-road  transport  technologies,  deployment  of  Intelligent  Transport  Systems)  and 
infrastructure  policies  for  alternative  fuels  (e.g.  deployment  of  refuelling/recharging  infrastructure  for 
electricity, hydrogen, LNG, CNG). Used as a module that contributes to the PRIMES energy system model, 

180 EUR-Lex - 52024DC0063 - EN - EUR-Lex (europa.eu) 
181 Delivering the European Green Deal | European Commission (europa.eu) 
182 SWD(2020)176 final 
183 EUR-Lex - 52020SC0331 - EN - EUR-Lex (europa.eu)   
184 Source: 2050 long-term strategy (europa.eu)   
185 Ricardo (2025), Support study on the impacts of an initiative on clean corporate vehicles  

91 

 
 
PRIMES-TREMOVE can show how policies and trends in the field of transport contribute to economy-
wide trends in energy use and emissions. Using data disaggregated per Member State, the model can show 
differentiated trends across Member States.  

The PRIMES-TREMOVE has been developed and is maintained by E3Modelling, based on, but extending 
features of, the open source TREMOVE model developed by the TREMOVE186 modelling community. 
Part of the model (e.g. the utility nested tree) was built following the TREMOVE model.187 Other parts, like 
the component on fuel consumption and emissions, follow the COPERT model. 

For  the  purpose  of  this  impact  assessment,  the  model  has  been  further  enhanced  to  provide  for  the 
representation  of  the  corporate  fleets.  The  figures  below  provide  the  agents  split  for  cars,  vans,  buses, 
coaches and trucks that allows for the representation of the corporate fleets in the model, including the split 
between vehicles belonging to large companies and SMEs.  

Figure 5: Agents split for cars and vans 

186 https://www.tmleuven.be/en/navigation/TREMOVE.  
187  Several  model  enhancements  were  made  compared  to  the  standard  TREMOVE  model,  as  for  example:  for  the 
number of vintages (allowing representation of the choice of second-hand cars); for the technology categories which 
include vehicle types using electricity from the grid and fuel cells. The model also incorporates additional fuel types, 
such  as  biofuels  (when  they  differ  from  standard  fossil  fuel  technologies),  LPG,  LNG,  hydrogen  and  e-fuels.  In 
addition,  representation  of  infrastructure  for  refuelling  and  recharging  are  among  the model  refinements,  influencing 
fuel choices. A major model enhancement concerns the inclusion of heterogeneity in the distance of stylised trips; the 
model  considers  that  the  trip  distances  follow  a  distribution  function  with  different  distances  and  frequencies.  The 
inclusion of heterogeneity was found to be of significant influence in the choice of vehicle-fuels especially for vehicles-
fuels with range limitations. 

92 

 
 
 
Figure 6: Agents split for buses, coaches and trucks 

The Dataforce database188 was the main data source used for the calibration of the model to represent the 
corporate fleets. Dataforce GmbH is a German automotive market intelligence company that is specialised 
in  detailed  registration  and  fleet  data  for  passenger  cars  and  commercial  vehicles  across  more  than  40 
countries,  with  particularly  deep  coverage  of  the  EU27  markets.  It  combines  official  vehicle  registration 
statistics with own data collection to build highly segmented datasets by sales channel (private, fleet, leasing, 
rental, dealer and manufacturer registrations), fleet size, vehicle type, fuel/powertrain, CO2 emissions, body 
type, and other attributes. The level of details available for each country varies, but full coverage is available 
for the biggest markets in the EU. In the corporate fleet segment it is regarded as a reference source – for 
example, its corporate-fleet statistics are used in various studies189,190 for analysing company-car and fleet 
markets. 

Data inputs 

The  main  data  sources  for  inputs  to  the  PRIMES-TREMOVE  model,  such  as  for  activity  and  energy 
consumption,  come  from  EUROSTAT  databases  and  from  the  Statistical  Pocketbook  EU  transport  in 
figures191. Excise taxes are derived from DG TAXUD excise duty tables. Other data comes from different 
sources  such  as  research  projects  (e.g.  TRACCS  and  New  Mobility  Pattern  projects) and  reports.  In  the 
context of this exercise, the PRIMES-TREMOVE transport model is calibrated to 2005, 2010, 2015 and 
2020-2023 historical data, as well as the most recent data on the structure of the road transport vehicle fleet 
for the first half of 2025 from the European Alternative Fuels Observatory (EAFO)192. For the corporate 
fleets the data from the Dataforce database has been used, including most recent data for the first half of 
2025.  

188 https://www.dataforce.de/en/market-data/ 
189  Transport  &  Environment  (2023),  The  corporate  cars  problem  and  what  the  EU  can  do  about  it.  Modelling  the 
impact of the Greening corporate fleets initiative. 
190  Wappelhorst,  S.  &  Díaz  de  Aguilar,  S.  (2025),  Decarbonization  of  Europe’s  corporate  fleet.  ICCT  Policy  Brief, 
International Council on Clean Transportation. 
191 Statistical pocketbook 2025 - Mobility and Transport - European Commission 
192 Homepage | European Alternative Fuels Observatory 

93 

 
 
 
 
2.  BASELINE SCENARIO 

2.1.  Main assumptions of the Baseline scenario 

The main assumptions related to economic development, international energy prices and technologies are 
described below. 

2.1.1.  Economic assumptions 

The  modelling  work  is  based  on  socio-economic  assumptions  describing  the  expected  evolution  of  the 
European society. Long-term projections on population dynamics and economic activity form part of the 
input  to  the  model  and  are  used  to  estimate  transport  activity,  particularly  relevant  for  this  impact 
assessment.  

Population projections rely on Eurostat’s long-term projections (EUROPOP2023)193. The EU population is 
projected to remain broadly stable over the projection period to 2050. However, there is a noticeable trend 
towards  the  ageing  of  the  population,  with  a  10%  decline  in  the  working-age  population  aged  20  to  64 
between 2025 and 2050 and an increase in the old-age dependency ratio from 38% to 55.2% (Figure 7). 

Figure 7: Population assumptions 

Source: Eurostat 

Economic projections have taken place in an unusually unstable context in the past few years, as the EU and 
world economies were hit first by the COVID pandemic and second by Russia’s war of aggression against 
Ukraine, with the ensuing sharp increase in international energy prices. The GDP projections for 2025 rely 
on the Spring Forecast194 of the Directorate General for Economic and Financial Affairs (DG ECFIN). From 
2025 onwards, the GDP growth projections converge to those prepared by DG ECFIN for the 2024 Ageing 
Report195. At EU level, real GDP is projected to be 23% higher in 2030 than in 2015, 39% higher in 2040, 
and 60% higher in 2050 compared to 2015 (Figure 8). 

193 EUROPOP2023 (proj_23n). 
194 DG ECFIN, European Economic Forecast. Spring 2024. 
195 DG ECFIN, 2024 Ageing Report. Economic and budgetary projections for the EU Member States (2022-2070). 

94 

0%10%20%30%40%50%60%05010015020025030035040045050020252026202720282029203020312032203320342035203620372038203920402041204220432044204520462047204820492050Million peopleOld-age dependency ratio (RHS)Total populationWorking-age population (20-64y) 
 
 
Projections  on  the  sectoral  composition  of  GDP  were  prepared  using  the  GEM-E3  computable  general 
economic  model.  It  is  projected  that  the  EU  economy  will  continue  to  become  increasingly  services-
oriented, with the sector’s share rising from close to 74% of total gross value added (GVA) in 2016-2020 to 
around 75% in 2040 and 76% in 2050. While the share of the transport sector in total GVA declined during 
the COVID pandemic, the projections assume that this was only a temporary phenomenon, and that the 
sector’s share remains broadly constant at close to 5% of the total. This is consistent with recent economic 
developments. 

Figure 8: EU GDP (2015 = 100) and GDP growth (%) 

Source: DG ECFIN 

2.1.2. 

International energy prices assumptions  

Alongside socio-economic projections, transport modelling requires projections of international fuel prices. 
The table below shows the oil prices assumptions of the baseline used in this impact assessment.  

Table 41: Oil prices assumptions  
Oil 

2015 

in $'2023 per boe 

in €'2023 per boe 

62.6 

57.5 

2020 

48.0 

44.0 

2030 

92.8 

85.2 

2040 

105.7 

97.0 

2050 

131.6 

120.7 

2.1.3.  Technology assumptions 

Modelling scenarios on the evolution of the transport system is highly dependent on the assumptions on the 
development of technologies - both in terms of performance and costs. For the purpose of the development 
of the baseline, these assumptions have been updated based on a rigorous literature review carried out by 
external consultants in collaboration with the JRC.  

Continuing the approach adopted in the long-term strategy in 2018 and for the Reference Scenario 2020, the 
Commission consulted on the technology assumptions with Member States and stakeholders in 2024. In 
particular, the technology database of PRIMES-TREMOVE transport model was discussed with Member 
States during a meeting of the Reference scenario expert group on 5 June 2024. They also benefited from a 
dedicated consultation workshop with stakeholders, held on 22-23 October 2024. 

The battery cost trajectory considered in the baseline is provided in Table 42. 

95 

-6%-4%-2%0%2%4%6%901001101201301401501601702015201720192021202320252027202920312033203520372039204120432045204720492015=100Real GDP (2015=100)Real GDP growth (RHS) 
 
 
Table 42: Battery cost trajectory (EUR/kWh)  

Battery cost in EUR/kWh 

2020 
141 

2025 
97 

2030 
72 

2035 
67 

2040 
63 

2045 
60 

2050 
58 

2.1.4.  Policies in the Baseline scenario  

The baseline has been designed to include the initiatives of the ‘Fit for 55’ package196 and the proposed 
amendment of the European Climate Law to include a 2040 climate target for the EU197, of reducing the 
EU's net greenhouse gas emissions by 90% by 2040 relative to 1990, with a limited contribution towards the 
2040 target of high-quality international credits of 3% of 1990 EU net emissions. It also reflects the revised 
CO2 emission performance standards for heavy-duty vehicles198, the new Euro 7 standards199, the revised 
TEN-T Regulation200, as well as the initiatives part of the Greening Freight package201 and Roadworthiness 
package202. It also reflects the National Energy and Climate Plans prepared by the Member States under the 
Regulation 2018/1999 on the Governance of the Energy Union and Climate Action and submitted to the 
Commission during 2024-2025. The baseline scenario assumes no further EU level intervention beyond the 
current fragment support framework at national level for corporate ZEV.  

The baseline also incorporates perspectives on potential future developments captured in the 2022 Strategic 
Foresight Report203 and during a foresight workshop organised by DG MOVE and JRC on 10 February 
2025,  analysing  the  impacts  of  the  megatrends  and  drivers  of  change  on  the  EU  transport  sector204.  In 
particular, the projected transport activity draws on the long-term population projections from Eurostat and 
GDP growth from the Ageing Report 2024205. 

2.2.  Baseline scenario results 

In the baseline scenario, EU transport activity is projected to grow post-2020, following the recovery from 
the COVID-19 pandemic. Road transport would maintain its dominant role within the EU by 2050, despite 
its lower modal share over time. Road passenger transport activity (expressed in passenger-kilometres)206 is 
projected to grow by 7% between 2015 and 2030 (15% for 2015-2050), while road freight transport activity 
(expressed in tonne-kilometres)207 by 32% during 2015-2030 (52% for 2015-2050). Transport activity for 
rail is projected to grow significantly faster than for road, driven in particular by the completion of the TEN-
T core network by 2030 and of the comprehensive network by 2050, supported by the CEF208, Cohesion 
Fund  and  ERDF  funding, but  also  by  measures of  the  ‘Fit  for  55’  package209  and  the Greening  Freight 
package.  

196 Delivering the European Green Deal - European Commission 
197 COM(2025) 524 final 
198 Regulation (EU) 2024/1610 
199 Regulation - 2024/1257 - EN - EUR-Lex 
200 Regulation - EU - 2024/1679 - EN - EUR-Lex 
201 Green Deal: Greening freight for more economic gain with less environmental impact (europa.eu). 
202 Updated rules for safer roads, less air pollution and digital vehicle documents 
203 COM(2022) 289 final 
204 https://knowledge4policy.ec.europa.eu/foresight/tool/megatrends-hub_en#explore  
205 DG  ECFIN, 2024 Ageing Report.  Economic and Budgetary Projections for the EU Member States (2022-2070)  - 
Economy and Finance 
206 Covering passenger cars, buses and coaches and power-two wheelers.  
207 Covering heavy goods vehicles and light commercial vehicles.  
208 Regulation - 2021/1153 - EN - EUR-Lex 
209 These measures increase to some extent the competitiveness of rail relative to road and air transport. 

96 

 
 
 
The share of ZEV in new registrations for corporate cars is projected to increase from 17% in 2025 to 31% 
in 2029 and 61% in 2030, while for vans from around 8% in 2025 to 30% in 2029 and 52% in 2030210. 
From 2035, all new light-duty vehicles (cars and vans) must achieve zero tailpipe emissions due to the CO2 
emission standards regulation, and thus the share of ZEV in new registrations of cars and vans is 100%. For 
lorries (virtually all corporate), the new registrations of ZEV are projected at around 7% in 2029, 24% in 
2030 and going up to 77% by 2050 in the baseline scenario. Taking into account the  payload weighting 
factors under the CO2 emission performance standards, the new zero-emissions registrations for lorries are 
projected at 9% in 2029, 30% in 2030 and around 90% by 2050. 

The projected share of ZEV in new registrations by large companies for cars, vans and for lorries (taking 
into account the payload weighting factors under the CO2 emission performance standards) are provided in 
the tables below. 

Table 43: Share of zero-emission cars in new registrations by large companies in the baseline 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
EU27 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

2035 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

2029 
22% 
29% 
52% 
22% 
72% 
70% 
34% 
8% 
32% 
21% 
24% 
54% 
72% 
51% 
28% 
17% 
21% 
10% 
64% 
22% 
28% 
47% 
48% 
18% 
50% 
52% 
64% 
31% 

2030 
58% 
60% 
79% 
61% 
87% 
81% 
61% 
50% 
62% 
57% 
60% 
70% 
83% 
71% 
56% 
60% 
55% 
56% 
87% 
62% 
42% 
70% 
74% 
58% 
60% 
70% 
76% 
61% 

2040 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

2045 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

Table 44: Share of zero-emission vans in new registrations by large companies in the baseline 

Austria 
Belgium 

2029 
42% 
44% 

2030 
53% 
55% 

2035 
100% 
100% 

2040 
100% 
100% 

2045 
100% 
100% 

2050 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

2050 
100% 
100% 

210 Overall, the shares of ZEV in the new registrations of cars and vans for 2029 assume some anticipation of the  CO2 
emission standards for 2030 in the baseline scenario.  

97 

 
  
  
 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
EU27 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

2035 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

2030 
43% 
48% 
91% 
53% 
26% 
51% 
48% 
53% 
52% 
60% 
62% 
64% 
52% 
36% 
50% 
53% 
55% 
51% 
53% 
51% 
51% 
48% 
51% 
51% 
49% 
52% 

2029 
27% 
37% 
86% 
42% 
10% 
37% 
9% 
24% 
22% 
46% 
64% 
65% 
40% 
28% 
38% 
38% 
56% 
20% 
42% 
39% 
41% 
35% 
38% 
13% 
38% 
29% 

2040 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

2045 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

2050 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 
100% 

Table  45:  Share  of  zero-emission  lorries  in  new  registrations  by  large  companies  in  the  baseline  (taking  into 
account the payload weighting factors under the CO2 emission performance standards) 

Austria 
Belgium 
Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Estonia 
Finland 
France 
Germany 
Greece 
Hungary 
Ireland 
Italy 
Latvia 
Lithuania 
Luxembourg 
Malta 
Netherlands 
Poland 
Portugal 

2029 
26% 
2% 
4% 
6% 
5% 
1% 
2% 
7% 
1% 
18% 
4% 
11% 
5% 
5% 
4% 
5% 
8% 
13% 
0% 
4% 
17% 
12% 

2035 
61% 
51% 
49% 
61% 
55% 
53% 
52% 
51% 
41% 
60% 
52% 
59% 
55% 
56% 
56% 
53% 
54% 
57% 
37% 
52% 
62% 
64% 

2030 
36% 
23% 
24% 
31% 
28% 
23% 
23% 
26% 
15% 
35% 
26% 
35% 
27% 
28% 
28% 
27% 
28% 
32% 
9% 
24% 
39% 
37% 

98 

2040 
94% 
90% 
90% 
94% 
94% 
92% 
89% 
91% 
87% 
93% 
89% 
92% 
91% 
92% 
93% 
91% 
91% 
94% 
88% 
90% 
93% 
93% 

2045 
94% 
91% 
90% 
93% 
92% 
93% 
89% 
91% 
90% 
91% 
89% 
92% 
91% 
92% 
93% 
91% 
92% 
97% 
89% 
90% 
94% 
92% 

2050 
93% 
90% 
89% 
93% 
91% 
92% 
89% 
90% 
89% 
90% 
88% 
91% 
90% 
90% 
91% 
89% 
89% 
98% 
87% 
89% 
93% 
93% 

 
  
 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
EU27 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

2029 
2% 
5% 
5% 
11% 
5% 
9% 

2030 
17% 
28% 
28% 
34% 
25% 
30% 

2035 
48% 
53% 
52% 
63% 
50% 
56% 

2040 
89% 
92% 
89% 
94% 
88% 
92% 

2045 
89% 
93% 
90% 
93% 
88% 
91% 

2050 
90% 
92% 
89% 
91% 
88% 
90% 

The share of ZEV in the overall cars fleet is projected at 13% in 2030, going up to 83% in 2050 in the 
baseline scenario, while for vans at 10% in 2030 and 82% in 2050, and for lorries at around 2% in 2030 and 
48% in 2050 (around 2% in 2030 and 57% in 2050 taking into account the payload weighting factors under 
the CO2 emission performance standards). Of this, for corporte cars the share of ZEV is projected at 30% in 
2030 and 98% in 2050, due to the shorter initial ownership duration and faster turnover of the corporate 
vehicles.  For  corporate  vans,  which  represent  around  90%  of  the  total,  the  share  of  ZEV  in  the  fleet  is 
projected at 11% in 2030 and 84% by 2050. These developments are mainly driven by the CO2 standards 
Regulation, supported by the Alternative Fuels Infrastructure Regulation and incentives for ZEV at national 
level. NOx emissions from road transport are projected to reduce by 72% in 2030 relative to 2015 (99% 
reduction  for  2015-2050),  while  particulate  matter  (PM2.5)  emissions  would  decrease  by  48%  in  2030 
relative to 2015 (95% reduction for 2015-2050).  

In line with the Better Regulation toolbox, the baseline assumes that all legislation in place and proposed by 
the Commission is fully implemented, including the ETS2 which caps the emissions from road transport and 
buildings, and the Renewable Energy Directive setting targets for renewable energy in transport as well as 
mandates  for  renewable  fuels  of  non-biological  origin  (RFNBO)  and  advanced  biofuels.  Vehicle 
manufacturers  are  assumed  to  comply  with  the  CO2  emission  performance  standards  for  new  vehicles 
throughout  the  time  horizon  considered.  Member  States  and  transport  operators  also  comply  with  other 
requirements included in the existing legislation. The EU climate targets for 2030, 2040 and 2050 are met in 
the baseline and the CO2 emissions from road transport are projected to decrease by 27% by 2030 relative to 
2015, and be close to zero by 2050, thanks to the large-scale uptake of zero-emission vehicles and some use 
of renewable and low-carbon fuels.  

Driven  by  the  recovery  of  the  transport  activity  following  the  COVID-19  pandemic,  the  most  recent 
available  statistics  (for  2023)  show  no  progress  in  the  reduction  of  CO2  emissions  from  road  transport 
relative to 2015. In case vehicle manufacturers do not meet their CO2 emission targets, or Member States 
and  transport  operators  do  not  fully  comply  with  other  legal  requirements,  or  consumers  delay  the 
acquisition of new vehicles, the reduction in the CO2 emissions from road transport would be lower than 
projected in the baseline. In this case, other transport modes (where emissions are harder to abate) or other 
sectors would need to deliver higher emission reductions to meet the EU climate targets for 2030, 2040 and 
2050. However, as explained above, in line with the Better Regulation toolbox, the baseline  assumes the 
implementation of existing policies.   

In addition, in the baseline the benefits of higher uptake of ZEV by large companies remain untapped. As 
corporate  vehicles  typically  have  comparatively  high  yearly  mileage,  their  higher  uptake  increases  the 
potential impact on real-world emissions reductions. 

3.  IMPACTS OF POLICY OPTIONS IN TERMS OF ADMINISTRATIVE COSTS 

3.1.  Administrative costs for businesses 

The options based on national targets (PO1A, PO1B, PO1C) will not directly create any administrative costs 
for  businesses,  as  the  reporting  is  done  by  Member  States  on  the  basis  of  existing  national  vehicle 

99 

 
 
registration procedures. On the other hand, in PO2A, PO2B and PO2C businesses will face administrative 
costs, both one-off and recurrent, since the policy options imply a new, additional reporting activity for those 
market actors.   

One-off administrative costs are expected for large companies in PO2A, PO2B and PO2C for extending 
their IT systems to include a relevant field to collect the required data from sub-contractors (i.e. tonne-km of 
activity performed and whether the lorry that performed it is a ZEV) and for updating the templates for 
the  contracts  with  the  sub-contractors  performing  transport  activities  on  their  behalf.  On  average, 
EUR  1,000  per  large  company  is  assumed  to  be  needed  for  extending  the  IT  systems.  Considering  the 
number of large companies in industry, construction and market services in the EU (54,219)211, the total 
one-off costs for the extension of their IT systems is estimated at EUR 54.22 million in 2029. In addition, 
half a day is expected to be needed per company to update the templates for the contracts with the sub-
contractors. Assuming 7.2 working hours per day on average212 and the tariff rates by Member State for 
the  ISCO  3  category  (technicians  and  associate  professionals)  in  2023  prices213,  the  total  one-off 
costs for updating the templates for the contracts are estimated at EUR 6.24 million in 2029. Thus, 
the total one-off administrative costs for large companies in PO2A, PO2B and PO2C are estimated 
at EUR 60.46 million in 2029. 

Table 46: One-off administrative costs for large companies in policy options PO2A, PO2B and PO2C relative to 
the baseline (in million EUR) 
 Member State 

Extension of the IT system 

Total one-off costs 

Update templates for 
contracts  

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 

1.53 
1.51 
0.76 
0.44 
0.13 
1.76 
0.90 
0.17 
0.76 
6.14 
14.98 
0.68 
1.02 
0.94 
4.73 
0.24 
0.48 
0.25 
0.12 
2.77 
3.55 
1.23 
1.67 
0.66 
0.28 
4.89 

0.22 
0.25 
0.03 
0.02 
0.01 
0.12 
0.17 
0.01 
0.09 
0.81 
2.21 
0.04 
0.04 
0.15 
0.53 
0.01 
0.03 
0.04 
0.01 
0.39 
0.17 
0.07 
0.06 
0.04 
0.02 
0.45 

1.74 
1.76 
0.79 
0.46 
0.14 
1.87 
1.08 
0.18 
0.85 
6.95 
17.19 
0.72 
1.06 
1.09 
5.26 
0.26 
0.50 
0.29 
0.13 
3.16 
3.72 
1.30 
1.73 
0.70 
0.30 
5.34 

211 Source: https://ec.europa.eu/eurostat/databrowser/view/sbs_sc_ovw__custom_17946676/default/table  
212 Actual and usual hours of work - Statistics Explained - Eurostat 
213 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.  

100 

 
 
 Member State 

Extension of the IT system 

Update templates for 
contracts  

Total one-off costs 

SE 
EU27 
Source: Ricardo (2025), Support study 

1.66 
54.22 

0.25 
6.24 

1.91 
60.46 

Recurrent  administrative  costs  are  expected  in  PO2A,  PO2B  and  PO2C  for  both  large  companies  and 
SMEs for reporting the activity performed (i.e. tonne-km) and whether the lorry that performed it is a ZEV. 
As  explained in section 5.2.3, most large  companies  perform  a  relatively  low share  of their  road  freight 
transport  activity  through  own  fleets  and  generally  rely  on  sub-contracting  for  the  vast  majority  of  their 
freight  transport  needs214.  All  transport  companies,  including  SMEs,  that  directly  or  indirectly  provide 
freight services by lorry to large companies will need to monitor and report their activity in terms of tonne-
km performed by type of vehicle, in order to allow the large company to monitor and report compliance with 
its target to the national authorities.  

For large companies, based on interviews with industry representatives, it is assumed that one minute per 
lorry per working day is needed to report the type of vehicle and activity performed (i.e. tonne-km) for the 
lorries that they own. Considering the evolution of the number of lorries owned by large companies in each 
policy option215, assuming 220 working days per year and the tariff rates by Member State for the ISCO 8 
category (plant and machine operators, and assemblers) in 2023 prices216, the recurrent administrative costs 
are estimated at around EUR 22 to 26 million per year  in all sub-options (PO2A, PO2B and PO2C), as 
shown in the table below.  

Table 47: Recurrent administrative costs for large companies for reporting on activity performed with their own 
lorries in PO2A, PO2B and PO2C, relative to the baseline (in million EUR) 

PO2A 

PO2B 

PO2C 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 

2029 
0.42 
0.66 
0.03 
0.13 
0.06 
0.51 
0.19 
0.05 
0.55 
2.95 
6.49 
0.42 
0.15 
0.25 
3.63 
0.04 
0.11 
0.01 
0.03 
0.52 
1.77 
0.09 
0.38 

2030 
0.42 
0.66 
0.03 
0.13 
0.06 
0.51 
0.19 
0.05 
0.55 
2.95 
6.49 
0.42 
0.15 
0.25 
3.63 
0.04 
0.11 
0.01 
0.03 
0.52 
1.77 
0.09 
0.38 

2040 
0.46 
0.75 
0.05 
0.12 
0.07 
0.58 
0.20 
0.05 
0.50 
3.03 
7.22 
0.41 
0.17 
0.29 
4.26 
0.03 
0.14 
0.02 
0.02 
0.55 
1.51 
0.08 
0.42 

2050 
0.51 
0.85 
0.08 
0.14 
0.08 
0.59 
0.23 
0.06 
0.55 
3.11 
7.24 
0.44 
0.20 
0.35 
4.75 
0.04 
0.15 
0.02 
0.03 
0.61 
1.57 
0.07 
0.46 

2029 
0.42 
0.65 
0.03 
0.13 
0.06 
0.51 
0.19 
0.05 
0.55 
2.95 
6.49 
0.42 
0.15 
0.25 
3.63 
0.04 
0.11 
0.01 
0.03 
0.52 
1.77 
0.09 
0.38 

2030 
0.42 
0.65 
0.03 
0.13 
0.06 
0.51 
0.19 
0.05 
0.55 
2.95 
6.49 
0.42 
0.15 
0.25 
3.63 
0.04 
0.11 
0.01 
0.03 
0.52 
1.77 
0.09 
0.38 

2040 
0.46 
0.75 
0.05 
0.12 
0.07 
0.58 
0.20 
0.05 
0.50 
3.03 
7.22 
0.41 
0.17 
0.29 
4.26 
0.03 
0.14 
0.02 
0.02 
0.55 
1.51 
0.08 
0.42 

2050 
0.51 
0.86 
0.08 
0.14 
0.08 
0.59 
0.23 
0.06 
0.55 
3.11 
7.24 
0.44 
0.20 
0.35 
4.75 
0.04 
0.15 
0.02 
0.03 
0.61 
1.57 
0.07 
0.46 

2029 
0.42 
0.65 
0.03 
0.13 
0.06 
0.51 
0.19 
0.05 
0.55 
2.95 
6.49 
0.42 
0.15 
0.25 
3.63 
0.04 
0.11 
0.01 
0.03 
0.52 
1.77 
0.09 
0.38 

2030 
0.42 
0.65 
0.03 
0.13 
0.06 
0.51 
0.19 
0.05 
0.55 
2.95 
6.49 
0.42 
0.15 
0.25 
3.63 
0.04 
0.11 
0.01 
0.03 
0.52 
1.77 
0.09 
0.38 

2040 
0.46 
0.75 
0.05 
0.12 
0.07 
0.58 
0.20 
0.05 
0.50 
3.03 
7.22 
0.41 
0.17 
0.29 
4.26 
0.03 
0.14 
0.02 
0.02 
0.55 
1.51 
0.08 
0.42 

2050 
0.51 
0.86 
0.08 
0.14 
0.08 
0.59 
0.23 
0.06 
0.55 
3.11 
7.23 
0.44 
0.20 
0.35 
4.75 
0.04 
0.15 
0.02 
0.03 
0.61 
1.57 
0.07 
0.46 

214 Typically, above 80% according to industry representatives. 
215 Based on PRIMES-TREMOVE model results.  
216 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.  

101 

 
  
 
PO2A 

2040 
0.19 
0.10 
2.14 
0.59 
23.95 
Source: Ricardo (2025), Support study 

2030 
0.17 
0.08 
2.16 
0.51 
22.37 

2029 
0.17 
0.08 
2.16 
0.51 
22.37 

SK 
SI 
ES 
SE 
EU27 

2050 
0.24 
0.10 
2.33 
0.66 
25.47 

2029 
0.17 
0.08 
2.16 
0.51 
22.36 

PO2B 

2030 
0.17 
0.08 
2.16 
0.51 
22.36 

2040 
0.19 
0.10 
2.14 
0.59 
23.94 

2050 
0.24 
0.10 
2.33 
0.66 
25.47 

2029 
0.17 
0.08 
2.16 
0.51 
22.36 

PO2C 

2030 
0.17 
0.08 
2.16 
0.51 
22.36 

2040 
0.19 
0.10 
2.14 
0.59 
23.94 

2050 
0.24 
0.10 
2.33 
0.66 
25.46 

In addition, 5 working days per year are assumed to be needed for collecting data from different parts of the 
company  and  from  sub-contractors,  quality-check,  validate,  and  submit  the  data  to  the  national  public 
authorities.  Using  the  tariff  rates  by  Member  State  for  the  ISCO  3  category  (technicians  and  associate 
professionals) in 2023 prices and the number of large companies, the recurrent costs for collecting the data 
from different parts of the company are estimated at EUR 62.43 million per year in PO2A, PO2B and PO2C 
as shown in the table below.  

Table  48:  Recurrent  administrative  costs  for  large  companies  for  collecting  data  from  different  parts  of  the 
company and from sub-contractors and submit the data to the national public authorities in PO2A, PO2B and 
PO2C, relative to the baseline (in million EUR) 

PO2A 

PO2B 

PO2C 

2040 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 
Source: Ricardo (2025), Support study 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

2030 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2029 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2050 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2029 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2030 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2040 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2050 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2029 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2030 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2040 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

2050 
2.17 
2.49 
0.25 
0.21 
0.11 
1.16 
1.72 
0.13 
0.93 
8.06 
22.10 
0.41 
0.43 
1.53 
5.29 
0.14 
0.25 
0.42 
0.07 
3.92 
1.68 
0.71 
0.63 
0.41 
0.20 
4.49 
2.52 
62.43 

For sub-contractors of large companies, 5 minutes per working day per lorry are assumed to be needed to 
report the type of vehicle and activity performed  (i.e. tonne-km), drawing on feedback from the targeted 
interviews.  Considering  the  tariff  rates  by  Member  State  for  the  ISCO  8  category  (plant  and  machine 
operators,  and  assemblers),  the  recurrent  administrative  costs  for  sub-contractors  of  large  companies  are 
estimated at around EUR 2.28 billion in 2029 and 2030, EUR 2.46 billion in 2040 and EUR 2.55 billion in 

102 

 
  
  
2050 in PO2A, PO2B and PO2C (see Table 49). Of this, for SMEs as sub-contractors of large companies 
the recurrent administrative costs are estimated at around EUR 1.84 billion in 2029 and 2030, EUR 1.98 
billion in 2040 and EUR 2.04 billion in 2050, and for large companies as sub-contractors of large companies 
at  around  EUR  447  million  in  2029  and  2030,  around  EUR  479  million  in  2040  and  around  EUR  509 
million in 2050 in PO2A, PO2B and PO2C relative to the baseline.  

Table 49: Recurrent administrative costs for sub-contractors (large companies and SMEs) of large companies to 
report  the  type  of  vehicle  and  the  activity  performed  in  PO2A,  PO2B  and  PO2C,  relative  to  the  baseline  (in 
million EUR) 

PO2A 

PO2B 

PO2C 

2029 
42.3 
102.8 
9.3 
10.5 
6.5 
48.0 
30.3 
5.4 
63.3 
355.2 
566.4 
40.7 
17.9 
21.5 
321.4 
5.3 
10.1 
3.2 
2.8 
81.4 
172.0 
10.5 
34.9 
19.7 
8.7 
227.2 
67.1 

2050 
49.9 
111.8 
13.1 
12.5 
7.4 
57.6 
32.7 
5.7 
54.2 
383.9 
623.1 
41.1 
22.5 
27.2 
433.7 
5.4 
13.7 
4.1 
2.4 
108.2 
151.2 
7.6 
40.8 
25.7 
11.2 
217.0 
82.4 
2,284.4  2,284.6  2,463.7  2,546.7  2,284.1  2,284.4  2,463.4  2,546.3  2,284.0  2,284.2  2,463.1  2,546.0 

2030 
42.3 
102.8 
9.3 
10.5 
6.5 
48.0 
30.3 
5.4 
63.3 
355.2 
566.5 
40.7 
17.9 
21.5 
321.4 
5.3 
10.2 
3.2 
2.8 
81.5 
172.0 
10.5 
35.0 
19.7 
8.7 
227.2 
67.1 

2050 
49.9 
111.8 
13.1 
12.5 
7.4 
57.6 
32.7 
5.7 
54.2 
383.9 
623.4 
41.1 
22.5 
27.2 
433.7 
5.4 
13.7 
4.1 
2.4 
108.2 
151.2 
7.6 
40.8 
25.7 
11.2 
217.0 
82.4 

2029 
42.3 
102.6 
9.3 
10.5 
6.5 
48.0 
30.3 
5.4 
63.3 
355.2 
566.3 
40.7 
17.9 
21.5 
321.4 
5.3 
10.1 
3.2 
2.8 
81.4 
172.0 
10.5 
34.9 
19.7 
8.7 
227.2 
67.1 

2040 
46.6 
111.3 
11.3 
11.7 
7.0 
55.0 
32.4 
5.6 
57.3 
379.0 
637.3 
40.0 
20.6 
23.0 
382.0 
5.4 
13.3 
3.7 
2.4 
98.3 
154.0 
8.9 
38.0 
21.6 
10.4 
213.5 
73.6 

2030 
42.3 
102.6 
9.3 
10.5 
6.5 
48.0 
30.3 
5.4 
63.3 
355.2 
566.4 
40.7 
17.9 
21.5 
321.4 
5.3 
10.2 
3.2 
2.8 
81.5 
172.0 
10.5 
34.9 
19.7 
8.7 
227.2 
67.1 

2040 
46.6 
111.3 
11.3 
11.7 
7.0 
55.0 
32.4 
5.6 
57.3 
379.0 
637.6 
40.0 
20.6 
23.0 
382.0 
5.4 
13.3 
3.7 
2.4 
98.3 
154.0 
8.9 
38.0 
21.6 
10.4 
213.5 
73.6 

2050 
49.9 
111.8 
13.1 
12.5 
7.4 
57.6 
32.7 
5.7 
54.2 
383.9 
623.7 
41.1 
22.5 
27.2 
433.7 
5.4 
13.7 
4.1 
2.4 
108.2 
151.2 
7.6 
40.8 
25.7 
11.2 
217.0 
82.4 

2040 
46.6 
111.3 
11.3 
11.7 
7.0 
55.0 
32.4 
5.6 
57.3 
379.0 
637.8 
40.0 
20.6 
23.0 
382.0 
5.4 
13.3 
3.7 
2.4 
98.3 
154.0 
8.9 
38.0 
21.6 
10.4 
213.5 
73.6 

2029 
42.3 
102.6 
9.3 
10.5 
6.5 
48.1 
30.3 
5.4 
63.3 
355.2 
566.2 
40.7 
17.9 
21.5 
321.4 
5.3 
10.1 
3.2 
2.8 
81.4 
172.0 
10.5 
34.9 
19.7 
8.7 
227.2 
67.1 

2030 
42.3 
102.6 
9.3 
10.5 
6.5 
48.1 
30.3 
5.4 
63.3 
355.2 
566.2 
40.7 
17.9 
21.5 
321.4 
5.3 
10.2 
3.2 
2.8 
81.5 
172.0 
10.5 
34.9 
19.7 
8.7 
227.2 
67.1 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

Source: Ricardo (2025), Support study 

Table 50: Recurrent administrative costs for SMEs as sub-contractors of large companies to report the type of 
vehicle and the activity performed in PO2A, PO2B and PO2C, relative to the baseline (in million EUR) 

PO2A 

PO2B 

PO2C 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 

2029 
33.9 
89.6 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.6 
32.3 

2030 
33.9 
89.6 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.7 
32.3 

2040 
37.4 
96.3 
10.4 
9.2 
5.5 
43.4 
28.3 
4.6 
47.4 
318.4 
493.3 
31.9 

2050 
39.7 
94.8 
11.4 
9.8 
5.8 
45.8 
28.2 
4.5 
43.1 
321.8 
478.9 
32.2 

2029 
33.9 
89.5 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.5 
32.3 

2030 
33.9 
89.5 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.6 
32.3 

103 

2040 
37.4 
96.3 
10.4 
9.2 
5.5 
43.4 
28.3 
4.6 
47.4 
318.4 
493.2 
31.9 

2050 
39.7 
94.7 
11.4 
9.8 
5.8 
45.8 
28.2 
4.5 
43.1 
321.8 
478.7 
32.2 

2029 
33.9 
89.5 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.4 
32.3 

2030 
33.9 
89.5 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.5 
32.3 

2040 
37.4 
96.3 
10.4 
9.2 
5.5 
43.4 
28.3 
4.6 
47.4 
318.4 
493.0 
31.9 

2050 
39.7 
94.7 
11.4 
9.8 
5.8 
45.8 
28.2 
4.5 
43.1 
321.7 
478.4 
32.2 

 
  
  
PO2A 

PO2B 

PO2C 

2029 
14.8 
16.5 
248.7 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2050 
18.6 
20.2 
338.6 
4.6 
10.7 
3.7 
1.9 
96.0 
119.8 
6.2 
31.5 
21.0 
9.1 
170.4 
69.2 
1,837.1  1,837.3  1,984.7  2,037.3  1,836.9  1,837.1  1,984.5  2,037.0  1,836.8  1,837.1  1,984.3  2,036.8 

2030 
14.8 
16.5 
248.8 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2050 
18.6 
20.2 
338.6 
4.6 
10.7 
3.7 
1.9 
96.0 
119.8 
6.2 
31.5 
21.0 
9.1 
170.4 
69.2 

2029 
14.8 
16.5 
248.7 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2040 
17.2 
17.2 
296.9 
4.7 
10.4 
3.3 
2.0 
87.3 
123.8 
7.3 
29.6 
17.8 
8.5 
170.7 
61.9 

2030 
14.8 
16.5 
248.8 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2040 
17.2 
17.2 
296.8 
4.7 
10.4 
3.3 
2.0 
87.3 
123.8 
7.3 
29.6 
17.8 
8.5 
170.7 
61.9 

2050 
18.6 
20.2 
338.6 
4.6 
10.7 
3.7 
1.9 
96.0 
119.8 
6.2 
31.5 
21.0 
9.1 
170.4 
69.2 

2040 
17.2 
17.2 
296.8 
4.7 
10.4 
3.3 
2.0 
87.3 
123.8 
7.3 
29.6 
17.8 
8.5 
170.7 
61.9 

2029 
14.8 
16.5 
248.7 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2030 
14.8 
16.5 
248.8 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

Source: Ricardo (2025), Support study 

Table  51:  Recurrent  administrative  costs  for  large  companies  as  sub-contractors  of  large  companies  to  report 
the  type  of  vehicle  and  the  activity  performed  in  PO2A,  PO2B  and  PO2C,  relative  to  the  baseline  (in  million 
EUR) 

PO2A 

PO2B 

PO2C 

2040 
9.2 
15.0 
1.0 
2.5 
1.5 
11.6 
4.1 
1.0 
10.0 
60.6 
144.5 
8.1 
3.4 
5.8 
85.2 
0.7 
2.9 
0.3 
0.5 
11.0 
30.2 
1.5 
8.4 
3.8 
1.9 
42.8 
11.7 
479.0 
Source: Ricardo (2025), Support study 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

2030 
8.4 
13.1 
0.7 
2.6 
1.2 
10.3 
3.8 
1.0 
11.0 
59.0 
129.8 
8.4 
3.0 
5.0 
72.6 
0.7 
2.2 
0.3 
0.5 
10.3 
35.4 
1.8 
7.5 
3.4 
1.6 
43.2 
10.2 
447.3 

2029 
8.4 
13.1 
0.7 
2.6 
1.2 
10.3 
3.8 
1.0 
11.0 
59.0 
129.8 
8.4 
3.0 
5.0 
72.6 
0.7 
2.2 
0.3 
0.5 
10.3 
35.4 
1.8 
7.5 
3.4 
1.6 
43.1 
10.2 
447.3 

2050 
10.3 
17.1 
1.7 
2.7 
1.7 
11.8 
4.5 
1.2 
11.0 
62.1 
144.8 
8.9 
3.9 
7.1 
95.1 
0.8 
3.0 
0.4 
0.5 
12.2 
31.4 
1.4 
9.3 
4.7 
2.1 
46.6 
13.3 
509.4 

2029 
8.4 
13.1 
0.7 
2.6 
1.2 
10.3 
3.8 
1.0 
11.0 
59.0 
129.8 
8.4 
3.0 
5.0 
72.6 
0.7 
2.2 
0.3 
0.5 
10.3 
35.4 
1.8 
7.5 
3.4 
1.6 
43.1 
10.2 
447.2 

2030 
8.4 
13.1 
0.7 
2.6 
1.2 
10.3 
3.8 
1.0 
11.0 
59.0 
129.8 
8.4 
3.0 
5.0 
72.6 
0.7 
2.2 
0.3 
0.5 
10.3 
35.4 
1.8 
7.5 
3.4 
1.6 
43.2 
10.2 
447.2 

2040 
9.2 
15.0 
1.0 
2.5 
1.5 
11.6 
4.1 
1.0 
10.0 
60.6 
144.4 
8.1 
3.4 
5.8 
85.2 
0.7 
2.9 
0.3 
0.5 
11.0 
30.2 
1.5 
8.4 
3.8 
1.9 
42.8 
11.7 
478.9 

2050 
10.3 
17.1 
1.7 
2.7 
1.7 
11.7 
4.5 
1.2 
11.0 
62.1 
144.7 
8.9 
3.9 
7.1 
95.1 
0.8 
3.0 
0.4 
0.5 
12.2 
31.4 
1.4 
9.3 
4.7 
2.1 
46.6 
13.3 
509.3 

2029 
8.4 
13.1 
0.7 
2.6 
1.2 
10.3 
3.8 
1.0 
11.0 
59.0 
129.7 
8.4 
3.0 
5.0 
72.6 
0.7 
2.2 
0.3 
0.5 
10.3 
35.4 
1.8 
7.5 
3.4 
1.6 
43.1 
10.2 
447.1 

2030 
8.4 
13.1 
0.7 
2.6 
1.2 
10.3 
3.8 
1.0 
11.0 
59.0 
129.7 
8.4 
3.0 
5.0 
72.6 
0.7 
2.2 
0.3 
0.5 
10.3 
35.4 
1.8 
7.5 
3.4 
1.6 
43.2 
10.2 
447.2 

2040 
9.2 
15.0 
1.0 
2.5 
1.5 
11.6 
4.1 
1.0 
10.0 
60.6 
144.3 
8.1 
3.4 
5.8 
85.2 
0.7 
2.9 
0.3 
0.5 
11.0 
30.2 
1.5 
8.4 
3.8 
1.9 
42.8 
11.7 
478.8 

2050 
10.3 
17.1 
1.7 
2.7 
1.7 
11.7 
4.5 
1.2 
11.0 
62.1 
144.7 
8.9 
3.9 
7.1 
95.1 
0.8 
3.0 
0.4 
0.5 
12.2 
31.4 
1.4 
9.3 
4.7 
2.1 
46.6 
13.3 
509.3 

Total  recurrent  administrative  costs  for  businesses  (for  large  companies  and  SMEs,  see  Table  52)  are 
estimated at around EUR 2.37 billion in 2029 and 2030, around EUR 2.55 billion in 2040 and at around 

104 

 
  
  
EUR 2.63 billion in 2050 for PO2A, PO2B and PO2C relative to the baseline (EUR 389 per vehicle in 2029 
and  2030,  EUR 394  per vehicle  in  2040  and EUR 392 per  vehicle  in  2050). Of  this, the total  recurrent 
administrative costs for large companies amount to around EUR 532 million in 2029 and 2030, around EUR 
565  million  in  2040  and  around  EUR  597  million  in  2050  in  PO2A,  PO2B  and  PO2C  relative  to  the 
baseline (see Table 53).  

Expressed as present value over 2029-2050, the total recurrent administrative costs are estimated at around 
EUR 41.29 billion in PO2A, PO2B and PO2C, of which EUR 32.13 billion for SMEs. Overall, total one-off 
and  recurrent  administrative  costs  for  businesses  are estimated  at  EUR  41.36 billion in  PO2A  and  EUR 
41.35 billion in PO2B and PO2C, expressed as present value over 2029-2050, of which EUR 32.13 billion 
for SMEs in PO2A, PO2B and PO2C.  

Table 52: Total recurrent administrative costs for businesses (large companies and SMEs) in PO2A, PO2B and 
PO2C, relative to the baseline (in million EUR) 

PO2A 

PO2B 

PO2C 

2029 
44.9 
105.9 
9.6 
10.8 
6.6 
49.7 
32.2 
5.5 
64.8 
366.2 
595.0 
41.6 
18.5 
23.3 
330.3 
5.5 
10.5 
3.6 
2.9 
85.9 
175.4 
11.3 
36.0 
20.3 
9.0 
233.9 
70.1 

2050 
52.6 
115.2 
13.4 
12.8 
7.6 
59.3 
34.6 
5.9 
55.6 
395.0 
652.5 
41.9 
23.1 
29.1 
443.8 
5.6 
14.1 
4.5 
2.5 
112.8 
154.4 
8.3 
41.9 
26.3 
11.5 
223.8 
85.6 
2,369.2  2,369.4  2,550.1  2,634.6  2,368.9  2,369.2  2,549.8  2,634.2  2,368.8  2,369.0  2,549.5  2,633.9 

2030 
44.9 
105.9 
9.6 
10.8 
6.6 
49.7 
32.2 
5.5 
64.8 
366.2 
595.1 
41.6 
18.5 
23.3 
330.3 
5.5 
10.5 
3.6 
2.9 
85.9 
175.5 
11.3 
36.0 
20.3 
9.0 
233.9 
70.1 

2050 
52.6 
115.2 
13.4 
12.8 
7.6 
59.3 
34.6 
5.9 
55.6 
395.1 
652.7 
41.9 
23.1 
29.1 
443.8 
5.6 
14.1 
4.5 
2.5 
112.7 
154.4 
8.4 
41.9 
26.3 
11.5 
223.8 
85.6 

2029 
44.9 
105.7 
9.6 
10.8 
6.6 
49.7 
32.2 
5.5 
64.8 
366.2 
594.9 
41.6 
18.5 
23.3 
330.3 
5.5 
10.5 
3.6 
2.9 
85.9 
175.4 
11.3 
36.0 
20.3 
9.0 
233.9 
70.1 

2040 
49.2 
114.5 
11.6 
12.1 
7.2 
56.7 
34.3 
5.7 
58.7 
390.0 
666.6 
40.8 
21.2 
24.8 
391.6 
5.6 
13.7 
4.1 
2.5 
102.8 
157.2 
9.6 
39.0 
22.2 
10.7 
220.1 
76.7 

2030 
44.9 
105.7 
9.6 
10.8 
6.6 
49.7 
32.2 
5.5 
64.8 
366.2 
595.0 
41.6 
18.5 
23.3 
330.3 
5.5 
10.5 
3.6 
2.9 
85.9 
175.5 
11.3 
36.0 
20.3 
9.0 
233.9 
70.1 

2040 
49.2 
114.5 
11.6 
12.1 
7.2 
56.7 
34.3 
5.7 
58.7 
390.1 
666.9 
40.8 
21.2 
24.8 
391.6 
5.6 
13.7 
4.1 
2.5 
102.8 
157.2 
9.6 
39.0 
22.2 
10.7 
220.1 
76.7 

2050 
52.6 
115.2 
13.4 
12.8 
7.6 
59.3 
34.7 
5.9 
55.7 
395.1 
653.1 
41.9 
23.1 
29.1 
443.7 
5.6 
14.1 
4.5 
2.5 
112.7 
154.4 
8.4 
41.9 
26.3 
11.5 
223.8 
85.6 

2040 
49.2 
114.6 
11.6 
12.1 
7.2 
56.7 
34.3 
5.7 
58.8 
390.1 
667.1 
40.8 
21.2 
24.8 
391.5 
5.6 
13.7 
4.1 
2.5 
102.8 
157.2 
9.6 
39.0 
22.2 
10.7 
220.2 
76.7 

2029 
44.9 
105.7 
9.6 
10.8 
6.6 
49.7 
32.2 
5.5 
64.8 
366.2 
594.7 
41.6 
18.5 
23.3 
330.3 
5.5 
10.5 
3.6 
2.9 
85.9 
175.4 
11.3 
35.9 
20.3 
9.0 
233.9 
70.1 

2030 
44.9 
105.8 
9.6 
10.8 
6.6 
49.7 
32.2 
5.5 
64.8 
366.2 
594.8 
41.6 
18.5 
23.3 
330.3 
5.5 
10.5 
3.6 
2.9 
85.9 
175.5 
11.3 
35.9 
20.3 
9.0 
233.9 
70.1 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

Source: Ricardo (2025), Support study 

Table 53: Total recurrent administrative costs for  large companies in PO2A, PO2B  and PO2C, relative to the 
baseline (in million EUR) 

PO2A 

PO2B 

PO2C 

AT 
BE 
BG 
HR 
CY 
CZ 

2029 
11.0 
16.3 
1.0 
3.0 
1.4 
11.9 

2030 
11.0 
16.3 
1.0 
3.0 
1.4 
11.9 

2040 
11.9 
18.2 
1.3 
2.8 
1.7 
13.3 

2050 
13.0 
20.4 
2.0 
3.1 
1.9 
13.5 

2029 
11.0 
16.2 
1.0 
3.0 
1.4 
11.9 

2030 
11.0 
16.2 
1.0 
3.0 
1.4 
11.9 

105 

2040 
11.9 
18.2 
1.3 
2.8 
1.7 
13.3 

2050 
13.0 
20.4 
2.0 
3.1 
1.9 
13.5 

2029 
11.0 
16.2 
1.0 
3.0 
1.4 
11.9 

2030 
11.0 
16.2 
1.0 
3.0 
1.4 
11.9 

2040 
11.9 
18.2 
1.3 
2.8 
1.7 
13.3 

2050 
13.0 
20.5 
2.0 
3.1 
1.9 
13.5 

 
  
  
PO2A 

PO2B 

PO2C 

2040 
6.0 
1.1 
11.4 
71.7 
173.8 
8.9 
4.0 
7.6 
94.7 
0.9 
3.3 
0.8 
0.6 
15.4 
33.4 
2.3 
9.5 
4.4 
2.2 
49.4 
14.8 
565.3 
Source: Ricardo (2025), Support study 

DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

2030 
5.7 
1.2 
12.5 
70.0 
158.4 
9.2 
3.6 
6.8 
81.6 
0.9 
2.5 
0.7 
0.6 
14.8 
38.9 
2.7 
8.5 
4.0 
1.9 
49.8 
13.2 
532.1 

2029 
5.7 
1.2 
12.5 
70.0 
158.4 
9.2 
3.6 
6.8 
81.6 
0.9 
2.5 
0.7 
0.6 
14.8 
38.9 
2.7 
8.5 
4.0 
1.9 
49.8 
13.2 
532.1 

2050 
6.4 
1.3 
12.5 
73.3 
174.1 
9.7 
4.6 
8.9 
105.1 
1.0 
3.4 
0.8 
0.6 
16.7 
34.6 
2.2 
10.4 
5.4 
2.4 
53.4 
16.4 
597.3 

2029 
5.7 
1.2 
12.5 
70.0 
158.4 
9.2 
3.6 
6.8 
81.6 
0.9 
2.5 
0.7 
0.6 
14.8 
38.9 
2.7 
8.5 
4.0 
1.9 
49.8 
13.2 
532.0 

2030 
5.7 
1.2 
12.5 
70.0 
158.4 
9.2 
3.6 
6.8 
81.6 
0.9 
2.5 
0.7 
0.6 
14.8 
38.9 
2.7 
8.5 
4.0 
1.9 
49.8 
13.2 
532.0 

2040 
6.0 
1.1 
11.4 
71.7 
173.7 
8.9 
4.0 
7.6 
94.7 
0.9 
3.3 
0.8 
0.6 
15.4 
33.4 
2.3 
9.5 
4.4 
2.2 
49.4 
14.8 
565.3 

2050 
6.4 
1.3 
12.5 
73.3 
174.1 
9.7 
4.6 
8.9 
105.1 
1.0 
3.4 
0.8 
0.6 
16.7 
34.6 
2.2 
10.4 
5.4 
2.4 
53.4 
16.4 
597.2 

2029 
5.7 
1.2 
12.5 
70.0 
158.3 
9.2 
3.6 
6.8 
81.6 
0.9 
2.5 
0.7 
0.6 
14.8 
38.9 
2.7 
8.5 
4.0 
1.9 
49.8 
13.2 
531.9 

2030 
5.7 
1.2 
12.5 
70.0 
158.3 
9.2 
3.6 
6.8 
81.6 
0.9 
2.5 
0.7 
0.6 
14.8 
38.9 
2.7 
8.5 
4.0 
1.9 
49.8 
13.2 
532.0 

2040 
6.0 
1.1 
11.4 
71.7 
173.6 
8.9 
4.0 
7.6 
94.7 
0.9 
3.3 
0.8 
0.6 
15.4 
33.4 
2.3 
9.5 
4.4 
2.2 
49.4 
14.8 
565.2 

2050 
6.4 
1.3 
12.5 
73.3 
174.0 
9.7 
4.6 
8.9 
105.1 
1.0 
3.4 
0.8 
0.6 
16.7 
34.6 
2.2 
10.4 
5.4 
2.4 
53.4 
16.4 
597.1 

Table 54: Total recurrent administrative costs for SMEs in PO2A, PO2B and PO2C, relative to the baseline (in 
million EUR) 

PO2A 

PO2B 

PO2C 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 

2029 
33.9 
89.6 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.6 
32.3 
14.8 
16.5 
248.7 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2030 
33.9 
89.6 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.7 
32.3 
14.8 
16.5 
248.8 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2040 
37.4 
96.3 
10.4 
9.2 
5.5 
43.4 
28.3 
4.6 
47.4 
318.4 
493.3 
31.9 
17.2 
17.2 
296.8 
4.7 
10.4 
3.3 
2.0 
87.3 
123.8 
7.3 
29.6 
17.8 
8.5 
170.7 
61.9 

2050 
39.7 
94.8 
11.4 
9.8 
5.8 
45.8 
28.2 
4.5 
43.1 
321.8 
478.9 
32.2 
18.6 
20.2 
338.6 
4.6 
10.7 
3.7 
1.9 
96.0 
119.8 
6.2 
31.5 
21.0 
9.1 
170.4 
69.2 

2029 
33.9 
89.5 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.5 
32.3 
14.8 
16.5 
248.7 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2030 
33.9 
89.5 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.6 
32.3 
14.8 
16.5 
248.8 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

106 

2040 
37.4 
96.3 
10.4 
9.2 
5.5 
43.4 
28.3 
4.6 
47.4 
318.4 
493.2 
31.9 
17.2 
17.2 
296.8 
4.7 
10.4 
3.3 
2.0 
87.3 
123.8 
7.3 
29.6 
17.8 
8.5 
170.7 
61.9 

2050 
39.7 
94.7 
11.4 
9.8 
5.8 
45.8 
28.2 
4.5 
43.1 
321.8 
478.7 
32.2 
18.6 
20.2 
338.6 
4.6 
10.7 
3.7 
1.9 
96.0 
119.8 
6.2 
31.5 
21.0 
9.1 
170.4 
69.2 

2029 
33.9 
89.5 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.4 
32.3 
14.8 
16.5 
248.7 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2030 
33.9 
89.5 
8.6 
7.8 
5.2 
37.8 
26.5 
4.3 
52.3 
296.2 
436.5 
32.3 
14.8 
16.5 
248.8 
4.6 
8.0 
2.9 
2.2 
71.1 
136.6 
8.6 
27.4 
16.3 
7.1 
184.1 
56.9 

2040 
37.4 
96.3 
10.4 
9.2 
5.5 
43.4 
28.3 
4.6 
47.4 
318.4 
493.0 
31.9 
17.2 
17.2 
296.9 
4.7 
10.4 
3.3 
2.0 
87.3 
123.8 
7.3 
29.6 
17.8 
8.5 
170.7 
61.9 

2050 
39.7 
94.7 
11.4 
9.8 
5.8 
45.8 
28.2 
4.5 
43.1 
321.7 
478.4 
32.2 
18.6 
20.2 
338.6 
4.6 
10.7 
3.7 
1.9 
96.0 
119.8 
6.2 
31.5 
21.0 
9.1 
170.4 
69.2 

 
  
  
PO2A 

PO2B 

PO2C 

2029 

2050 
1,837.1  1,837.3  1,984.7  2,037.3  1,836.9  1,837.1  1,984.5  2,037.0  1,836.8  1,837.1  1,984.3  2,036.8 

2030 

2050 

2029 

2040 

2040 

2050 

2030 

2040 

2029 

2030 

EU27 

Source: Ricardo (2025), Support study 

Recurrent enforcement costs are only expected in PO2A, PO2B and PO2C for cooperating with the sample 
verification  of  the  correctness of  companies’  reporting that  will be used  by public  authorities to  monitor 
enforcement. One percent of large companies is assumed to be checked per year on average and the check 
per company is assumed to take 2 working days. Using the tariff rates by Member State for the ISCO 3 
category  (technicians  and  associate  professionals),  the  total  recurrent  enforcement  costs  are  estimated  at 
EUR 0.25 million per year in PO2A, PO2B and PO2C, or EUR 4.1 million expressed as present value over 
2029-2050. 

Table 55: Recurrent enforcement costs for large companies in PO2A, PO2B and PO2C, relative to the baseline 
(in million EUR) 

PO2A 

PO2B 

PO2C 

2040 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 
Source: Ricardo (2025), Support study 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

2030 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2029 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2050 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2029 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2030 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2040 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2050 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2029 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2030 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2040 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2050 
0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

3.2.  Administrative costs for public authorities 

One-off  and  recurrent  administrative  costs  for  public  authorities.  For  PO1A,  PO1B  and  PO1C 
monitoring and reporting on the targets will be ensured directly by the Member States, by extracting the 
relevant data from their vehicle registries and submitting it yearly to the Commission. This is also the case of 
cars  and  vans  under  PO2A,  PO2B  and  PO2C.  While  Member  States  are  already  able  to  differentiate 
corporate  from  private  vehicles  in their  registry, the  exclusion  of  corporate  vehicles  registered  by SMEs 
would require a one-off adaptation of Member States’ registries.  

107 

 
  
  
One-off administrative costs for public authorities in all policy options are derived assuming an effort of 
0.2 full time equivalents per Member State for adapting the vehicle registers217. Considering 220 working 
days per year and 7.2 working hours per day on average218, and using the tariff rate per hour by Member 
State for the ISCO 3 category (technicians and associate professionals) in 2023 prices219, the total one-off 
costs for public authorities at EU level are estimated at EUR 0.23 million in 2029 in all policy options.  

Table  56:  One-off  administrative  costs  for  public  authorities  in  all  policy  options,  relative  to  the  baseline  (in 
million EUR) 

One-off administrative costs 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 
Source: Ricardo (2025), Support study 

0.01 
0.01 
0.00 
0.00 
0.01 
0.01 
0.02 
0.01 
0.01 
0.01 
0.01 
0.01 
0.00 
0.01 
0.01 
0.01 
0.00 
0.01 
0.01 
0.01 
0.00 
0.01 
0.00 
0.01 
0.01 
0.01 
0.01 
0.23 

Recurrent  administrative  costs  for  public  authorities.  In  PO1A,  PO1B  and  PO1C  Member  States  are 
expected  to  spend  2  working  days  per  year  for  extracting,  validating,  and  submitting  the  data  to  the 
Commission/EEA.  Considering  7.2  working  hours  per  day  on  average  and  the  tariff  rate  per  hour  by 
Member State for the ISCO 3 category (technicians and associate professionals), the recurrent administrative 
costs are estimated at EUR 10,350 per year at EU level. Expressed as present value over 2029-2050 they 
amount to EUR 0.17 million relative to the baseline.  

In  PO2A,  PO2B  and  PO2C,  for  cars  and  vans  the  reporting  is  the  same  as  in  PO1.  For  lorries,  public 
authorities will be required to compile reports from all large companies established on their territory and 

217  This  draws  on  the  assumptions  for  adding  new  data  to  the  vehicle  register  used  in  the  impact  assessment 
accompanying  the  revision  of  the  Roadworthiness  Package  (SWD(2025)  96  final/2),  which  considers  2.1  full  time 
equivalents for a much larger set of data to be added to the vehicle register. 
218 Actual and usual hours of work - Statistics Explained - Eurostat 
219 Eurostat Structure of earnings survey, Labour Force Survey data for Non-Wage Labour Costs.  

108 

 
  
 
submit them yearly to the Commission/EEA. Around 3.5 hours would be needed to receive, quality-check 
and collate information from each one of the reporting companies. In addition, 3 working days would be 
needed  per  year  to  compile  all  information  (for  cars,  vans  and  lorries),  validate,  and  submit  it  to  the 
Commission/EEA. The total recurrent administrative costs for reporting are estimated at EUR 6.09 million 
per  year.  Expressed  as  present  value  over  2029-2050  they  amount  to  EUR  99.89  million  relative  to  the 
baseline.  

Table 57: Recurrent administrative costs for public authorities for reporting in the policy options, relative to the 
baseline (in million EUR) 

PO1A/PO1B/PO1C 

PO2A/PO2B/PO2C 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

2029 
0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

2030 
0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

2040 
0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

2050 
0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

2029 
0.21 
0.24 
0.02 
0.02 
0.01 
0.11 
0.17 
0.01 
0.09 
0.78 
2.15 
0.04 
0.04 
0.15 
0.51 
0.01 
0.02 
0.04 
0.01 
0.38 
0.16 
0.07 
0.06 
0.04 
0.02 
0.44 
0.25 
6.09 

2030 
0.21 
0.24 
0.02 
0.02 
0.01 
0.11 
0.17 
0.01 
0.09 
0.78 
2.15 
0.04 
0.04 
0.15 
0.51 
0.01 
0.02 
0.04 
0.01 
0.38 
0.16 
0.07 
0.06 
0.04 
0.02 
0.44 
0.25 
6.09 

2040 
0.21 
0.24 
0.02 
0.02 
0.01 
0.11 
0.17 
0.01 
0.09 
0.78 
2.15 
0.04 
0.04 
0.15 
0.51 
0.01 
0.02 
0.04 
0.01 
0.38 
0.16 
0.07 
0.06 
0.04 
0.02 
0.44 
0.25 
6.09 

2050 
0.21 
0.24 
0.02 
0.02 
0.01 
0.11 
0.17 
0.01 
0.09 
0.78 
2.15 
0.04 
0.04 
0.15 
0.51 
0.01 
0.02 
0.04 
0.01 
0.38 
0.16 
0.07 
0.06 
0.04 
0.02 
0.44 
0.25 
6.09 

Source: Ricardo (2025), Support study 

Furthermore,  in  PO2A,  PO2B  and  PO2C  monitoring  enforcement  will  be  performed  based  on  sample 
verification of the correctness of companies’ reporting. One percent of large companies is assumed to be 
checked per year on average and the check per company is assumed to take 2 working days, with total costs 
for  monitoring  enforcement  estimated  at  EUR  0.25  million  per  year,  or  EUR  4.1  million  expressed  as 
present value over 2029-2050.  

Table 58: Recurrent administrative costs for public authorities for monitoring enforcement in PO2A, PO2B and 
PO2C, relative to the baseline (in million EUR) 

AT 
BE 
BG 
HR 
CY 

2029 
0.01 
0.00 
0.00 
0.01 
0.09 

PO2A/PO2B/PO2C 

2030 
0.01 
0.00 
0.00 
0.01 
0.09 

109 

2040 
0.01 
0.00 
0.00 
0.01 
0.09 

2050 
0.01 
0.00 
0.00 
0.01 
0.09 

 
  
  
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

2029 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

PO2A/PO2B/PO2C 

2030 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2040 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

2050 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

Source: Ricardo (2025), Support study 

Total recurrent administrative costs for public authorities are thus estimated at EUR 10,350 per year at EU 
level for PO1A, PO1B and PO1C and at EUR 6.33 million per year in PO2A, PO2B and PO2C. Expressed 
as present value over 2029-2050 they are estimated at EUR 0.17 million in PO1A, PO1B and PO1C and at  
EUR 103.99 million for PO2A, PO2B and PO2C relative to the baseline.  

Table 59: Total recurrent administrative costs for public authorities in the policy options, relative to the baseline 
(in million EUR) 

PO1A/PO1B/PO1C 

PO2A/PO2B/PO2C 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 

2029 
0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 

2030 
0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 

2040 
0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 

2050 
0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 

110 

2029 
0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 

2030 
0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 

2040 
0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 

2050 
0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 

 
  
  
PO1A/PO1B/PO1C 

PO2A/PO2B/PO2C 

2029 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

2030 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

2040 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

2050 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

2029 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

2030 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

2040 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

2050 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

PT 
RO 
SK 
SI 
ES 
SE 
EU27 

Source: Ricardo (2025), Support study 

The total one-off and recurrent administrative costs for public authorities amount to EUR 0.40 million in 
PO1A, PO1B and PO1C and at EUR 104.21 million, expressed as present value over 2029-2050 relative to 
the baseline.  

4.  OTHER DETAILED IMPACTS OF THE POLICY OPTIONS 

This section provides more detailed results on the changes in ZEV in the second-hand market and 
total stock, as well as on the fossil fuel consumption, CO2 and air pollution emissions and external 
costs.  Table  60  presents  the  number  of  ZEV  in  the  second-hand  market  in  the  policy  options 
relative to the baseline for 2031-2035, 2036-2040, 2041-2045 and 2046-2050 by different type of 
vehicle (cars, vans and lorries) and stakeholder group (citizens and corporate for large companies 
and  SMEs).  Table  61  presents  the  number  of  ZEV  in  the  stock  for  2030,  2040  and  2050  in  the 
policy  options  relative  to  the  baseline  by  different  type  of  vehicle  (cars,  vans  and  lorries)  and 
stakeholder  group  (citizens  and  corporate  for  large  companies  and  SMEs).  Table  62  presents  the 
fossil fuel consumption by policy option for specific years, relative to the baseline, while Tables 63 
and  64  present  the  impacts  on  CO2  emissions  and  air  pollution  emissions  and  the  impacts  on 
external costs of CO2 emissions, air pollution emissions and noise for specific years. 

Table  60:  Number  of  ZEV  in  the  second-hand  market  in  the  policy  options  (difference  relative  to  the  baseline), 
expressed as annual averages over 2031-2035, 2036-2040, 2041-2045 and 2046-2050 (in thousand vehicles) 

Cars 

Citizens 
Corporate 

Large companies 
SMEs 

Vans 

Citizens 
Corporate 

Large companies 
SMEs 

Lorries 

Large companies 
SMEs 

Total 

Cars 

Citizens 
Corporate 

Large companies 
SMEs 

Vans 

PO1A 

PO1B 

PO1C 

'31-35 
461 
333 
127 
4 
123 
24 
1 
22 
4 
18 
4 
1 
3 
488 

'36-40 
1,078 
796 
282 
8 
274 
149 
10 
139 
24 
115 
18 
3 
16 
1,245 

'41-45 
688 
509 
179 
5 
174 
162 
11 
151 
25 
126 
28 
4 
24 
878 

'46-50 
152 
110 
43 
2 
41 
81 
5 
76 
12 
64 
40 
6 
34 
273 

'31-35 
715 
517 
198 
7 
191 
44 
3 
41 
7 
34 
6 
1 
5 
764 

'36-40 
1,621 
1,189 
432 
14 
418 
205 
13 
192 
33 
159 
29 
4 
25 
1,855 

'41-45 
1,027 
754 
274 
9 
264 
220 
14 
205 
34 
171 
45 
7 
38 
1,292 

'46-50 
234 
167 
67 
3 
64 
112 
6 
106 
17 
89 
56 
9 
47 
401 

'31-35 
885 
639 
246 
9 
237 
64 
4 
60 
10 
50 
9 
1 
7 
958 

'36-40 
2,180 
1,597 
583 
19 
564 
267 
17 
250 
43 
207 
41 
6 
34 
2,488 

'41-45 
1,431 
1,048 
383 
14 
369 
288 
19 
270 
45 
225 
65 
10 
55 
1,784 

'46-50 
328 
234 
95 
5 
90 
154 
9 
146 
23 
122 
77 
12 
65 
559 

PO2A 

PO2B 

PO2C 

'31-35 
461 
333 
127 
4 
123 
24 

'36-40 
1,078 
796 
282 
8 
274 
149 

'41-45 
688 
509 
179 
5 
174 
162 

'46-50 
152 
110 
43 
2 
41 
81 

'31-35 
715 
517 
198 
7 
191 
44 

'36-40 
1,621 
1,189 
432 
14 
418 
205 

'41-45 
1,027 
754 
274 
9 
264 
220 

'46-50 
234 
167 
67 
3 
64 
112 

'31-35 
885 
639 
246 
9 
237 
64 

'36-40 
2,180 
1,597 
583 
19 
564 
267 

'41-45 
1,431 
1,048 
383 
14 
369 
288 

'46-50 
328 
234 
95 
5 
90 
154 

111 

 
  
  
  
Citizens 
Corporate 

Large companies 
SMEs 

Lorries 

Large companies 
SMEs 

1 
22 
4 
18 
30 
4 
25 
514 

10 
139 
24 
115 
100 
16 
84 
1,327 

11 
151 
25 
126 
157 
26 
131 
1,007 

5 
76 
12 
64 
196 
32 
164 
429 

3 
41 
7 
34 
40 
6 
34 
798 

13 
192 
33 
159 
134 
22 
112 
1,960 

14 
205 
34 
171 
208 
34 
174 
1,455 

6 
106 
17 
89 
254 
42 
212 
599 

4 
60 
10 
50 
57 
9 
48 
1,006 

17 
250 
43 
207 
175 
28 
147 
2,622 

19 
270 
45 
225 
265 
43 
222 
1,985 

9 
146 
23 
122 
319 
52 
267 
802 

Total 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

Table 61: Number of ZEV in the stock in the policy options - difference relative to the baseline (in thousand vehicles) 

Cars 

Citizens 
Corporate 

Large companies 
SMEs 

Vans 

Citizens 
Corporate 

Large companies 
SMEs 

Lorries 

Large companies 
SMEs 

Cars 

Citizens 
Corporate 

Large companies 
SMEs 

Vans 

Citizens 
Corporate 

Large companies 
SMEs 

Lorries 

Large companies 
SMEs 

PO1A 
2040 

2030 

2050 

2030 

PO1B 
2040 

2050 

2030 

PO1C 
2040 

2050 

477 
-347 
825 
1,026 
-201 
37 
-6 
43 
85 
-42 
3 
11 
-8 

1,019 
686 
333 
17 
315 
182 
-10 
192 
140 
53 
27 
35 
-8 

606 
586 
20 
2 
18 
47 
-4 
51 
8 
43 
45 
24 
21 

852 
-421 
1,273 
1,517 
-243 
75 
-9 
84 
150 
-66 
6 
18 
-12 

1,698 
1,193 
505 
27 
478 
262 
-8 
270 
170 
100 
42 
57 
-16 

1,018 
986 
31 
3 
28 
67 
-3 
70 
11 
59 
59 
27 
32 

1,084 
-492 
1,575 
1,860 
-284 
111 
-13 
123 
221 
-98 
9 
25 
-16 

2,531 
1,824 
708 
38 
669 
358 
-4 
363 
203 
160 
63 
82 
-19 

1,541 
1,497 
44 
4 
40 
98 
0 
98 
15 
83 
81 
30 
50 

PO2A 
2040 

2030 

2050 

2030 

PO2B 
2040 

2050 

2030 

PO2C 
2040 

2050 

477 
-347 
825 
1,026 
-201 
37 
-6 
43 
85 
-42 
54 
12 
42 

1,019 
686 
333 
17 
315 
182 
-10 
192 
140 
53 
205 
26 
179 

606 
586 
20 
2 
18 
47 
-4 
51 
8 
43 
267 
45 
222 

852 
-421 
1,273 
1,517 
-243 
75 
-9 
84 
150 
-66 
77 
15 
62 

1,698 
1,193 
505 
27 
478 
262 
-8 
270 
170 
100 
269 
43 
226 

1,018 
986 
31 
3 
28 
67 
-3 
70 
11 
59 
332 
58 
274 

1,084 
-492 
1,575 
1,860 
-284 
111 
-13 
123 
221 
-98 
115 
24 
91 

2,531 
1,824 
708 
38 
669 
358 
-4 
363 
203 
160 
338 
56 
283 

1,541 
1,497 
44 
4 
40 
98 
0 
98 
15 
83 
407 
73 
334 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

Table  62:  Impacts  on  fossil  fuel  consumption  in  the  policy  options  for  2029,  2030,  2040  and  2050  relative  to  the 
baseline (in ktoe and % change to the baseline) 

Fossil fuel 
consumption (ktoe) 
% change to baseline 

PO1A  

PO1B 

PO1C 

2029 
-134 

2030 
-386 

2040 
-418 

2050 
-77 

2029 
-374 

2030 
-1,094 

2040 
-1,127 

2050 
-108 

2029 
-521 

2030 
-1,524 

2040 
-2,340 

2050 
-160 

-0.1% 

-0.1% 

-0.2% 

-0.7% 

-0.2% 

-0.2% 

-0.5% 

-1.0% 

-0.3% 

-0.3% 

-1.1% 

-1.4% 

PO2A 

PO2B 

PO2C 

2029 
-198 

2030 
-567 

2040 
-3,407 

2050 
-402 

2029 
-579 

2030 
-1,712 

2040 
-4,783 

2050 
-490 

Fossil fuel 
consumption (ktoe) 
% change to baseline 
-4.4% 
-1.6% 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

-3.6% 

-0.3% 

-0.3% 

-2.2% 

-0.1% 

-0.1% 

2029 
-961 

2030 
-2,869 

2040 
-6,645 

2050 
-610 

-0.6% 

-0.5% 

-3.1% 

-5.4% 

112 

 
  
  
  
  
Table 63: Impacts on CO2 emissions and air pollution emissions in the policy options for 2029, 2030, 2040 and 2050 
relative to the baseline (in kt and % change to the baseline) 

CO2 emissions (kt) 
% change to baseline 
NOx emissions (kt) 
% change to baseline 
PM2.5 emissions (kt) 
% change to baseline 

PO1A  

2029 
-381 
-0.1% 
-0.8 
-0.1% 
0.0 
-0.1% 

2030 
-381 
-0.1% 
-0.8 
-0.1% 
0.0 
-0.1% 

2040 
-412 
-0.2% 
-0.8 
-0.3% 
0.0 
-0.1% 

2050 
-77 
-0.7% 
-0.2 
-0.5% 
0.0 
1.0% 

2029 
-1,088 
-0.2% 
-1.3 
-0.1% 
-0.1 
-0.1% 

PO2A 

PO1B 

2030 
-1,089 
-0.2% 
-1.3 
-0.1% 
-0.1 
-0.1% 

2040 
-1,122 
-0.5% 
-1.4 
-0.6% 
0.0 
-0.3% 

PO2B 

2050 
-108 
-1.0% 
-0.3 
-0.8% 
0.0 
0.8% 

2040 
2050 
-3,402 
CO2 emissions (kt) 
-491 
-1.6% 
% change to baseline 
-4.5% 
-1.8 
NOx emissions (kt) 
-1.5 
-0.7% 
% change to baseline 
-3.8% 
-0.1 
PM2.5 emissions (kt) 
0.0 
-0.3% 
% change to baseline 
0.0% 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

2040 
-4,778 
-2.3% 
-2.6 
-1.1% 
-0.1 
-0.6% 

2029 
-1,706 
-0.3% 
0.9 
0.1% 
0.0 
0.0% 

2030 
-1,707 
-0.3% 
0.9 
0.1% 
0.0 
0.0% 

2050 
-402 
-3.7% 
-1.2 
-3.0% 
0.0 
0.3% 

2030 
-562 
-0.1% 
1.4 
0.2% 
0.0 
0.0% 

2029 
-561 
-0.1% 
1.4 
0.2% 
0.0 
0.0% 

PO1C 

2030 
-1,520 
-0.3% 
-1.4 
-0.2% 
-0.1 
-0.1% 

2040 
-2,335 
-1.1% 
-2.4 
-1.0% 
-0.1 
-0.6% 

PO2C 

2030 
-2,864 
-0.6% 
0.7 
0.1% 
0.0 
-0.1% 

2040 
-6,640 
-3.2% 
-4.3 
-1.8% 
-0.2 
-1.0% 

2050 
-161 
-1.5% 
-0.6 
-1.4% 
0.0 
0.5% 

2050 
-611 
-5.7% 
-2.0 
-5.1% 
0.0 
-0.5% 

2029 
-1,518 
-0.3% 
-1.4 
-0.2% 
-0.1 
-0.1% 

2029 
-2,862 
-0.6% 
0.7 
0.1% 
0.0 
-0.1% 

Table  64:  Savings  in  external  costs  of  CO2  emissions,  air  pollution  emissions  and  noise  emissions  in the policy 
options for 2029, 2030, 2040 and 2050 relative to the baseline, in million EUR (2023 prices) 

CO2 emissions  
Air pollution emissions 
Noise emissions 

PO1A 

PO1B 

PO1C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

48 
19 
5 

96 
13 
5 

48 
19 
5 
PO2A 

26 
-3 
2 

137 
34 
13 

261 
29 
14 

137 
34 
13 
PO2B 

37 
1 
4 

192 
40 
18 

543 
57 
27 

192 
40 
18 
PO2C 

55 
7 
7 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

CO2 emissions  
Air pollution emissions 
Noise emissions 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

1,112 
48 
25 

792 
28 
17 

137 
12 
11 

215 
-9 
47 

215 
-9 
47 

71 
-26 
33 

71 
-26 
33 

167 
18 
15 

361 
-4 
66 

361 
-4 
66 

1,545 
84 
42 

207 
27 
24 

5.  SUMMARY OF COSTS AND COST SAVINGS BY POLICY OPTION AND STAKEHOLDER GROUP  

This section provides the costs and costs savings by policy option and stakeholder group for 2029, 2030, 
2040 and 2050 relative to the baseline. The present value of the costs and costs savings by stakeholder group 
over 2029-2050, relative to the baseline, are presented in section 6.1 of the impact assessment.  

5.1.  Businesses 

Table 65: Recurrent and one-off costs and cost savings for businesses in the policy options, in 2029, 2030, 2040 
and 2050, relative to the baseline, in million EUR (2023 prices) 

PO1A 

PO1B 

PO1C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

Administrative costs 

Enforcement costs 

Adjustment costs 

Capital costs 

Fuel costs 

Other operation costs 

Increase in tax 
expenditures 
Adjustment costs savings 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

1,149 

1,151 

1,396 

276 

391 

482 

470 

277 

392 

483 

470 

408 

679 

309 

474 

1,464 

1,466 

1,767 

Capital costs savings 

518 

519 

916 

0.00 

0.00 

384 

168 

161 

55 

33 

624 

160 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

1,668 

1,670 

1,938 

397 

552 

719 

644 

397 

553 

720 

645 

689 

840 

409 

646 

2,368 

2,370 

2,447 

873 

874 

1,259 

0.00 

0.00 

420 

177 

196 

47 

26 

636 

149 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

2,211 

2,213 

2,471 

535 

717 

959 

820 

535 

717 

960 

821 

984 

966 

520 

789 

3,174 

3,177 

3,177 

1,175 

1,176 

1,560 

0.00 

0.00 

458 

237 

183 

37 

14 

659 

116 

113 

 
  
  
  
  
  
  
  
Fuel costs savings 

Other operation costs 
savings 

Reduction in tax 
expenditures 
Net benefits (+) or net 
costs (-) 

549 

397 

550 

397 

491 

360 

273 

191 

873 

622 

873 

623 

694 

494 

280 

207 

1,145 

1,146 

854 

855 

958 

659 

292 

251 

918 

919 

729 

173 

1,447 

1,448 

1,155 

179 

1,866 

1,868 

1,696 

206 

764 

764 

626 

380 

1,502 

1,504 

1,018 

368 

2,009 

2,011 

1,613 

393 

PO2A 

PO2B 

PO2C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

Administrative costs 

2,430 

2,369 

2,550 

2,635 

2,429 

2,369 

2,550 

2,634 

2,429 

2,369 

2,549 

2,634 

Enforcement costs 

Adjustment costs 

Capital costs 

Fuel costs 

Other operation costs 

Increase in tax 
expenditures 
Adjustment costs savings 

Capital costs savings 

Fuel costs savings 

Other operation costs 
savings 

0.25 

0.25 

0.25 

0.25 

0.25 

0.25 

0.25 

0.25 

0.25 

0.25 

0.25 

0.25 

1,599 

1,600 

2,397 

1,326 

2,254 

2,256 

3,108 

1,645 

3,208 

3,211 

3,939 

1,888 

684 

645 

269 

424 

685 

646 

270 

424 

1,705 

1,138 

1,006 

1,007 

2,394 

1,463 

1,543 

1,545 

3,198 

1,735 

482 

210 

133 

134 

54 

33 

861 

387 

539 

862 

387 

540 

514 

200 

130 

134 

1,117 

1,118 

47 

26 

548 

647 

549 

648 

469 

272 

118 

116 

37 

14 

1,077 

1,078 

1,527 

2,244 

1,768 

1,770 

1,929 

2,576 

2,440 

2,442 

2,510 

2,974 

339 

497 

242 

339 

497 

242 

583 

430 

514 

100 

1,648 

496 

599 

797 

372 

599 

798 

373 

707 

617 

605 

107 

799 

799 

1,909 

1,048 

1,049 

560 

593 

594 

843 

859 

807 

116 

2,200 

658 

907 

908 

Reduction in tax 
expenditures 
Net benefits (+) or net 
costs (-) 
Source:  Ricardo  (2025),  Support  study;  PRIMES-TREMOVE  transport  model  (E3-Modelling)  and  standard  cost  model  for 
administrative and enforcement costs 

-1,666 

-1,237 

-2,409 

-1,898 

-1,872 

-1,992 

-1,931 

-1,811 

-2,469 

2,193 

2,860 

1,109 

1,655 

1,973 

1,975 

1,463 

1,465 

1,291 

-620 

-783 

-272 

967 

Table  66:  One-off  costs  and  cost  savings  for  businesses  in  the  policy  options,  in  2029,  2030,  2040  and  2050, 
relative to the baseline, in million EUR (2023 prices) 

PO1A 

PO1B 

PO1C 

Administrative costs 
Adjustment costs 
(capital costs) 
Adjustment costs 
savings (capital costs 
savings) 
Net benefits (+) or 
net costs (-) 

Administrative costs 
Adjustment costs 
(capital costs) 
Adjustment costs 
savings (capital costs 
savings) 
Net benefits (+) or 
net costs (-) 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

0.00 
276 

0.00 
277 

0.00 
408 

0.00 
168 

0.00 
397 

0.00 
397 

0.00 
689 

0.00 
177 

0.00 
535 

0.00 
535 

0.00 
984 

0.00 
237 

518 

519 

916 

160 

873 

874 

1,259 

149 

1,175 

1,176 

1,560 

116 

242 

242 

508 

-8 

477 

477 

571 

-28 

640 

640 

576 

-121 

PO2A 

PO2B 

PO2C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

60.46 
684 

0.00 
685 

0.00 
1,705 

0.00 
1,138 

60.46 
1,006 

0.00 
1,007 

0.00 
2,394 

0.00 
1,463 

60.46 
1,543 

0.00 
1,545 

0.00 
3,198 

0.00 
1,735 

339 

339 

583 

100 

599 

599 

707 

107 

799 

799 

843 

116 

-406 

-346 

-1,122 

-1,038 

-468 

-408 

-1,686 

-1,357 

-805 

-745 

-2,355 

-1,619 

Source:  Ricardo  (2025),  Support  study;  PRIMES-TREMOVE  transport  model  (E3-Modelling)  and  standard  cost  model  for 
administrative costs 

5.2.  National public authorities 

In the baseline scenario the fuel tax revenues from cars, vans and lorries are projected to decrease from EUR 
189.3 billion in 2029 to EUR 54.2 billion in 2050, driven by the higher uptake of ZEV over time. It should 
be noted that the losses in tax revenues, presented in the table below, represent around 0.5% of the baseline 

114 

 
  
  
  
in 2029-2030 in PO1A/PO2A, around 0.8% in PO1B/PO2B and around 1% in PO1C/PO2C. Post-2030, the 
reduction is higher in PO2 (i.e. 1.8% reduction relative to the baseline in PO2A, 2.3% in PO2B and 2.9% in 
PO2C). 

Table 67: Recurrent  and one-off costs and cost savings for national  public  authorities in the policy options, in 
2029, 2030, 2040 and 2050, relative to the baseline, in million EUR (2023 prices) 

PO1A 

PO1B 

PO1C 

Administrative costs 
Losses in tax 
revenues 
Additional tax 
revenues 
Net benefits (+) or 
net costs (-) 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

0.24 
918 

0.01 
919 

0.01 
830 

0.01 
182 

0.24 
1,447 

0.01 
1,448 

0.01 
1,477 

0.01 
302 

0.24 
1,866 

0.01 
1,868 

0.01 
2,411 

0.01 
485 

774 

775 

482 

33 

1,032 

1,033 

655 

26 

1,285 

1,286 

798 

15 

-145 

-145 

-348 

-149 

-415 

-415 

-822 

-276 

-581 

-582 

-1,613 

-471 

PO2A 

PO2B 

PO2C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

6.33 
908 

6.56 
907 

6.33 
976 

6.56 
1,463 

6.33 
1,756 

Administrative costs 
Losses in tax 
revenues 
Additional tax 
revenues 
Net benefits (+) or 
net costs (-) 
Source:  Ricardo  (2025),  Support  study;  PRIMES-TREMOVE  transport  model  (E3-Modelling)  and  standard  cost  model  for 
administrative costs 

6.33 
3,576 

6.33 
2,515 

6.33 
1,233 

6.33 
1,465 

6.56 
1,973 

6.33 
1,975 

6.33 
1,570 

-3,455 

-2,382 

-1,213 

-1,621 

-1,561 

1,112 

1,113 

-949 

-185 

-542 

-543 

-868 

-869 

-185 

127 

729 

728 

141 

927 

928 

139 

33 

26 

15 

Table  68:  One-off  costs  for  national  public  authorities  in  the  policy  options,  in  2029,  2030,  2040  and  2050, 
relative to the baseline, in million EUR (2023 prices) 

PO1A 

PO1B 

PO1C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

Administrative costs 

0.23 

0.00 

0.00 

0.23 

0.00 
PO2A 

0.00 
PO2B 

0.00 

0.00 

0.23 

0.00 

0.00 

0.00 
PO2C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

Administrative costs 
Source: Ricardo (2025), Support study 

0.23 

0.00 

0.00 

0.00 

0.23 

0.00 

0.00 

0.00 

0.23 

0.00 

0.00 

0.00 

5.3.  European Environment Agency (EEA) 

Table 69: Recurrent and one-off costs for  European Environment Agency in the policy options, in 2029, 2030, 
2040 and 2050, relative to the baseline, in million EUR (2023 prices) 
PO1B 
PO1A 

PO1C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

Administrative costs 

0.03 

0.03 

0.03 

0.03 

0.03 
PO2A 

0.03 
PO2B 

0.03 

0.03 

0.03 

0.03 

0.03 

0.03 
PO2C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

Administrative costs 
Source: Ricardo (2025), Support study 

0.05 

0.06 

0.06 

0.06 

0.05 

0.06 

0.06 

0.06 

0.05 

0.06 

0.06 

0.06 

Table 70: One-off costs for European Environment Agency in the policy options, in 2029, 2030, 2040 and 2050, 
relative to the baseline, in million EUR (2023 prices) 

PO1A 

PO1B 

PO1C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

Administrative costs 

0.03   

0.03   

0.03   

PO2A 

PO2B 

PO2C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

Administrative costs 
Source: Ricardo (2025), Support study 

0.05   

0.05   

115 

0.05   

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
5.4.  Citizens 

Table 71: Recurrent and one-off costs and cost savings for citizens in the policy options, in 2029, 2030, 2040 and 
2050, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs 
Capital costs 
Fuel costs 
Other operation costs 

Increase in tax expenditures 
Adjustment costs savings 
Capital costs savings 
Fuel costs savings 
Other operation costs savings 

Reduction in tax expenditures 
Net benefits (+) or net costs  (-
) 

Adjustment costs 
Capital costs 
Fuel costs 
Other operation costs 

Increase in tax expenditures 
Adjustment costs savings 
Capital costs savings 
Fuel costs savings 
Other operation costs savings 

Reduction in tax expenditures 
Net benefits (+) or net costs  (-
) 

PO1A 

PO1B 

PO1C 

2029 

2030  2040  2050 

2029 

2030  2040  2050 

2029 

2030 

2040 

2050 

389 
137 
198 
54 
304 
39 
0 
0 
39 
0 
-655 

390 
137 
199 
54 
305 
39 
0 
0 
39 
0 
-656 

189 
0 
11 
179 
8 
295 
275 
8 
12 
101 
198 

154 
0 
31 
124 
0 
66 
58 
0 
8 
9 
-79 

500 
161 
257 
82 
388 
44 
0 
0 
44 
0 
-845 

501 
162 
257 
82 
389 
44 
0 
0 
44 
0 
-846 

324 
0 
13 
310 
8 
562 
392 
159 
10 
322 
552 

199 
0 
8 
190 
0 
216 
66 
142 
9 
124 
141 

609 
192 
311 
106 
465 
47 
0 
0 
47 
0 
-1,027 

610 
192 
311 
106 
465 
47 
0 
0 
47 
0 

522 
0 
16 
506 
9 
988 
529 
452 
6 
715 
-1,028  1,172 

316 
0 
9 
307 
0 
460 
76 
376 
8 
279 
423 

PO2A 

PO2B 

PO2C 

2029 

2030  2040  2050 

2029 

2030  2040  2050 

2029 

2030 

2040 

2050 

389 
137 
198 
54 
304 
39 
0 
0 
39 
0 
-655 

390 
137 
199 
54 
305 
39 
0 
0 
39 
0 
-656 

189 
0 
11 
179 
8 
295 
275 
8 
12 
101 
198 

154 
0 
31 
124 
0 
66 
58 
0 
8 
9 
-79 

500 
161 
257 
82 
388 
44 
0 
0 
44 
0 
-845 

501 
162 
257 
82 
389 
44 
0 
0 
44 
0 
-846 

324 
0 
13 
310 
8 
562 
392 
159 
10 
322 
552 

199 
0 
8 
190 
0 
216 
66 
142 
9 
124 
141 

609 
192 
311 
106 
465 
47 
0 
0 
47 
0 
-1,027 

610 
192 
311 
106 
465 
47 
0 
0 
47 
0 

522 
0 
16 
506 
9 
988 
529 
452 
6 
715 
-1,028  1,172 

316 
0 
9 
307 
0 
460 
76 
376 
8 
279 
423 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

Table 72: One-off costs and cost savings for citizens in the policy options, in 2029, 2030, 2040 and 2050, relative 
to the baseline, in million EUR (2023 prices) 

PO1A 

PO1B 

PO1C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

137 

137 

0 

0 

161 

162 

0 

0 

192 

192 

0 

0 

0 

0 

275 

58 

0 

0 

392 

66 

0 

0 

529 

76 

-137 

-137 

275 

58 

-161 

-162 

392 

66 

-192 

-192 

529 

76 

PO2A 

PO2B 

PO2C 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

2029 

2030 

2040 

2050 

137 

137 

0 

0 

161 

162 

0 

0 

192 

192 

0 

0 

0 

0 

275 

58 

0 

0 

392 

66 

0 

0 

529 

76 

-137 

-137 

275 

58 

-161 

-162 

392 

66 

-192 

-192 

529 

76 

Adjustment costs 
(capital costs) 

Adjustment costs 
savings (capital costs 
savings) 
Net benefits (+) or 
net costs (-) 

Adjustment costs 
(capital costs) 

Adjustment costs 
savings (capital costs 
savings) 
Net benefits (+) or 
net costs (-) 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) 

116 

 
  
  
  
  
6.  SUMMARY  OF  COSTS  AND  BENEFITS  BY  POLICY  OPTION  INCLUDING  THE  SPLIT  BY  VEHICLE 

TYPE  

This section  provides  the  summary  of  the  costs  and  benefits  expressed  as  present  value  over  2029-2050 
relative to the baseline, by policy option and stakeholder group, also including the split between cars and 
vans, and lorries.  

Table 73: Summary of costs and benefits of policy options including the split by vehicle type - present value over 2029-
2050 compared to the baseline (in billion EUR, 2023 prices) 

PO1A 

PO1B 

PO1C 

PO2A 

PO2B 

PO2C 

Businesses  
Administrative costs 
Cars and vans 
Lorries 

Enforcement costs 
Cars and vans 
Lorries 

Adjustment costs 
Cars and vans 
Lorries 

Increase in tax expenditures 

Cars and vans 
Lorries 

Adjustment costs savings 

Cars and vans 
Lorries 

Reduction in tax expenditures 

Cars and vans 
Lorries 
Citizens 
Adjustment costs  
Cars and vans 

Increase in tax expenditures 

Cars and vans 

Adjustment costs savings 

Cars and vans 

Reduction in tax expenditures 

Cars and vans 
National authorities 
Administrative costs 
Losses in tax revenues 

Cars and vans 
Lorries 

Additional tax revenues 

Cars and vans 
Lorries 

0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
24.5 
10.1 
14.3 
9.7 
5.3 
4.4 
32.9 
20.9 
11.9 
17.8 
12.8 
5.0 

6.0 
6.0 
3.8 
3.8 
2.2 
2.2 
0.6 
0.6 

0.00 
18.4 
13.4 
5.0 
13.5 
9.1 
4.4 

0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
32.7 
12.1 
20.6 
12.3 
6.2 
6.0 
45.7 
29.4 
16.2 
25.6 
19.1 
6.5 

7.8 
7.8 
4.3 
4.3 
4.0 
4.0 
2.1 
2.1 

0.00 
27.7 
21.2 
6.5 
16.6 
10.5 
6.0 

0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
40.8 
13.7 
27.1 
14.3 
6.8 
7.5 
59.2 
38.9 
20.3 
34.6 
26.4 
8.2 

10.3 
10.3 
4.7 
4.7 
7.0 
7.0 
4.6 
4.6 

0.00 
39.1 
31.0 
8.2 
18.9 
11.4 
7.5 

41.36 
0.00 
41.36 
0.004 
0.00 
0.004 
36.6 
10.1 
26.5 
5.4 
5.3 
0.1 
30.7 
20.9 
9.8 
26.5 
12.8 
13.7 

6.0 
6.0 
3.8 
3.8 
2.2 
2.2 
0.6 
0.6 

0.10 
27.1 
13.4 
13.7 
9.2 
9.1 
0.1 

41.35 
0.00 
41.35 
0.004 
0.00 
0.004 
47.9 
12.1 
35.8 
6.3 
6.2 
0.1 
40.9 
29.4 
11.4 
36.3 
19.1 
17.2 

7.8 
7.8 
4.3 
4.3 
4.0 
4.0 
2.1 
2.1 

0.10 
38.4 
21.2 
17.2 
10.6 
10.5 
0.1 

41.35 
0.00 
41.35 
0.004 
0.00 
0.004 
61.7 
13.7 
48.0 
6.8 
6.8 
0.0 
53.5 
38.9 
14.6 
47.8 
26.4 
21.5 

10.3 
10.3 
4.7 
4.7 
7.0 
7.0 
4.6 
4.6 

0.10 
52.4 
31.0 
21.5 
11.5 
11.4 
0.0 

European Environmental Agency 
Administrative costs  
External costs savings 
External costs related to CO2 emissions, air pollution 
emissions and noise 
Cars and vans 
Lorries 
Total costs 
Total benefits 
Net benefits (+) or net costs (-) 

0.0005 

0.0005 

0.0005 

0.0009 

0.0009 

0.0009 

1.9 

4.3 

7.9 

8.4 

12.9 

18.9 

1.7 
0.1 
62.3 
68.8 
6.5 

4.2 
0.1 
84.8 
98.3 
13.6 

7.7 
0.2 
109.2 
132.2 
23.0 

1.7 
6.6 
120.3 
77.6 
-42.7 

4.2 
8.7 
146.1 
106.8 
-39.4 

7.7 
11.1 
177.4 
143.2 
-34.2 

117 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Benefits to costs ratio 
0.81 
Source: Ricardo  (2025), Support  study;  PRIMES-TREMOVE  transport  model (E3-Modelling)  and  standard cost  model  for  the 
administrative and enforcement costs. 

0.73 

0.65 

1.21 

1.16 

1.10 

PO1A 

PO1B 

PO1C 

PO2A 

PO2B 

PO2C 

7.  SUMMARY  OF  COSTS  AND  COST  SAVINGS  BY  POLICY  OPTION  AND  STAKEHOLDER  GROUP  BY 

MEMBER STATE FOR 2030 AND 2040  

This section presents the costs and costs savings by policy option for 2030 and 2040 for businesses, citizens 
and national public authorities. The net benefits or costs for businesses and citizens relative to the baseline, 
are also presented per vehicle and as share of GDP, and the net benefits or net costs relative to the baseline 
for national public authorities are also presented as share of GDP. The preferred policy option (PO1) does 
not show disproportionate net costs per vehicle or as share of GDP, relative to the baseline, for any Member 
State or stakeholder group.  

118 

 
  
 
 
 
7.1.  PO1A: Impacts on costs and costs savings for businesses in 2030 and 2040 relative to the baseline 

Table 74: Recurrent costs and cost savings for businesses in PO1A in 2030, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

119 
102 
2 
3 
0 
24 
62 
0 
34 
306 
466 
1 
9 
11 
48 
1 
5 
20 
0 
127 
9 
3 
24 
8 
4 
12 
68 
1,466 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

50 
35 
2 
5 
0 
24 
41 
1 
14 
153 
558 
1 
16 
7 
50 
5 
4 
9 
0 
71 
10 
3 
29 
5 
3 
8 
48 
1,151 

37 
24 
0 
0 
0 
5 
12 
1 
7 
82 
227 
0 
3 
3 
8 
1 
1 
6 
0 
31 
1 
1 
5 
2 
0 
2 
10 
470 

76 
80 
0 
2 
0 
1 
29 
1 
23 
197 
339 
0 
1 
8 
11 
1 
1 
18 
0 
94 
1 
1 
4 
3 
0 
1 
28 
919 

119 

107 
122 
0 
-1 
0 
-4 
38 
-1 
36 
268 
19 
0 
-8 
10 
2 
-4 
1 
23 
0 
119 
-2 
0 
-6 
5 
0 
3 
37 
764 

53 
51 
0 
-1 
-1 
-2 
37 
-4 
35 
21 
1 
0 
-5 
14 
0 
-13 
2 
153 
2 
40 
0 
0 
-2 
4 
0 
0 
22 
9 

0.02% 
0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.01% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.03% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 

 
  
Table 75: Recurrent costs and cost savings for businesses in PO1A in 2040, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

91 
-20 
8 
58 
-2 
99 
34 
18 
37 
255 
423 
16 
43 
10 
187 
48 
18 
13 
2 
204 
72 
-8 
48 
23 
26 
67 
-3 
1,767 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

13 
38 
8 
0 
0 
40 
46 
1 
29 
265 
423 
3 
19 
8 
133 
2 
5 
4 
0 
150 
6 
4 
46 
11 
11 
62 
70 
1,396 

3 
22 
3 
2 
4 
13 
10 
0 
3 
20 
165 
1 
13 
7 
72 
3 
2 
1 
0 
41 
6 
2 
18 
5 
4 
29 
24 
474 

49 
43 
3 
1 
2 
10 
26 
0 
13 
78 
269 
1 
8 
9 
38 
1 
4 
0 
0 
107 
16 
-1 
23 
3 
3 
8 
14 
729 

125 
-36 
0 
57 
-4 
57 
5 
17 
18 
48 
103 
13 
19 
4 
20 
44 
14 
8 
3 
120 
76 
-16 
6 
9 
14 
-17 
-83 
626 

59 
-15 
0 
88 
-37 
23 
4 
61 
16 
3 
6 
6 
12 
6 
2 
112 
31 
46 
30 
40 
8 
-7 
2 
8 
45 
-2 
-43 
7 

0.02% 
0.00% 
0.00% 
0.05% 
-0.01% 
0.01% 
0.00% 
0.03% 
0.01% 
0.00% 
0.00% 
0.01% 
0.01% 
0.00% 
0.00% 
0.08% 
0.02% 
0.01% 
0.01% 
0.01% 
0.01% 
-0.01% 
0.00% 
0.01% 
0.02% 
0.00% 
-0.01% 
0.00% 

120 

 
  
7.2.  PO1A: Impacts on costs and costs savings for citizens in 2030 and 2040 relative to the baseline 

Table 76: Recurrent costs and cost savings for citizens in PO1A in 2030, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

1 
1 
0 
0 
0 
0 
2 
0 
2 
11 
13 
0 
0 
1 
0 
0 
0 
1 
0 
3 
4 
0 
0 
0 
0 
0 
0 
39 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

30 
15 
0 
0 
0 
16 
9 
0 
10 
84 
205 
0 
-1 
0 
0 
2 
0 
3 
0 
18 
-1 
0 
0 
-1 
0 
0 
2 
390 

23 
14 
0 
0 
0 
8 
6 
0 
10 
72 
153 
0 
0 
0 
0 
0 
0 
4 
0 
13 
0 
0 
0 
0 
0 
0 
2 
305 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

-52 
-28 
0 
0 
0 
-24 
-13 
0 
-18 
-145 
-345 
0 
1 
0 
0 
-2 
0 
-5 
0 
-28 
5 
0 
1 
0 
0 
1 
-4 
-656 

-13 
-6 
0 
0 
0 
-5 
-6 
0 
-6 
-4 
-9 
0 
0 
0 
0 
-4 
0 
-13 
0 
-4 
0 
0 
0 
0 
0 
0 
-1 
-3 

-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

121 

 
  
Table 77: Recurrent costs and cost savings for citizens in PO1A in 2040, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

104 
102 
-4 
13 
-3 
4 
10 
2 
-7 
48 
-163 
-4 
-7 
3 
8 
16 
1 
-1 
2 
138 
32 
2 
1 
-3 
4 
-8 
6 
295 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

15 
19 
1 
-3 
0 
2 
9 
-1 
-4 
23 
64 
1 
-1 
0 
-2 
-4 
0 
1 
-1 
62 
4 
0 
-3 
-2 
-1 
5 
5 
189 

0 
0 
0 
0 
2 
0 
0 
0 
0 
1 
2 
0 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
8 

70 
77 
1 
-3 
0 
0 
7 
0 
-14 
25 
-205 
0 
-8 
3 
5 
0 
0 
-3 
0 
142 
15 
0 
-5 
-5 
0 
-8 
8 
101 

159 
160 
-5 
13 
-5 
2 
9 
3 
-18 
48 
-434 
-5 
-14 
5 
14 
19 
1 
-6 
2 
217 
43 
2 
-1 
-6 
5 
-22 
10 
198 

32 
27 
-2 
13 
-7 
1 
4 
4 
-6 
1 
-10 
-1 
-4 
3 
0 
29 
1 
-11 
6 
31 
3 
1 
0 
-3 
7 
-1 
2 
1 

0.03% 
0.02% 
0.00% 
0.01% 
-0.01% 
0.00% 
0.00% 
0.01% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.04% 
0.00% 
-0.01% 
0.01% 
0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 

122 

 
  
7.3.  PO1A: Impacts on costs and costs savings for national public authorities in 2030 and 2040 relative to the baseline 

Table 78: Recurrent costs and cost savings for national public authorities in PO1A in 2030, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net costs   (-) in 
EUR million 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

Additional tax revenues (EUR 
million) 

million) 

Net benefits (+) or net costs   (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

76 
80 
0 
2 
0 
1 
29 
1 
23 
197 
339 
0 
1 
8 
11 
1 
1 
18 
0 
94 
1 
1 
4 
3 
0 
1 
28 
919 

60 
38 
0 
0 
0 
13 
19 
1 
17 
154 
380 
0 
3 
3 
8 
1 
1 
9 
0 
45 
1 
1 
5 
2 
0 
2 
12 
775 

-16 
-42 
0 
-2 
0 
12 
-10 
0 
-6 
-44 
41 
0 
2 
-5 
-3 
0 
0 
-9 
0 
-49 
1 
0 
1 
0 
0 
0 
-17 
-145 

0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

123 

 
  
 
Table 79: Recurrent costs and cost savings for national public authorities in PO1A in 2040, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net costs   (-) in 
EUR million 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

Additional tax revenues (EUR 
million) 

million) 

Net benefits (+) or net costs   (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

119 
120 
4 
-2 
2 
10 
34 
0 
-1 
102 
63 
1 
0 
12 
43 
0 
4 
-3 
0 
249 
31 
-1 
17 
-2 
3 
0 
22 
830 

3 
22 
3 
2 
5 
13 
10 
0 
3 
21 
167 
1 
13 
7 
73 
3 
2 
1 
0 
42 
6 
2 
18 
5 
4 
30 
24 
482 

-116 
-99 
-1 
4 
3 
3 
-24 
0 
4 
-81 
104 
0 
13 
-5 
30 
2 
-2 
4 
0 
-208 
-25 
4 
1 
7 
1 
30 
2 
-348 

-0.02% 
-0.01% 
0.00% 
0.00% 
0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

124 

 
  
 
 
7.4.  PO1B: Impacts on costs and costs savings for businesses in 2030 and 2040 relative to the baseline 

Table 80: Recurrent costs and cost savings for businesses in PO1B in 2030, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net 
costs (-) in EUR million 

Adjustment costs savings 
(EUR million) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

170 
149 
3 
4 
0 
32 
90 
0 
50 
490 
846 
2 
13 
18 
76 
0 
9 
26 
0 
180 
16 
7 
30 
14 
5 
34 
104 
2,370 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

62 
45 
3 
8 
0 
34 
57 
2 
19 
232 
797 
2 
22 
10 
78 
8 
8 
12 
0 
98 
17 
7 
37 
9 
5 
27 
72 
1,670 

43 
29 
1 
1 
0 
6 
16 
1 
10 
118 
309 
0 
3 
4 
12 
1 
2 
8 
0 
42 
3 
3 
7 
4 
1 
6 
15 
645 

108 
117 
1 
4 
0 
2 
42 
1 
35 
295 
577 
0 
1 
13 
26 
2 
3 
24 
0 
133 
2 
3 
6 
5 
0 
4 
46 
1,448 

125 

172 
192 
0 
-2 
0 
-6 
59 
-2 
56 
435 
317 
0 
-10 
17 
11 
-7 
2 
30 
0 
173 
-1 
0 
-9 
5 
0 
6 
63 
1,504 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

86 
79 
0 
-2 
1 
-3 
58 
-7 
54 
34 
21 
0 
-6 
26 
1 
-22 
5 
202 
2 
58 
0 
0 
-3 
5 
-1 
1 
37 
18 

0.03% 
0.03% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.02% 
0.01% 
0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.02% 
0.00% 
0.03% 
0.00% 
0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.01% 

 
  
Table 81: Recurrent costs and cost savings for businesses in PO1B in 2040, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net 
costs (-) in EUR million 

Adjustment costs savings 
(EUR million) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

111 
3 
10 
59 
-1 
109 
51 
18 
49 
434 
612 
18 
51 
15 
246 
48 
23 
14 
2 
248 
95 
-7 
67 
26 
30 
110 
7 
2,447 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

13 
55 
11 
2 
0 
59 
53 
1 
37 
348 
567 
8 
31 
11 
216 
4 
10 
4 
0 
174 
30 
6 
68 
17 
16 
112 
85 
1,938 

3 
29 
3 
3 
4 
19 
14 
0 
3 
38 
213 
2 
16 
10 
96 
3 
5 
1 
0 
54 
14 
2 
25 
7 
6 
44 
31 
646 

67 
66 
5 
2 
2 
16 
39 
1 
17 
189 
395 
2 
12 
19 
57 
1 
7 
1 
1 
146 
22 
0 
33 
5 
5 
22 
24 
1,155 

163 
-15 
0 
56 
-4 
47 
23 
17 
25 
238 
227 
10 
16 
13 
-9 
42 
15 
9 
3 
166 
73 
-16 
8 
7 
12 
-24 
-84 
1,018 

126 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

77 
-6 
0 
86 
-36 
19 
22 
61 
22 
16 
14 
5 
10 
19 
-1 
109 
32 
51 
31 
55 
8 
-7 
3 
6 
40 
-3 
-44 
11 

0.03% 
0.00% 
0.00% 
0.05% 
-0.01% 
0.01% 
0.01% 
0.03% 
0.01% 
0.01% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.08% 
0.02% 
0.01% 
0.01% 
0.01% 
0.01% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
-0.01% 
0.00% 

 
  
7.5.  PO1B: Impacts on costs and costs savings for citizens in 2030 and 2040 relative to the baseline 

Table 82: Recurrent costs and cost savings for citizens in PO1B in 2030, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

1 
1 
0 
0 
0 
0 
2 
0 
2 
13 
16 
0 
0 
0 
0 
-1 
0 
1 
0 
3 
4 
0 
0 
0 
0 
0 
0 
44 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

36 
18 
0 
0 
0 
16 
11 
0 
14 
115 
262 
0 
-1 
0 
1 
3 
0 
3 
0 
20 
-1 
0 
0 
0 
0 
0 
3 
501 

27 
16 
0 
0 
0 
8 
8 
0 
14 
96 
195 
0 
0 
1 
1 
0 
0 
4 
0 
15 
0 
0 
0 
1 
0 
0 
2 
389 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

-62 
-33 
0 
-1 
0 
-24 
-17 
0 
-25 
-198 
-441 
0 
1 
-1 
-2 
-4 
0 
-7 
0 
-32 
5 
0 
1 
-1 
0 
1 
-6 
-846 

-15 
-7 
0 
-1 
0 
-5 
-8 
-1 
-8 
-5 
-12 
0 
0 
-1 
0 
-8 
0 
-17 
-1 
-5 
0 
0 
0 
-1 
0 
0 
-2 
-4 

-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.01% 
-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

127 

 
  
Table 83: Recurrent costs and cost savings for citizens in PO1B in 2040, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

149 
150 
-4 
13 
-3 
4 
27 
2 
-8 
154 
-179 
-4 
-7 
8 
13 
14 
1 
1 
1 
176 
32 
2 
1 
-4 
4 
-7 
28 
562 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

21 
29 
1 
-2 
0 
2 
14 
0 
-3 
59 
111 
1 
-1 
1 
1 
-3 
0 
1 
0 
81 
4 
0 
-3 
-2 
-1 
5 
9 
324 

0 
0 
0 
0 
2 
0 
0 
0 
0 
1 
2 
0 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
8 

103 
115 
1 
-3 
0 
0 
20 
0 
-16 
100 
-216 
0 
-8 
8 
11 
0 
0 
-2 
0 
186 
15 
0 
-5 
-5 
0 
-8 
27 
322 

231 
235 
-5 
12 
-5 
2 
33 
2 
-21 
194 
-508 
-5 
-14 
15 
21 
17 
2 
-2 
0 
281 
43 
2 
-1 
-7 
5 
-22 
45 
552 

46 
40 
-2 
12 
-7 
1 
15 
4 
-7 
5 
-12 
-1 
-4 
8 
1 
25 
2 
-4 
1 
40 
3 
1 
0 
-4 
7 
-1 
11 
3 

0.04% 
0.03% 
0.00% 
0.01% 
-0.01% 
0.00% 
0.01% 
0.00% 
-0.01% 
0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.00% 
0.00% 
0.00% 
0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.01% 
0.00% 

128 

 
  
7.6.  PO1B: Impacts on costs and costs savings for national public authorities in 2030 and 2040 relative to the baseline 

Table 84: Recurrent costs and cost savings for national public authorities in PO1B in 2030, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net costs   (-) in 
EUR million 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

Additional tax revenues (EUR 
million) 

million) 

Net benefits (+) or net costs   (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

108 
117 
1 
4 
0 
2 
42 
1 
35 
295 
577 
0 
1 
13 
26 
2 
3 
24 
0 
133 
2 
3 
6 
5 
0 
4 
46 
1,448 

70 
44 
0 
2 
0 
14 
24 
1 
24 
214 
504 
0 
3 
5 
14 
2 
2 
12 
0 
57 
3 
3 
7 
5 
1 
6 
17 
1,033 

-38 
-72 
0 
-2 
0 
13 
-18 
-1 
-12 
-81 
-73 
0 
2 
-8 
-12 
0 
-1 
-12 
0 
-75 
1 
0 
1 
1 
0 
2 
-28 
-415 

-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

129 

 
  
 
Table 85: Recurrent costs and cost savings for national public authorities in PO1B in 2040, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net costs   (-) in 
EUR million 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

Additional tax revenues (EUR 
million) 

million) 

Net benefits (+) or net costs   (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

170 
181 
6 
-1 
2 
16 
59 
1 
1 
289 
179 
2 
4 
27 
68 
1 
8 
-2 
0 
332 
38 
0 
28 
0 
5 
14 
51 
1,477 

3 
29 
3 
3 
6 
19 
14 
0 
3 
39 
215 
2 
16 
10 
98 
3 
5 
1 
0 
55 
14 
2 
25 
8 
6 
45 
31 
655 

-167 
-152 
-2 
4 
3 
3 
-45 
-1 
2 
-250 
35 
0 
12 
-17 
30 
2 
-3 
3 
-1 
-277 
-23 
3 
-3 
8 
1 
31 
-20 
-822 

-0.03% 
-0.02% 
0.00% 
0.00% 
0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

130 

 
  
 
 
7.7.  PO1C: Impacts on costs and costs savings for businesses in 2030 and 2040 relative to the baseline 

Table 86: Recurrent costs and cost savings for businesses in PO1C in 2030, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

209 
184 
4 
5 
0 
41 
112 
0 
62 
650 
1,183 
3 
17 
26 
103 
1 
13 
34 
0 
227 
30 
13 
35 
17 
7 
53 
147 
3,177 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

68 
58 
4 
10 
0 
44 
70 
3 
24 
320 
1,049 
4 
27 
13 
107 
10 
12 
16 
0 
129 
28 
14 
46 
12 
8 
43 
93 
2,213 

45 
34 
1 
2 
0 
7 
18 
1 
13 
154 
396 
0 
4 
5 
17 
2 
3 
10 
0 
54 
7 
6 
8 
5 
1 
9 
19 
821 

134 
146 
1 
5 
0 
3 
52 
2 
43 
371 
753 
1 
1 
19 
39 
2 
4 
28 
0 
164 
7 
6 
7 
6 
1 
6 
69 
1,868 

131 

229 
237 
-1 
-3 
0 
-9 
75 
-2 
68 
547 
492 
0 
-12 
26 
18 
-9 
2 
37 
0 
209 
2 
0 
-12 
5 
-1 
7 
103 
2,011 

114 
98 
-1 
-4 
1 
-4 
74 
-9 
65 
42 
32 
0 
-8 
39 
2 
-27 
5 
243 
3 
70 
0 
0 
-4 
5 
-1 
1 
61 
25 

0.04% 
0.04% 
0.00% 
0.00% 
0.00% 
0.00% 
0.02% 
0.00% 
0.02% 
0.02% 
0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.02% 
0.00% 
0.04% 
0.00% 
0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.02% 
0.01% 

 
  
Table 87: Recurrent costs and cost savings for businesses in PO1C in 2040, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

132 
31 
12 
60 
-1 
118 
69 
18 
65 
595 
846 
20 
58 
25 
299 
48 
25 
14 
2 
298 
123 
-6 
72 
31 
33 
159 
32 
3,177 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

7 
76 
14 
5 
1 
81 
59 
2 
41 
399 
721 
14 
41 
18 
304 
6 
13 
4 
0 
201 
62 
8 
81 
24 
20 
166 
105 
2,471 

0 
36 
4 
5 
4 
25 
18 
0 
3 
26 
266 
3 
19 
13 
122 
4 
5 
1 
-1 
68 
24 
2 
24 
10 
7 
60 
40 
789 

89 
92 
7 
3 
2 
23 
54 
1 
30 
316 
567 
3 
16 
31 
78 
2 
10 
1 
1 
191 
33 
1 
43 
7 
6 
39 
46 
1,696 

213 
11 
1 
54 
-4 
35 
46 
17 
51 
487 
426 
7 
15 
25 
-48 
41 
17 
10 
3 
219 
70 
-14 
10 
4 
11 
-28 
-67 
1,613 

101 
5 
1 
83 
-35 
14 
44 
61 
43 
32 
26 
3 
9 
36 
-4 
106 
35 
55 
34 
73 
7 
-6 
3 
4 
36 
-3 
-35 
18 

0.04% 
0.00% 
0.00% 
0.05% 
-0.01% 
0.01% 
0.01% 
0.03% 
0.02% 
0.01% 
0.01% 
0.00% 
0.01% 
0.00% 
0.00% 
0.08% 
0.02% 
0.01% 
0.01% 
0.02% 
0.01% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
-0.01% 
0.01% 

132 

 
  
7.8.  PO1C: Impacts on costs and costs savings for citizens in 2030 and 2040 relative to the baseline 

Table 88: Recurrent costs and cost savings for citizens in PO1C in 2030, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0 
1 
0 
0 
0 
0 
2 
0 
3 
15 
17 
0 
0 
0 
0 
-1 
0 
1 
0 
3 
5 
0 
0 
0 
0 
0 
0 
47 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

38 
20 
0 
0 
0 
16 
12 
0 
17 
145 
325 
0 
-1 
1 
1 
4 
0 
4 
0 
22 
-1 
0 
0 
1 
0 
0 
5 
610 

28 
17 
0 
1 
0 
8 
9 
0 
17 
118 
236 
0 
0 
2 
3 
0 
0 
5 
0 
17 
1 
0 
0 
2 
0 
0 
4 
465 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

-65 
-37 
0 
-1 
0 
-24 
-19 
-1 
-31 
-248 
-544 
0 
1 
-2 
-3 
-5 
0 
-9 
-1 
-36 
5 
0 
1 
-3 
0 
1 
-9 
-1,028 

-16 
-8 
0 
-1 
0 
-5 
-9 
-1 
-10 
-6 
-15 
0 
0 
-1 
0 
-9 
0 
-21 
-2 
-6 
0 
0 
0 
-1 
0 
0 
-3 
-5 

-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.01% 
-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 

133 

 
  
Table 89: Recurrent costs and cost savings for citizens in PO1C in 2040, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

197 
194 
-5 
12 
-2 
4 
48 
2 
1 
236 
-61 
-4 
-7 
15 
19 
13 
1 
8 
-1 
215 
32 
2 
1 
-4 
4 
-8 
75 
988 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

29 
43 
1 
-2 
1 
2 
27 
0 
2 
76 
215 
1 
-1 
3 
4 
-3 
0 
0 
1 
101 
5 
-1 
-3 
-2 
-1 
5 
19 
522 

0 
0 
0 
0 
2 
0 
0 
0 
0 
2 
2 
0 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
9 

139 
154 
1 
-3 
0 
0 
34 
0 
-8 
168 
-83 
0 
-8 
14 
16 
0 
1 
-2 
0 
228 
15 
0 
-5 
-6 
0 
-8 
70 
715 

306 
304 
-5 
12 
-5 
2 
56 
2 
-9 
326 
-360 
-5 
-14 
26 
29 
16 
2 
6 
-1 
341 
42 
2 
-1 
-8 
5 
-21 
125 
1,172 

61 
52 
-2 
12 
-7 
1 
25 
3 
-3 
8 
-8 
-1 
-4 
15 
1 
24 
2 
11 
-3 
49 
3 
1 
0 
-5 
7 
-1 
31 
5 

0.05% 
0.04% 
0.00% 
0.01% 
-0.01% 
0.00% 
0.01% 
0.00% 
0.00% 
0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.00% 
0.01% 
0.00% 
0.03% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.01% 
0.00% 
0.02% 
0.01% 

134 

 
  
7.9.  PO1C: Impacts on costs and costs savings for national public authorities in 2030 and 2040 relative to the baseline 

Table 90: Recurrent costs and cost savings for national public authorities in PO1C in 2030, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net costs   (-) in 
EUR million 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

Additional tax revenues (EUR 
million) 

million) 

Net benefits (+) or net costs   (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

134 
146 
1 
5 
0 
3 
52 
2 
43 
371 
753 
1 
1 
19 
39 
2 
4 
28 
0 
164 
7 
6 
7 
6 
1 
6 
69 
1,868 

73 
52 
1 
3 
0 
15 
26 
1 
30 
271 
632 
0 
4 
7 
19 
2 
3 
15 
0 
71 
7 
6 
8 
7 
1 
9 
23 
1,286 

-60 
-94 
0 
-2 
0 
13 
-26 
-1 
-14 
-99 
-121 
0 
2 
-11 
-19 
0 
-1 
-13 
0 
-94 
1 
0 
1 
1 
0 
3 
-46 
-582 

-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

135 

 
  
 
Table 91: Recurrent costs and cost savings for national public authorities in PO1C in 2040, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net costs   (-) in 
EUR million 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

Additional tax revenues (EUR 
million) 

million) 

Net benefits (+) or net costs   (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.001 
0.001 
0.000 
0.000 
0.000 
0.000 
0.001 
0.000 
0.000 
0.001 
0.001 
0.000 
0.000 
0.001 
0.000 
0.000 
0.000 
0.001 
0.000 
0.001 
0.000 
0.000 
0.000 
0.000 
0.000 
0.000 
0.001 
0.010 

228 
246 
8 
1 
2 
23 
88 
1 
22 
484 
484 
3 
8 
45 
94 
2 
11 
-1 
1 
419 
48 
1 
37 
2 
6 
31 
116 
2,411 

0 
36 
4 
5 
6 
25 
18 
0 
3 
28 
268 
3 
19 
13 
123 
4 
5 
1 
-1 
68 
24 
2 
24 
10 
7 
61 
40 
798 

-228 
-210 
-4 
4 
3 
2 
-70 
-1 
-19 
-456 
-216 
0 
11 
-32 
29 
2 
-6 
2 
-1 
-350 
-23 
1 
-13 
8 
1 
29 
-76 
-1,613 

-0.04% 
-0.03% 
0.00% 
0.00% 
0.01% 
0.00% 
-0.02% 
0.00% 
-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.03% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
-0.01% 
-0.01% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

136 

 
  
 
 
7.10. PO2A: Impacts on costs and costs savings for businesses in 2030 and 2040 relative to the baseline 

Table 92: Recurrent costs and cost savings for businesses in PO2A in 2030, relative to the baseline, in million EUR (2023 prices) 

Administrative 
costs (EUR 
million) 

Enforcement costs 
(EUR million) 

Adjustment costs 
(EUR million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs 
savings (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or 
net costs (-) in 
EUR million 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or 
net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

45 
106 
10 
11 
7 
50 
32 
6 
65 
366 
595 
42 
18 
23 
330 
6 
11 
4 
3 
86 
175 
11 
36 
20 
9 
234 
70 
2,369 

0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

81 
116 
7 
19 
0 
95 
36 
3 
9 
129 
728 
0 
4 
10 
1 
16 
10 
8 
0 
143 
10 
2 
105 
22 
24 
-1 
23 
1,600 

38 
15 
-1 
1 
0 
3 
11 
0 
7 
79 
227 
0 
2 
0 
1 
1 
1 
7 
0 
31 
1 
1 
-7 
1 
2 
0 
4 
424 

130 
130 
-1 
1 
0 
17 
41 
0 
29 
282 
279 
0 
-1 
7 
4 
-2 
2 
20 
0 
105 
5 
2 
-11 
8 
8 
4 
20 
1,078 

83 
119 
3 
1 
0 
8 
22 
1 
22 
195 
295 
0 
0 
8 
5 
2 
1 
21 
0 
88 
0 
1 
7 
5 
1 
0 
18 
908 

48 
12 
-13 
-29 
-7 
-124 
-16 
-8 
-29 
-98 
-976 
-41 
-25 
-18 
-324 
-22 
-17 
22 
-3 
-68 
-181 
-12 
-138 
-30 
-26 
-229 
-58 
-2,409 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative and enforcement costs 

137 

24 
5 
-11 
-41 
-70 
-57 
-15 
-34 
-27 
-8 
-64 
-21 
-16 
-27 
-33 
-67 
-39 
144 
-37 
-23 
-21 
-5 
-47 
-28 
-67 
-30 
-34 
-29 

0.01% 
0.00% 
-0.01% 
-0.03% 
-0.02% 
-0.04% 
0.00% 
-0.02% 
-0.01% 
0.00% 
-0.02% 
-0.02% 
-0.01% 
0.00% 
-0.01% 
-0.05% 
-0.02% 
0.02% 
-0.01% 
-0.01% 
-0.02% 
0.00% 
-0.04% 
-0.02% 
-0.03% 
-0.01% 
-0.01% 
-0.01% 

 
  
Table 93: Recurrent costs and cost savings for businesses in PO2A in 2040, relative to the baseline, in million EUR (2023 prices) 

Administrative 
costs (EUR 
million) 

Enforcement costs 
(EUR million) 

Adjustment costs 
(EUR million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs 
savings (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or 
net costs (-) in 
EUR million 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or 
net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

49 
115 
12 
12 
7 
57 
34 
6 
59 
390 
667 
41 
21 
25 
392 
6 
14 
4 
3 
103 
157 
10 
39 
22 
11 
220 
77 
2,550 

0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

33 
135 
21 
36 
6 
112 
34 
11 
99 
337 
582 
60 
11 
-3 
282 
14 
5 
-2 
11 
223 
101 
2 
118 
24 
17 
114 
15 
2,397 

1 
0 
1 
0 
3 
0 
-1 
0 
1 
18 
25 
0 
7 
0 
35 
1 
0 
1 
0 
12 
1 
2 
5 
2 
0 
21 
0 
133 

102 
-27 
5 
57 
-3 
95 
19 
19 
4 
288 
329 
4 
39 
6 
140 
47 
14 
13 
1 
196 
66 
-10 
28 
19 
25 
92 
-39 
1,527 

65 
102 
28 
10 
5 
51 
17 
6 
86 
115 
451 
37 
22 
12 
45 
10 
18 
5 
8 
139 
97 
7 
145 
10 
11 
140 
11 
1,655 

84 
-174 
0 
19 
-15 
-22 
-31 
7 
-69 
-342 
-494 
-60 
21 
-3 
-524 
36 
14 
16 
-5 
-2 
-95 
-16 
11 
-19 
7 
-122 
-119 
-1,898 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative and enforcement costs 

40 
-70 
0 
29 
-149 
-9 
-29 
27 
-60 
-23 
-30 
-27 
13 
-4 
-48 
93 
29 
87 
-53 
-1 
-10 
-7 
4 
-16 
23 
-15 
-61 
-21 

0.01% 
-0.02% 
0.00% 
0.02% 
-0.04% 
-0.01% 
-0.01% 
0.01% 
-0.02% 
-0.01% 
-0.01% 
-0.02% 
0.01% 
0.00% 
-0.02% 
0.07% 
0.01% 
0.01% 
-0.01% 
0.00% 
-0.01% 
-0.01% 
0.00% 
-0.01% 
0.01% 
-0.01% 
-0.02% 
-0.01% 

138 

 
  
7.11. PO2A: Impacts on costs and costs savings for citizens in 2030 and 2040 relative to the baseline 

Table 94: Recurrent costs and cost savings for citizens in PO2A in 2030, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

1 
1 
0 
0 
0 
0 
2 
0 
2 
11 
13 
0 
0 
1 
0 
0 
0 
1 
0 
3 
4 
0 
0 
0 
0 
0 
0 
39 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

23 
14 
0 
0 
0 
8 
6 
0 
10 
72 
153 
0 
0 
0 
0 
0 
0 
4 
0 
13 
0 
0 
0 
0 
0 
0 
2 
305 

30 
15 
0 
0 
0 
16 
9 
0 
10 
84 
205 
0 
-1 
0 
0 
2 
0 
3 
0 
18 
-1 
0 
0 
-1 
0 
0 
2 
390 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

-52 
-28 
0 
0 
0 
-24 
-13 
0 
-18 
-145 
-345 
0 
1 
0 
0 
-2 
0 
-5 
0 
-28 
5 
0 
1 
0 
0 
1 
-4 
-656 

-13 
-6 
0 
0 
0 
-5 
-6 
0 
-6 
-4 
-9 
0 
0 
0 
0 
-4 
0 
-13 
0 
-4 
0 
0 
0 
0 
0 
0 
-1 
-3 

-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

139 

 
  
Table 95: Recurrent costs and cost savings for citizens in PO2A in 2040, relative to the baseline, in million EUR (2023 prices) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs savings 
(EUR million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) in EUR million 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

104 
102 
-4 
13 
-3 
4 
10 
2 
-7 
48 
-163 
-4 
-7 
3 
8 
16 
1 
-1 
2 
138 
32 
2 
1 
-3 
4 
-8 
6 
295 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

15 
19 
1 
-3 
0 
2 
9 
-1 
-4 
23 
64 
1 
-1 
0 
-2 
-4 
0 
1 
-1 
62 
4 
0 
-3 
-2 
-1 
5 
5 
189 

0 
0 
0 
0 
2 
0 
0 
0 
0 
1 
2 
0 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
8 

70 
77 
1 
-3 
0 
0 
7 
0 
-14 
25 
-205 
0 
-8 
3 
5 
0 
0 
-3 
0 
142 
15 
0 
-5 
-5 
0 
-8 
8 
101 

159 
160 
-5 
13 
-5 
2 
9 
3 
-18 
48 
-434 
-5 
-14 
5 
14 
19 
1 
-6 
2 
217 
43 
2 
-1 
-6 
5 
-22 
10 
198 

32 
27 
-2 
13 
-7 
1 
4 
4 
-6 
1 
-10 
-1 
-4 
3 
0 
29 
1 
-11 
6 
31 
3 
1 
0 
-3 
7 
-1 
2 
1 

0.03% 
0.02% 
0.00% 
0.01% 
-0.01% 
0.00% 
0.00% 
0.01% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.04% 
0.00% 
-0.01% 
0.01% 
0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.00% 
0.00% 

140 

 
  
7.12. PO2A: Impacts on costs and costs savings for national public authorities in 2030 and 2040 relative to the baseline 

Table 96: Recurrent costs and cost savings for national public authorities in PO2A in 2030, relative to the baseline, in million EUR (2023 prices) 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

million) 

Additional tax revenues (EUR 
million) 

Net benefits (+) or net costs (-) in 
EUR million 

Net benefits (+) or net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

83 
119 
3 
1 
0 
8 
22 
1 
22 
195 
295 
0 
0 
8 
5 
2 
1 
21 
0 
88 
0 
1 
7 
5 
1 
0 
18 
908 

61 
29 
-1 
1 
0 
11 
17 
1 
17 
151 
380 
0 
2 
1 
1 
1 
0 
10 
0 
45 
1 
1 
-7 
2 
2 
0 
5 
729 

-22 
-91 
-5 
0 
0 
4 
-5 
-1 
-6 
-45 
82 
0 
2 
-7 
-4 
-2 
-1 
-10 
0 
-43 
0 
0 
-15 
-4 
1 
0 
-13 
-185 

0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

141 

 
 
  
Table 97: Recurrent costs and cost savings for national public authorities in PO2A in 2040, relative to the baseline, in million EUR (2023 prices) 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

million) 

Additional tax revenues (EUR 
million) 

Net benefits (+) or net costs (-) in 
EUR million 

Net benefits (+) or net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

134 
179 
29 
7 
5 
51 
24 
6 
71 
139 
246 
37 
13 
15 
50 
10 
19 
2 
7 
282 
113 
7 
140 
6 
11 
132 
20 
1,756 

1 
0 
1 
0 
5 
0 
-1 
0 
1 
19 
27 
0 
7 
0 
36 
1 
0 
1 
0 
12 
1 
2 
5 
2 
0 
22 
0 
141 

-133 
-179 
-27 
-7 
0 
-52 
-26 
-6 
-70 
-121 
-222 
-37 
-7 
-16 
-14 
-8 
-19 
-1 
-7 
-270 
-112 
-5 
-135 
-4 
-11 
-111 
-20 
-1,621 

-0.02% 
-0.02% 
-0.02% 
-0.01% 
0.00% 
-0.01% 
-0.01% 
-0.01% 
-0.02% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
-0.02% 
-0.02% 
0.00% 
-0.02% 
-0.02% 
-0.01% 
0.00% 
-0.03% 
0.00% 
-0.01% 
-0.01% 
0.00% 
-0.01% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

142 

 
  
 
 
7.13. PO2B: Impacts on costs and costs savings for businesses in 2030 and 2040 relative to the baseline 

Table 98: Recurrent costs and cost savings for businesses in PO2B in 2030, relative to the baseline, in million EUR (2023 prices) 

Administrative 
costs (EUR 
million) 

Enforcement costs 
(EUR million) 

Adjustment costs 
(EUR million) 

Increase in tax 
expenditures 
(EUR million) 

Adjustment costs 
savings (EUR 
million) 

Reduction in tax 
expenditures 
(EUR million) 

Net benefits (+) or 
net costs (-) in 
EUR million 

Net benefits (+) or net costs 
(-) divided by corporate 
vehicle stock (in EUR) 

Net benefits (+) or 
net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

45 
106 
10 
11 
7 
50 
32 
6 
65 
366 
595 
42 
18 
23 
330 
6 
11 
4 
3 
86 
175 
11 
36 
20 
9 
234 
70 
2,369 

0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

90 
159 
8 
32 
0 
146 
47 
4 
13 
273 
1,003 
0 
4 
11 
17 
19 
16 
10 
0 
162 
30 
9 
109 
37 
31 
-1 
28 
2,256 

45 
16 
-1 
2 
0 
2 
12 
0 
9 
120 
269 
0 
2 
1 
4 
1 
0 
8 
0 
38 
7 
4 
-10 
3 
3 
1 
6 
540 

178 
145 
-1 
2 
0 
19 
61 
-1 
44 
497 
557 
0 
-1 
13 
14 
-4 
4 
26 
0 
144 
11 
7 
-15 
12 
8 
10 
40 
1,770 

115 
143 
3 
4 
0 
19 
33 
3 
34 
304 
561 
0 
0 
13 
14 
3 
3 
28 
0 
124 
7 
3 
5 
10 
1 
1 
33 
1,465 

114 
7 
-14 
-39 
-7 
-160 
2 
-9 
-9 
42 
-749 
-41 
-25 
-10 
-324 
-26 
-19 
32 
-3 
-17 
-194 
-13 
-144 
-38 
-33 
-223 
-30 
-1,931 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative and enforcement costs 

143 

56 
3 
-11 
-56 
-70 
-73 
2 
-39 
-8 
3 
-49 
-21 
-16 
-15 
-33 
-79 
-43 
214 
-37 
-6 
-23 
-6 
-49 
-36 
-86 
-29 
-18 
-24 

0.02% 
0.00% 
-0.01% 
-0.04% 
-0.02% 
-0.05% 
0.00% 
-0.02% 
0.00% 
0.00% 
-0.02% 
-0.02% 
-0.01% 
0.00% 
-0.01% 
-0.06% 
-0.02% 
0.04% 
-0.01% 
0.00% 
-0.02% 
0.00% 
-0.04% 
-0.03% 
-0.04% 
-0.01% 
0.00% 
-0.01% 

 
  
Table 99: Recurrent costs and cost savings for businesses in PO2B in 2040, relative to the baseline, in million EUR (2023 prices) 

Administrative 
costs (EUR 
million) 

Enforcement costs 
(EUR million) 

Adjustment costs 
(EUR million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs 
savings (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or 
net costs (-) in 
EUR million 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or 
net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

49 
115 
12 
12 
7 
57 
34 
6 
59 
390 
667 
41 
21 
25 
392 
6 
14 
4 
3 
103 
157 
10 
39 
22 
11 
220 
77 
2,550 

0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

32 
151 
31 
57 
9 
159 
31 
13 
107 
428 
819 
102 
24 
-5 
382 
16 
11 
-4 
11 
240 
147 
5 
127 
39 
23 
131 
22 
3,108 

1 
-1 
1 
0 
3 
0 
-2 
0 
1 
23 
20 
0 
7 
0 
35 
1 
0 
1 
0 
10 
1 
2 
5 
2 
0 
21 
0 
130 

123 
-4 
6 
59 
-4 
99 
31 
18 
12 
454 
482 
2 
41 
9 
90 
46 
15 
13 
1 
229 
79 
-9 
29 
21 
27 
95 
-36 
1,929 

82 
130 
40 
18 
6 
73 
29 
9 
94 
202 
612 
66 
33 
17 
70 
12 
25 
8 
8 
178 
97 
11 
151 
17 
16 
175 
15 
2,193 

122 
-138 
3 
7 
-17 
-44 
-4 
8 
-61 
-185 
-411 
-74 
22 
7 
-648 
35 
15 
20 
-5 
54 
-129 
-14 
9 
-25 
9 
-102 
-119 
-1,666 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative and enforcement costs 

58 
-56 
2 
11 
-176 
-18 
-4 
30 
-52 
-12 
-25 
-33 
13 
10 
-59 
90 
32 
110 
-52 
18 
-14 
-6 
3 
-21 
29 
-12 
-62 
-19 

0.02% 
-0.02% 
0.00% 
0.01% 
-0.04% 
-0.01% 
0.00% 
0.02% 
-0.02% 
-0.01% 
-0.01% 
-0.03% 
0.01% 
0.00% 
-0.03% 
0.07% 
0.02% 
0.02% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.02% 
0.01% 
-0.01% 
-0.02% 
-0.01% 

144 

 
  
7.14. PO2B: Impacts on costs and costs savings for citizens in 2030 and 2040 relative to the baseline 

Table 100: Recurrent costs and cost savings for citizens in PO2B in 2030, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net 
costs (-) in EUR million 

Adjustment costs savings 
(EUR million) 

Adjustment costs (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

1 
1 
0 
0 
0 
0 
2 
0 
2 
13 
16 
0 
0 
0 
0 
-1 
0 
1 
0 
3 
4 
0 
0 
0 
0 
0 
0 
44 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

36 
18 
0 
0 
0 
16 
11 
0 
14 
115 
262 
0 
-1 
0 
1 
3 
0 
3 
0 
20 
-1 
0 
0 
0 
0 
0 
3 
501 

27 
16 
0 
0 
0 
8 
8 
0 
14 
96 
195 
0 
0 
1 
1 
0 
0 
4 
0 
15 
0 
0 
0 
1 
0 
0 
2 
389 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

-62 
-33 
0 
-1 
0 
-24 
-17 
0 
-25 
-198 
-441 
0 
1 
-1 
-2 
-4 
0 
-7 
0 
-32 
5 
0 
1 
-1 
0 
1 
-6 
-846 

-15 
-7 
0 
-1 
0 
-5 
-8 
-1 
-8 
-5 
-12 
0 
0 
-1 
0 
-8 
0 
-17 
-1 
-5 
0 
0 
0 
-1 
0 
0 
-2 
-4 

-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.01% 
-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

145 

 
  
Table 101: Recurrent costs and cost savings for citizens in PO2B in 2040, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net 
costs (-) in EUR million 

Adjustment costs savings 
(EUR million) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

149 
150 
-4 
13 
-3 
4 
27 
2 
-8 
154 
-179 
-4 
-7 
8 
13 
14 
1 
1 
1 
176 
32 
2 
1 
-4 
4 
-7 
28 
562 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

21 
29 
1 
-2 
0 
2 
14 
0 
-3 
59 
111 
1 
-1 
1 
1 
-3 
0 
1 
0 
81 
4 
0 
-3 
-2 
-1 
5 
9 
324 

0 
0 
0 
0 
2 
0 
0 
0 
0 
1 
2 
0 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
8 

103 
115 
1 
-3 
0 
0 
20 
0 
-16 
100 
-216 
0 
-8 
8 
11 
0 
0 
-2 
0 
186 
15 
0 
-5 
-5 
0 
-8 
27 
322 

231 
235 
-5 
12 
-5 
2 
33 
2 
-21 
194 
-508 
-5 
-14 
15 
21 
17 
2 
-2 
0 
281 
43 
2 
-1 
-7 
5 
-22 
45 
552 

46 
40 
-2 
12 
-7 
1 
15 
4 
-7 
5 
-12 
-1 
-4 
8 
1 
25 
2 
-4 
1 
40 
3 
1 
0 
-4 
7 
-1 
11 
3 

0.04% 
0.03% 
0.00% 
0.01% 
-0.01% 
0.00% 
0.01% 
0.00% 
-0.01% 
0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.00% 
0.00% 
0.00% 
0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.01% 
0.00% 
0.01% 
0.00% 

146 

 
  
7.15. PO2B: Impacts on costs and costs savings for national public authorities in 2030 and 2040 relative to the baseline 

Table 102: Recurrent costs and cost savings for national public authorities in PO2B in 2030, relative to the baseline, in million EUR (2023 prices) 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

million) 

Additional tax revenues (EUR 
million) 

Net benefits (+) or net costs (-) in 
EUR million 

Net benefits (+) or net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

115 
143 
3 
4 
0 
19 
33 
3 
34 
304 
561 
0 
0 
13 
14 
3 
3 
28 
0 
124 
7 
3 
5 
10 
1 
1 
33 
1,465 

71 
32 
-2 
2 
0 
10 
20 
0 
23 
216 
464 
0 
2 
2 
6 
1 
0 
13 
0 
53 
7 
4 
-11 
4 
2 
1 
8 
928 

-43 
-111 
-5 
-2 
0 
-9 
-13 
-2 
-11 
-89 
-99 
0 
2 
-10 
-9 
-2 
-3 
-16 
0 
-72 
-1 
0 
-16 
-6 
1 
0 
-26 
-543 

-0.01% 
-0.02% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.02% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

147 

 
 
  
Table 103: Recurrent costs and cost savings for national public authorities in PO2B in 2040, relative to the baseline, in million EUR (2023 prices) 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

million) 

Additional tax revenues (EUR 
million) 

Net benefits (+) or net costs (-) in 
EUR million 

Net benefits (+) or net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

184 
245 
41 
15 
7 
73 
49 
9 
78 
302 
397 
65 
24 
25 
81 
11 
26 
5 
8 
364 
112 
11 
146 
11 
16 
167 
41 
2,515 

1 
-1 
1 
0 
5 
0 
-2 
0 
1 
24 
22 
0 
7 
0 
36 
1 
0 
1 
0 
11 
1 
2 
5 
2 
0 
22 
0 
139 

-184 
-246 
-39 
-15 
-1 
-73 
-51 
-9 
-77 
-279 
-377 
-65 
-17 
-26 
-46 
-10 
-26 
-5 
-8 
-354 
-111 
-9 
-141 
-10 
-16 
-146 
-42 
-2,382 

-0.03% 
-0.03% 
-0.03% 
-0.01% 
0.00% 
-0.02% 
-0.01% 
-0.02% 
-0.02% 
-0.01% 
-0.01% 
-0.03% 
-0.01% 
0.00% 
0.00% 
-0.02% 
-0.03% 
0.00% 
-0.02% 
-0.03% 
-0.01% 
0.00% 
-0.03% 
-0.01% 
-0.02% 
-0.01% 
-0.01% 
-0.01% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

148 

 
  
 
7.16. PO2C: Impacts on costs and costs savings for businesses in 2030 and 2040 relative to the baseline 

Table 104: Recurrent costs and cost savings for businesses in PO2C in 2030, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or 
net costs (-) in 
EUR million 

Adjustment costs 
savings (EUR 
million) 

Reduction in tax 
expenditures 
(EUR million) 

Administrative 
costs (EUR 
million) 

Increase in tax 
expenditures 
(EUR million) 

Enforcement costs 
(EUR million) 

Adjustment costs 
(EUR million) 

Net benefits (+) or net costs 
(-) divided by corporate 
vehicle stock (in EUR) 

Net benefits (+) or 
net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

45 
106 
10 
11 
7 
50 
32 
6 
65 
366 
595 
42 
18 
23 
330 
6 
11 
4 
3 
86 
175 
11 
36 
20 
9 
234 
70 
2,369 

0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

93 
174 
9 
66 
0 
200 
60 
5 
19 
452 
1,360 
0 
4 
15 
124 
20 
23 
13 
0 
179 
128 
26 
108 
58 
33 
-2 
43 
3,211 

46 
18 
-2 
2 
0 
2 
12 
0 
11 
153 
328 
0 
2 
2 
3 
0 
0 
10 
0 
44 
7 
7 
-16 
3 
3 
2 
10 
648 

215 
177 
-1 
1 
0 
23 
75 
-2 
52 
682 
843 
0 
-1 
19 
21 
-6 
5 
33 
0 
175 
20 
13 
-19 
14 
8 
15 
78 
2,442 

140 
170 
3 
14 
0 
31 
42 
3 
43 
403 
777 
0 
0 
19 
26 
3 
5 
33 
0 
152 
21 
9 
3 
17 
2 
1 
56 
1,975 

171 
50 
-14 
-64 
-7 
-197 
12 
-9 
1 
113 
-662 
-41 
-25 
-2 
-410 
-29 
-24 
40 
-3 
18 
-268 
-22 
-144 
-50 
-35 
-218 
12 
-1,811 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative and enforcement costs 

149 

85 
21 
-12 
-92 
-70 
-91 
12 
-41 
1 
9 
-43 
-21 
-16 
-3 
-41 
-87 
-54 
262 
-36 
6 
-31 
-9 
-49 
-48 
-91 
-29 
7 
-22 

0.03% 
0.01% 
-0.01% 
-0.07% 
-0.02% 
-0.06% 
0.00% 
-0.02% 
0.00% 
0.00% 
-0.02% 
-0.02% 
-0.01% 
0.00% 
-0.02% 
-0.06% 
-0.03% 
0.04% 
-0.01% 
0.00% 
-0.03% 
-0.01% 
-0.04% 
-0.04% 
-0.05% 
-0.01% 
0.00% 
-0.01% 

 
  
Table 105: Recurrent costs and cost savings for businesses in PO2C in 2040, relative to the baseline, in million EUR (2023 prices) 

Administrative 
costs (EUR 
million) 

Enforcement costs 
(EUR million) 

Adjustment costs 
(EUR million) 

Increase in tax 
expenditures (EUR 
million) 

Adjustment costs 
savings (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or 
net costs (-) in 
EUR million 

Net benefits (+) or net 
costs (-) divided by 
corporate vehicle stock 
(in EUR) 

Net benefits (+) or 
net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

49 
115 
12 
12 
7 
57 
34 
6 
59 
390 
667 
41 
21 
25 
392 
6 
14 
4 
3 
103 
157 
10 
39 
22 
11 
220 
77 
2,549 

0.01 
0.00 
0.00 
0.01 
0.09 
0.00 
0.01 
0.00 
0.02 
0.03 
0.00 
0.02 
0.00 
0.00 
0.00 
0.00 
0.00 
0.00 
0.02 
0.01 
0.01 
0.00 
0.00 
0.00 
0.00 
0.00 
0.01 
0.25 

24 
186 
37 
87 
14 
204 
26 
15 
117 
488 
1,079 
131 
28 
-2 
520 
21 
19 
-5 
11 
256 
237 
10 
142 
55 
22 
202 
16 
3,939 

1 
-2 
1 
0 
3 
0 
-2 
0 
1 
21 
15 
0 
7 
0 
35 
1 
0 
1 
0 
8 
1 
2 
5 
2 
0 
21 
-1 
118 

142 
28 
8 
58 
-5 
100 
38 
19 
27 
591 
708 
1 
39 
18 
125 
46 
16 
13 
1 
271 
99 
-8 
34 
21 
23 
123 
-25 
2,510 

96 
172 
52 
30 
8 
97 
43 
10 
111 
316 
786 
87 
51 
23 
88 
16 
32 
9 
8 
229 
109 
22 
169 
29 
19 
216 
32 
2,860 

164 
-98 
11 
-10 
-21 
-63 
23 
7 
-40 
8 
-267 
-84 
34 
19 
-733 
35 
16 
21 
-4 
133 
-186 
-7 
16 
-29 
10 
-104 
-86 
-1,237 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative and enforcement costs 

77 
-40 
9 
-16 
-210 
-26 
22 
26 
-34 
1 
-16 
-38 
20 
27 
-67 
89 
35 
118 
-48 
44 
-20 
-3 
6 
-24 
31 
-12 
-44 
-14 

0.03% 
-0.01% 
0.01% 
-0.01% 
-0.05% 
-0.02% 
0.01% 
0.01% 
-0.01% 
0.00% 
-0.01% 
-0.03% 
0.01% 
0.00% 
-0.03% 
0.07% 
0.02% 
0.02% 
-0.01% 
0.01% 
-0.02% 
0.00% 
0.00% 
-0.02% 
0.01% 
-0.01% 
-0.01% 
-0.01% 

150 

 
  
7.17. PO2C: Impacts on costs and costs savings for citizens in 2030 and 2040 relative to the baseline 

Table 106: Recurrent costs and cost savings for citizens in PO2C in 2030, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net 
costs (-) in EUR million 

Adjustment costs savings 
(EUR million) 

Adjustment costs (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0 
1 
0 
0 
0 
0 
2 
0 
3 
15 
17 
0 
0 
0 
0 
-1 
0 
1 
0 
3 
5 
0 
0 
0 
0 
0 
0 
47 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

38 
20 
0 
0 
0 
16 
12 
0 
17 
145 
325 
0 
-1 
1 
1 
4 
0 
4 
0 
22 
-1 
0 
0 
1 
0 
0 
5 
610 

28 
17 
0 
1 
0 
8 
9 
0 
17 
118 
236 
0 
0 
2 
3 
0 
0 
5 
0 
17 
1 
0 
0 
2 
0 
0 
4 
465 

0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 

-65 
-37 
0 
-1 
0 
-24 
-19 
-1 
-31 
-248 
-544 
0 
1 
-2 
-3 
-5 
0 
-9 
-1 
-36 
5 
0 
1 
-3 
0 
1 
-9 
-1,028 

-16 
-8 
0 
-1 
0 
-5 
-9 
-1 
-10 
-6 
-15 
0 
0 
-1 
0 
-9 
0 
-21 
-2 
-6 
0 
0 
0 
-1 
0 
0 
-3 
-5 

-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.01% 
-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.00% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 

151 

 
  
Table 107: Recurrent costs and cost savings for citizens in PO2C in 2040, relative to the baseline, in million EUR (2023 prices) 
Net benefits (+) or net 
costs (-) in EUR million 

Adjustment costs savings 
(EUR million) 

Adjustment costs (EUR 
million) 

Reduction in tax 
expenditures (EUR 
million) 

Increase in tax 
expenditures (EUR 
million) 

Net benefits (+) or net 
costs (-) divided by 
private vehicle stock (in 
EUR) 

Net benefits (+) or net 
costs (-) as share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

197 
194 
-5 
12 
-2 
4 
48 
2 
1 
236 
-61 
-4 
-7 
15 
19 
13 
1 
8 
-1 
215 
32 
2 
1 
-4 
4 
-8 
75 
988 
Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling)  

29 
43 
1 
-2 
1 
2 
27 
0 
2 
76 
215 
1 
-1 
3 
4 
-3 
0 
0 
1 
101 
5 
-1 
-3 
-2 
-1 
5 
19 
522 

0 
0 
0 
0 
2 
0 
0 
0 
0 
2 
2 
0 
0 
0 
1 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
1 
0 
9 

139 
154 
1 
-3 
0 
0 
34 
0 
-8 
168 
-83 
0 
-8 
14 
16 
0 
1 
-2 
0 
228 
15 
0 
-5 
-6 
0 
-8 
70 
715 

306 
304 
-5 
12 
-5 
2 
56 
2 
-9 
326 
-360 
-5 
-14 
26 
29 
16 
2 
6 
-1 
341 
42 
2 
-1 
-8 
5 
-21 
125 
1,172 

61 
52 
-2 
12 
-7 
1 
25 
3 
-3 
8 
-8 
-1 
-4 
15 
1 
24 
2 
11 
-3 
49 
3 
1 
0 
-5 
7 
-1 
31 
5 

0.05% 
0.04% 
0.00% 
0.01% 
-0.01% 
0.00% 
0.01% 
0.00% 
0.00% 
0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.03% 
0.00% 
0.01% 
0.00% 
0.03% 
0.00% 
0.00% 
0.00% 
-0.01% 
0.01% 
0.00% 
0.02% 
0.01% 

152 

 
  
7.18. PO2C: Impacts on costs and costs savings for national public authorities in 2030 and 2040 relative to the baseline 

Table 108: Recurrent costs and cost savings for national public authorities in PO2C in 2030, relative to the baseline, in million EUR (2023 prices) 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

million) 

Additional tax revenues (EUR 
million) 

Net benefits (+) or net costs (-) in 
EUR million 

Net benefits (+) or net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

140 
170 
3 
14 
0 
31 
42 
3 
43 
403 
777 
0 
0 
19 
26 
3 
5 
33 
0 
152 
21 
9 
3 
17 
2 
1 
56 
1,975 

74 
35 
-2 
3 
0 
10 
21 
0 
28 
270 
564 
0 
2 
3 
6 
1 
0 
15 
0 
61 
7 
8 
-16 
5 
3 
2 
13 
1,113 

-66 
-136 
-5 
-11 
0 
-21 
-21 
-3 
-15 
-133 
-216 
0 
2 
-15 
-21 
-2 
-5 
-18 
0 
-92 
-14 
-2 
-20 
-13 
1 
1 
-43 
-869 

-0.01% 
-0.02% 
0.00% 
-0.01% 
0.00% 
-0.01% 
-0.01% 
-0.01% 
-0.01% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
0.00% 
-0.01% 
-0.02% 
0.00% 
-0.01% 
0.00% 
0.00% 
-0.01% 
-0.01% 
0.00% 
0.00% 
-0.01% 
0.00% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

153 

 
 
  
Table 109: Recurrent costs and cost savings for national public authorities in PO2C in 2040, relative to the baseline, in million EUR (2023 prices) 

Administrative costs (EUR million)  Losses in tax revenues (EUR 

million) 

Additional tax revenues (EUR 
million) 

Net benefits (+) or net costs (-) in 
EUR million 

Net benefits (+) or net costs (-) as 
share of GDP 

AT 
BE 
BG 
HR 
CY 
CZ 
DK 
EE 
FI 
FR 
DE 
EL 
HU 
IE 
IT 
LV 
LT 
LU 
MT 
NL 
PL 
PT 
RO 
SK 
SI 
ES 
SE 
EU27 

0.22 
0.24 
0.03 
0.03 
0.10 
0.11 
0.17 
0.01 
0.11 
0.82 
2.15 
0.06 
0.04 
0.15 
0.52 
0.02 
0.03 
0.04 
0.02 
0.39 
0.17 
0.07 
0.06 
0.04 
0.02 
0.44 
0.26 
6.33 

235 
326 
53 
28 
8 
97 
77 
10 
103 
484 
703 
87 
42 
38 
104 
16 
33 
6 
8 
457 
124 
22 
163 
24 
19 
208 
101 
3,576 

1 
-2 
1 
0 
5 
0 
-2 
0 
1 
22 
17 
0 
7 
0 
36 
1 
0 
1 
0 
9 
1 
2 
5 
2 
0 
22 
-1 
127 

-234 
-328 
-52 
-28 
-3 
-98 
-80 
-10 
-102 
-462 
-688 
-87 
-35 
-38 
-69 
-14 
-33 
-6 
-8 
-449 
-123 
-20 
-158 
-22 
-19 
-187 
-102 
-3,455 

-0.04% 
-0.04% 
-0.04% 
-0.03% 
-0.01% 
-0.02% 
-0.02% 
-0.02% 
-0.03% 
-0.01% 
-0.01% 
-0.03% 
-0.01% 
0.00% 
0.00% 
-0.03% 
-0.03% 
-0.01% 
-0.02% 
-0.04% 
-0.01% 
-0.01% 
-0.03% 
-0.01% 
-0.02% 
-0.01% 
-0.01% 
-0.02% 

Source: Ricardo (2025), Support study; PRIMES-TREMOVE transport model (E3-Modelling) and standard cost model for administrative costs 

154 

 
  
8.  ASSUMPTIONS USED FOR THE ASSESSMENT OF IMPACTS OF EU CONTENT REQUIREMENTS 

According to analysis performed by JRC with FIDELIO model, introducing EU content requirements for steel 
and aluminium in the automotive sector for public procurement and support schemes would lead to a 0.53% 
reduction of the EU automotive sector’s gross value added for 2025-2030, relative to a baseline scenario without 
EU content requirements220.  

For batteries, EU content requirements may raise the costs of battery electric vehicles, affecting affordability and 
competitiveness in cost-sensitive markets. However, a phased implementation plus the support schemes in place 
would help absorb the impact. Based on 2024 cost differentials, the price increase for an average electric car 
equipped with a 68 kWh battery pack, when using EU-made cells, cathode active materials (CAM), and anode 
active materials (AAM), would range between EUR 653 and EUR 1,632. This corresponds to approximately 
1.4% to 3.5% of the average retail price of an electric vehicle in Europe. However, as battery cell costs decline 
over time, the total cost differential with China is also expected to decrease. The table below provides the low 
and high  estimates  for the  cost  difference  for  an  electric  car,  van  and lorry based on  the  cost difference  per 
battery cell and the average battery capacity of an average vehicle in the baseline221.   

Table 110: Low and high estimates for the cost difference between electric vehicles equipped with batteries using EU-
made battery cells with locally sourced CAM and AAM and Chinese imports (in EUR per vehicle) 

Cost difference for an electric car (average 65-67 kWh) 
Cost difference for an electric van (average 89 kWh) 
Cost difference for an electric lorry (average 445 kWh in 2029 
to 333 kWh in 2050) 

2035 
2029 
264-659 
393-982 
350-874 
534-1,335 
2,674-6,686  2,355-5,887  1,494-3,734  1,374-2,863  1,311-1,639 

2030 
346-865 
470-1,175 

2050 
263-328 
350-437 

2040 
262-545 
350-729 

The economic impacts of the measure on vehicle components were calculated by JRC using the SMILE EU 
model222, including Eurostat's FIGARO tables223 and other data sources224. The estimated impacts on prices per 
electric vehicle stemming from this measure are expected to be limited: (i) for cars, 0.9% increase in 2029 and 
1.2% increase from 2030 relative to the baseline; (ii) for vans, 0.1% increase in 2029 and 0.4% increase from 
2030 relative to the baseline; (iii) for lorries, 0.9% increase in 2029 and 1.2% increase from 2030 relative to the 
baseline.  

220 FIDELIO stands for Fully Interregional Dynamic Econometric Long-term Input-Output model. It is a dynamic general 
equilibrium model developed by the JRC. For simulating the impacts of local content requirements for aluminium and steel, 
FIDELIO  was  used  in  combination  with  the  FIGARO-E3  database  (Cazcarro  et  al.,  2025);  a  disaggregation  of  the 
Eurostat’s global FIGARO input-output tables (Remond-Tiedrez and Rueda-Cantuche, 2019) that includes such materials 
explicitly represented. 
221 Post-2035, the low estimate of the cost difference per battery cell has been kept constant over time, while accounting for 
the  changes  in  the  average  battery  capacity  in  the  baseline.  For  the  high  estimate  of  the  cost  difference  some  further 
reduction has been assumed up to 2050 due to economies of scale. The cost difference per battery cell by 2050 is assumed 
to be half of the cost difference in 2035.  
222 SMILE EU (Single Market Integration through a MIcroeconomic LEns) is a set of analytical and quantitative tools on 
market  efficiency  and  microeconomic  behaviour  to  provide  tailor-made  answers  related  to  industrial,  innovation  and 
employment  policies.  At  its  core,  there  is  a  macroeconomic  model  where  economic  outcomes  are  the  result  of 
microeconomic decisions made by heterogeneous firms and/or households. In SMILE EU, the micro drives the macro. The 
impact  assessment  builds  on  various  tools  developed  within  SMILE  EU.  It  leverages  the  methodology  developed  to 
disaggregate input-output data, which provides science-to-policy evidence at a more granular level.  
223 https://joint-research-centre.ec.europa.eu/projects-and-activities/trade-and-industrial-policy-analysis/input-output-
accounts/figaro-tables_en  
224 McKinsey & Company (2024), Europe's economic potential in the shift to electric vehicles; JRC (2022), Revision of the 
EU  Green  Public  Procurement  Criteria  for  Road  transport;  ACEA  (2025),  Tax  benefits  and  incentives;  Leard  and  Wu 
(2023), New Passenger Vehicle Demand Elasticities: Estimates and Policy Implications; 
Draghi (2024), The future of European competitiveness 

155 

 
  
 
Table  111  provides  the  estimated  costs  of  applying  EU  content  criteria  to  new  zero-emission  vehicles  in 
corporate fleets, associated to the policy options, assuming 100% pass through of the costs to vehicle owners. 
The table shows the number of vehicles subject to the requirements on batteries and to the requirements on other 
vehicle  components  as  well  as  the  costs  associated  to  the  requirements  on  batteries  and  on  other  vehicle 
components for specific years (2029, 2030, 2033 and 2035), relative to the baseline.  

Table 111: Impacts of EU content requirements on costs for businesses for specific years relative to the baseline 

Number of vehicles subject to 
requirements on vehicle 
components, excluding batteries (in 
thousand) 
Number of vehicles subject to 
requirements on batteries (in 
thousand) 

Costs related to vehicle components 
(million EUR) 

Costs related to batteries - low 
estimates (million EUR) 

Costs related to batteries - high 
estimates (million EUR) 

Total costs for businesses - low 
estimates (million EUR) 

Total costs for businesses - high 
estimates (million EUR) 

Number of vehicles subject to 
requirements on vehicle 
components, excluding batteries (in 
thousand) 
Number of vehicles subject to 
requirements on batteries (in 
thousand) 

Costs related to vehicle components 
(million EUR) 

Costs related to batteries - low 
estimates (million EUR) 

Costs related to batteries - high 
estimates (million EUR) 

Total costs for businesses - low 
estimates (million EUR) 

Total costs for businesses - high 
estimates (million EUR) 

PO1A 

PO1B 

PO1C 

2029 
525 

2030 
598 

2033 
244 

2035 
8 

2029 
901 

2030 
785 

2033  2035 
12 

321 

2029 
1,122 

2030 
984 

2033  2035 
16 

403 

501 

590 

239 

6 

860 

774 

314 

9 

1,072 

970 

395 

12 

119 

191 

92 

24 

202 

253 

125 

38 

251 

319 

160 

52 

208 

226 

83 

9 

361 

299 

111 

13 

458 

377 

141 

18 

519 

564 

207 

22 

902 

747 

278 

33 

1,145 

941 

353 

46 

327 

416 

175 

33 

563 

552 

236 

51 

709 

696 

301 

70 

638 

754 

299 

46 

1,104 

1,000 

403 

71 

1,396 

1,261 

513 

97 

PO2A 

PO2B 

PO2C 

2029 
521 

2030 
617 

2033 
293 

2035 
77 

2029 
894 

2030 
808 

2033  2035 
94 

380 

2029 
1,112 

2030 
1,019 

2033  2035 
99 

467 

498 

607 

281 

64 

854 

796 

364 

77 

1,063 

1,004 

449 

81 

110 

255 

253 

241 

185 

337 

317 

291 

224 

337 

317 

291 

199 

266 

159 

95 

345 

351 

202 

115 

434 

351 

202 

115 

499 

665 

397 

238 

863 

878 

504 

288 

1,085 

878 

504 

288 

310 

521 

412 

336 

530 

688 

519 

406 

658 

688 

519 

406 

609 

920 

650 

479 

1,048 

1,215 

822 

579 

1,309 

1,215 

822 

579 

156 

 
  
  
 
 
 
 
 
 
 
 
ANNEX 5: COMPETITIVENESS CHECK 

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS  

Dimensions of 
Competitiveness 

Impact of the initiative 
(++ / + / 0 / - / -- / n.a.) 

References to sub-sections of the 
main report or annexes 

Cost and price competitiveness 

++ for PO1A and PO1B 
/ +++ for PO1C 

6.1.1, 6.1.5, 6.1.6, 6.1.7 and Annex 4 
(sections 3, 4, 5, 6 and 7) 

Capacity to innovate 

International competitiveness  

+ for PO1A / ++ for 
PO1B / +++ for PO1C 

+ for PO1A, PO1B and 
PO1C 

6.1.8 

6.1.5 

SME competitiveness 

-- for PO1A, PO1B and 
PO1C 

6.1.6, Annex 4 (section 3 and 4) and 
Annex 6 

2.  SYNTHETIC ASSESSMENT  

2.1 

Cost and price competitiveness 

PO1A, PO1B and PO1C are expected to have an overall positive impact on the cost competitiveness of 
the  directly  affected  businesses,  that  include  large  road  transport  operators  and  other  large  businesses 
(vehicle  owners).  Lower  fuel  costs  and  other  operation  costs  will  strengthen  the  cost  competitiveness  of 
these companies despite the higher upfront cost for the ZEV purchase. 

Total adjustment costs for large businesses, mostly capital costs for the ZEV purchase, are estimated at EUR 
8.3 billion in PO1A, EUR 11.9 billion in PO1B and EUR 15.6 billion in PO1C expressed as present value 
over 2029-2050 relative to the baseline (see Table 22 in section 6.1.5). On the other hand, adjustment costs 
savings, mostly fuel and other operation costs savings, are projected at EUR 23.4 billion in PO1A, EUR 
32.7 billion in PO1B and EUR 42.9 billion in PO1C, expressed as present value over 2029-2050 relative to 
the baseline.  In addition, the reduction in  the fossil fuel use due to the  purchase of new  ZEV  instead of 
conventional  vehicles  would  also  lead  to  a  decrease  in  the  fuel  tax  expenditures  for  large  companies, 
estimated at EUR 16.9 billion in PO1A, EUR 24.1 billion in PO1B and EUR 32 billion in PO1C. As shown 
in section 6.1.5, PO1A, PO1B and PO1C are expected to result in net benefits for the directly affected 
businesses. The net benefits for large companies are estimated at EUR 32 billion in PO1A, EUR 45 billion 
in PO1B and EUR 59.2 billion in PO1C, expressed as present value over 2029-2050 relative to the baseline. 
Thus, large businesses are expected to increase their cost competitiveness in PO1A, PO1B and PO1C. 

SMEs are not directly affected by PO1A, PO1B and PO1C. However, assuming that vehicle manufacturers 
maintain the minimum share of ZEVs in new registrations required to meet their emission reduction targets 
under the CO2 emission performance standards, the increased demand for new ZEVs by large companies 
will reduce the availability of new ZEVs for SMEs resulting in net costs for SMEs as discussed in section 
6.1.6, and  further discussed in section 2.4 of  Annex 5 and in Annex 6.  

At aggregate level, the preferred option is expected to result in net benefits for businesses owning vehicles 

157 

 
 
(large businesses and SMEs taken together) estimated at EUR 16.4 billion in PO1A, EUR 26.3 billion in 
PO1B and EUR 38.7 billion in PO1C, expressed as present value over 2029-2050 relative to the baseline.   

The  competitiveness  of  automotive  manufacturers  is  also  expected  to  improve,  as  long-term  predictable 
increases  in  the  demand  for  ZEVs  from  corporate  fleets  provides  greater  certainty  for  the  investment 
necessary to maintain a competitive position in the fast-growing ZEV market. 

2.2 

Capacity to innovate 

PO1A,  PO1B  and  PO1C  are  expected  to  have  an  overall  positive  impact  on  the  capacity  of  vehicle 
manufacturers  to  innovate.  By  stimulating  the  deployment  of  zero-emission  technologies  in  new 
corporate  vehicle  registrations,  they  create  long-term  demand  certainty  and  establish  a  more  stable 
environment for vehicle manufacturers to invest in ZEV innovation and technological development. While 
innovation in technologies for road transport vehicles is primarily driven by the CO2 emission performance 
standards, this initiative will play a supporting role by stimulating demand in specific corporate fleets use 
cases  and  by  incentivising  the  deployment  of  ZEV  models  suited  to  their  operational  requirements.  The 
wider deployment of ZEVs in the second-hand vehicle markets is also expected to increase their visibility in 
markets  with  currently  low  market  penetration  rates  and  to  enhance  understanding  of  ZEV  use  across  a 
broader  range  of  operational  contexts.  This  broader  exposure  is  likely  to  provide  additional  impetus  for 
technological  development,  particularly  in  the  case  of  lorries.  The  positive  impacts  on  innovation  and 
technological  development  are  expected  to  be  highest  in PO1C,  due  to the  highest impacts  on  the  ZEV 
corporate fleets and second-hand market, followed by PO1B and PO1A. 

2.3 

International competitiveness 

The international competitiveness of larger companies is expected to increase, as lower fuel costs and other 
operation costs over the lifetime of the ZEV fleet will impact positively the cost structure of the companies 
and free resources. Importantly, the increased competitiveness of automotive manufacturers due to a more 
predictable planning of the transition to ZEVs will also benefit their ability to better position themselves in 
competitive global markets for ZEVs. 

2.4 

SME competitiveness 

For SMEs, PO1A is estimated to result in net costs of EUR 15.6 billion expressed as present value over 
2029-2050 relative to the baseline, PO1B to net costs of EUR 18.7 billion and PO1C to net costs of EUR 
20.5 billion. Despite SMEs not being directly targeted by the preferred policy options, the increased demand 
for  new  ZEVs  by  large  companies  will  reduce  the  availability  of  new  ZEVs  for  SMEs  in  the  short  to 
medium term. This is based on the assumption that vehicle manufacturers maintain the minimum share of 
ZEVs  in  new  registrations  required  to  meet  their  emission  reduction  targets  under  the  CO2  emission 
performance  standards.  At  the  same  time,  the  faster  increase  in  the  share  of  ZEVs  in  corporate  fleets, 
particularly  in  fleets  with  high  turnover  such  as  rental  car  fleets,  is  expected  to  accelerate  the  uptake  of 
second-hand  ZEV  by  SMEs.  This  would  lead  to  fuel  costs  and  other  operation  costs  savings  for  SMEs 
relative to the baseline. It should also be noted that although SMEs are expected to experience overall net 
costs, expressed as present value over 2029-2050 relative to the baseline, in the medium to longer term in 
PO1B and PO1C they are projected to experience net benefits, due to the higher ZEV uptake in the second-
hand market. In addition, the net costs are estimated at up to EUR 21.1 per vehicle per year in PO1A, EUR 
29.6 in PO1B and EUR 38.5 in PO1C. More detailed explanations on the impacts on SMEs are provided in 
section 6.1.6, Annex 4 (sections 3 and 4) and the SME check is provided in Annex 6.   

158 

 
3.  COMPETITIVE POSITION OF THE MOST AFFECTED SECTORS 

Corporate fleets present a clear potential in helping to sustain and accelerate the increase in the uptake of 
ZEVs in the EU. Renting and leasing of motor vehicles sector represents 10% of all value added generated 
by administrative and support service activities (0.6% of the total value added of the industry, construction 
and market services in the EU economy), while passenger and freight transport by road represents around 
36% of all value added generated by the transport and storage sector (2.1% of the total value added of the 
industry,  construction  and  market  services)225.  Around  73.5%  of  businesses  and  approximately  half  of 
persons employed in the transportation and storage sector operate in passenger and freight transport by road. 

Table  112:  Value  added,  persons  employed  and  number  of  businesses  in  the  road  transport  and  rental  and 
leasing sectors in EU27 in 2023 

Industry, construction and market services [B-S_X_O_S94]* 
  Transportation and storage [H] 

Land transport and transport via pipelines [H49] 

Other passenger land transport [H493] 

Freight transport by road and removal services [H494] 

  Administrative and support service activities [N] 

Rental and leasing activities [N77] 

   Renting and leasing of motor vehicles [N771] 

Value added 
(million EUR, 
current prices) 

Persons 
employed 

Number of 
enterprises 

10,459,844 

162,151,763 

33,065,685 

597,797 

264,687 

64,410 

150,609 

607,186 

144,177 

60,430 

10,312,819 

1,461,505 

5,740,560 

1,063,770 

1,720,000 

3,400,000 

474,806 

600,000 

14,083,422 

1,936,646 

749,282 

209,329 

225,431 

52,000 

Source: Eurostat. Enterprises by detailed NACE Rev. 2 activity and special aggregates [sbs_ovw_act]. *Except public 
administration and defence, compulsory social security, activities of membership organisations. 

The sector is also significantly represented by SMEs, which represent more than 99% of total businesses in 
passenger and freight transport by land as well as rental and leasing of motor vehicles, as shown in the table 
below. This is particularly important when considering the high purchase costs and operational constraints of 
ZEVs compared to conventional vehicles. The low availability of affordable ZEVs in the market is one of 
the factors driving the current low uptake of ZEVs in corporate fleets. 

Table 113: Number of businesses in selected sectors in the EU27 in 2023, by size 
Small 
(10-49 
employees) 

Micro 
(less than 9 
employees) 

Medium 
(50-249 
employees) 

Large 
(250 or more 
employees) 

Industry, construction and market services 
[B-S_X_O_S94]* 

Transportation and storage [H] 

Land transport and transport via pipelines [H49] 

Other passenger land transport [H493] 

Freight transport by road and removal services [H494] 

Administrative and support service activities [N] 

31,190,732 

1,572,015 

248,720 

54,219 

1,347,436 

983,194 

433,105 ** 

524,505 

1,818,115 

94,169 

68,892 

13,931 

54,838 

90,328 

16,539 

10,200 

2,549 

7,000 

22,450 

3,360 

1,510 

516 

880 

5,752 

225 The three NACE sub-sectors (H493, H494 and N77) capture corporate fleets primarily focused on public passenger 
transport, freight/logistics, and vehicle leasing. Missing corporate fleets activity include internally owned fleets, non-
transport fleets, or industry-specific fleets. 

159 

 
  
  
  
 
 
 
  
 
 
 
 
  
  
 
 
Rental and leasing activities [N77] 

Micro 
(less than 9 
employees) 
216,185 

Small 
(10-49 
employees) 
7,767 

Medium 
(50-249 
employees) 
1,226 

Large 
(250 or more 
employees) 
254 

   Renting and leasing of motor vehicles [N771] 

50,000 

1,783 

303 

88 ** 

Source:  Eurostat.  Enterprise  statistics  by  size  class  and  NACE  Rev.  2  activity  (from  2021  onwards)  [sbs_sc_ovw]. 
*Except public administration and defence, compulsory social security, activities of membership organisations. ** 2022 
data, as 2023 is confidential. 

Given  that  an  increase  in  the  uptake  of  ZEVs  in  corporate  fleets  across  the  EU  would  support  the 
competitiveness of the automotive sector, it is relevant to also examine the  automotive sector in the EU. 
From  a  socioeconomic  perspective,  the  automotive  sector  is  a  key  contributor  to  economic  growth  and 
employment across the EU. The overall transport, mobility and automotive ecosystem is responsible of EUR 
1 trillion of GDP as stated in section 1.1226. The table below shows the value added produced by businesses 
directly involved into the manufacturing of motor vehicles, trailers and semi-trailers. It can be observed that 
this subsector represented around 9.5% of total value added generated by the manufacturing sector in the EU 
between 2021 and 2023. The sector kept a stable employment between 2021 and 2023, hovering at around 
2.45  million  workers,  i.e.,  8%  of  total  EU  jobs  in  manufacturing.  These  represent  the  persons  directly 
employed in the automotive sector. 

Table 114: Value added for the EU industry, construction and market services sectors, including the automotive 
manufacturing sector, between 2021 and 2023 (EUR million, in current prices) 

2021 

2022 

2023 

Industry, construction and market services [B-S_X_O_S94]* 

9,342,087 

10,061,373 

10,459,844 

Manufacturing [C] 
   Manufacture of motor vehicles, trailers and semi-trailers [C29] 

2,190,084 

2,419,775 

2,466,454 

204,000 

223,636 

240,806 

Source: Eurostat. Enterprises by detailed NACE Rev. 2 activity and special aggregates) [sbs_ovw_act]. *Except public 
administration and defence, compulsory social security, activities of membership organisations. 

Table  115:  Persons  employed  in  the  EU  industry,  construction  and  market  services  sectors,  including  the 
automotive manufacturing sector, between 2021 and 2023 

2021 

2022 

2023 

Industry, construction and market services [B-S_X_O_S94]* 

156,098,847 

160,424,218 

162,151,763 

Manufacturing [C] 
   Manufacture of motor vehicles, trailers and semi-trailers [C29] 

29,736,500 

30,026,436 

30,286,221 

2,453,776 

2,426,930 

2,450,000 

Source: Eurostat. Enterprises by detailed NACE Rev. 2 activity and special aggregates) [sbs_ovw_act]. *Except public 
administration and defence, compulsory social security, activities of membership organisations. 

As the  automotive industry is  currently  undergoing a  massive  transformation  –  due to the  importance  of 
reducing CO2 emissions in road transport – the uptake of ZEVs is crucial. The table below shows the share 
of new ZEVs, by type of vehicle. The share of new ZEV registrations has overall  witnessed an increase 
between 2016 and 2025 in the EU. Quite notably, zero-emission cars registrations increased from less than 
1% in 2016 to around 14% of new vehicles registered in 2024 and around 16% in the first half of 2025. Over 
the same period, registrations of new  zero-emission buses and coaches also increased considerably, from 
1.4% to 18.7% in 2024, while the uptake of zero-emission vans and lorries was more limited. 

226 Transition pathway for the EU mobility industrial ecosystem 

160 

 
 
  
 
  
 
  
 
2025 
(first 
half) 
16.2% 

Table 116: New registrations of zero-emission vehicles by type of vehicle in the EU27, between 2016 and 2025 

2016 

2017 

2018 

2019 

2020 

2021 

2022 

2023 

2024 

Cars 

Vans 

Buses and coaches 

Lorries 

0.5% 

0.7% 

1.4% 

0.0% 

0.7% 

0.9% 

1.8% 

0.0% 

1.0% 

1.2% 

1.9% 

0.1% 

1.9% 

1.3% 

4.1% 

0.2% 

5.4% 

1.9% 

5.6% 

0.3% 

9.0% 

12.1% 

14.6% 

13.6% 

2.9% 

4.8% 

6.6% 

5.4% 

8.4% 

8.0% 

12.6% 

15.3% 

18.7% 

22% 

0.4% 

0.5% 

1.8% 

2.4% 

3.7% 

Source: European Alternative Fuel Observatory. Market share of total registrations; Note: The table displays the new 
ZEVs acquisition and does not allow to distinguish between corporate fleets and other uses. 

The  accelerated  uptake  of  ZEVs  observed  in  the  table  above  is  also  reflected  in  the  increasing  relative 
importance of motor vehicles with electric motor for propulsion in international trade. As displayed in the 
table below, the share of EU imports of electric vehicles over total imported motor vehicles increased from 
1.8% (EUR 1,231 million) in 2018 to 16.5% (EUR 15,926 million) in 2024. Exports also saw a significant 
rise, growing from 1% (EUR 1,820 million) to 12.3% (EUR 25,766 million) during the same period. 

Table 117: Exports and imports of motor vehicles and electric vehicles between EU27 and the rest of the world 
between 2018 and 2024 (EUR million, in current prices) 

Exports 

Total EU 

Motor vehicles 

Motor vehicles, with only electric motor for propulsion 
Road tractors for semi-trailers with only electric motor for 
propulsion 
Motor vehicles for the transport of goods with only electric 
motor for propulsion 

Imports 

Total EU 

Motor vehicles 

Motor vehicles, with only electric motor for propulsion 
Road tractors for semi-trailers with only electric motor for 
propulsion 
Motor vehicles for the transport of goods with only electric 
motor for propulsion 

2018 

2020 

2022 

2024 

2,058,470 

1,932,076 

2,570,215 

2,583,053 

177,799 

151,103 

196,808 

208,663 

1,820 

7,096 

21,693 

25,766 

NA 

NA 

NA 

NA  

16 

564 

115 

952 

1,910,414 

1,715,119 

3,005,720 

2,437,177 

68,986 

1,231 

NA 

NA 

60,288 

5,304 

NA 

NA  

76,041 

12,558 

1 

311 

91,634 

15,138 

2 

786 

Source: Comext database. EU trade since 2002 by CPA 2.2 & International trade of goods.  

161 

 
 
  
  
  
  
  
  
 
  
  
  
  
  
 
 
 
ANNEX 6: SME CHECK  

OVERVIEW OF IMPACTS ON SMES 

Relevance for SMEs  

The  initiative  is  considered  relevant  for  SMEs,  although  the  SMEs  are  only  indirectly  affected  in  the 
preferred policy option. 

(1) 

IDENTIFICATION OF AFFECTED BUSINESSES AND ASSESSMENT OF RELEVANCE 

Are SMEs directly affected?  In which sectors? 

No, SMEs are not directly affected by the preferred policy option.  

Estimated number of directly affected SMEs 

- 

Estimated number of employees in directly affected SMEs 

- 

Are  SMEs  indirectly  affected?  In  which  sectors?  What  is  the  estimated  number  of  indirectly 
affected SMEs and employees? 

Yes, SMEs are expected to be indirectly affected by the preferred policy option.  

Scale of SME involvement: SMEs are estimated to own a significant share of corporate fleets in the EU, 
although statistics are not available on the number of vehicles owned by SMEs. Based on stakeholders 
interviews, the share of corporate fleets belonging to SMEs is estimated at around 60% for cars, 70% for 
vans and 80% for lorries.  

Sectors affected: SMEs are expected to be indirectly affected across various sectors, notably in rentals, 
leasing, passenger transport services, logistics and road haulage. More broadly, all SMEs owning vehicles 
may be indirectly affected by the preferred policy option.  

Estimated number of most affected SMEs and employees: 
SMEs represent over 99% of total businesses in passenger and freight transport by land as well as rental 
and leasing of motor vehicles (see section 3 of Annex 5). A total of 1.1 million SMEs were operating in 
these sectors in 2023 (see Table 113 in Annex 5). Around 87% of companies operating in the road haulage 
sector and the vast majority of taxi companies are micro-enterprises227. 

227 Source: Eurostat. Enterprises by detailed NACE Rev. 2 activity and special aggregates [sbs_ovw_act]. 

162 

 
 
 
 
 
 
 
 
In terms of employment, in 2023 the SMEs in the renting and leasing of motor vehicles sector employed 
130,560 persons, while the SMEs in the passenger and freight transport by land sector 3.9 million persons 
(2.8 million persons in the haulage sector and 1.1 million persons in passenger land transport). Of this, 
micro-enterprises  in  the  renting  and  leasing  of  motor  vehicles  sector  employed  64,247  persons,  the 
haulage sector 1,057,289 persons and the passenger land transport sector 592,035 persons228.  

(2)  CONSULTATION OF SME STAKEHOLDERS 
How has the input from the SME community been taken into consideration? 

SMEs were involved in the consultation activities, further described in Annex 2 (‘Synopsis report’). Out of 
the  268  respondents  to  the  OPC,  158  (59%)  identified  as  SMEs.  More  specifically,  53  were  micro-
enterprises  (i.e.  1  to  9  employees),  54  were  small-enterprises  (i.e.  10  to  49  employees),  and  51  were 
medium-enterprises (i.e. 50 to 249 employees). In the CfE, 104 of the 179 respondents in the company 
and business category were SMEs. Of the 21 targeted interviews, 5 were with representatives of SMEs229. 
Most  of  the  remaining  interviews  were  conducted  with  large  organisations,  which  heavily  rely  on 
subcontracting carried out by SMEs.  

Are SMEs’ views different from those of large businesses?  

Out of the 179 respondents to the CfE identifying as companies or businesses, 104 stated they were SMEs. 
The views expressed by SMEs were somewhat similar to those of larger companies, depending on the 
topic. The responses of the CfE were not systematically disaggregated by company size230. However, an 
additional  qualitative  analysis  was  conducted  for SMEs,  allowing  partial  comparison  of their  positions 
with those of larger companies. 

ZEV mandates and flexibility: Most SMEs were not in favour of ZEV mandates, echoing the views of 
financial institutions, leasing companies, rental companies and road haulage operators. SMEs and other 
small  operators  repeatedly  called  for  gradual,  incentive-based  approaches  rather  than  rigid  obligations, 
stressing the need for flexibility and proportionality. 3.8% of respondents to the CfE (18 of 483) proposed 
SME-specific thresholds or simplified templates to ensure reporting remains feasible for smaller firms. 
The need for sectoral flexibility was also mentioned by companies making use of transport and logistics 
services (shippers, retailers, etc.), as well as road haulage operators. 

Infrastructure and operational constraints: SMEs highlighted that access to charging infrastructure is a 
major barrier to ZEV uptake in corporate fleets, echoing the views of logistics operators, electric vehicles 
and alternative-fuels refuelling and charging infrastructure providers, logistics services companies, rental 
companies, road haulage operators, and passenger transport services. Stakeholder groups with higher SME 
representation  (leasing,  finance)  placed  relatively  more  emphasis  on  upfront  and  financing  costs  while 
operational actors (haulage, logistics, rental) put more emphasis on cost implications of the inability to 
charge (under current duty cycles) and operational constraints. Overall, 54.4% of respondents to the CfE 
(259 of 483) identified the lack of charging infrastructure (public and depot) as a key barrier in the uptake 

228 Source: Eurostat. Enterprise statistics by size class and NACE Rev. 2 activity [sbs_sc_ovw]. Sectors are categorised 
using the NACE classification. The calculation of employees is based on the average number of employees in micro, 
small and medium sized companies. 
229 CLECAT, IRU, Muoversi, T4SM and UETR. 
230 Company-size breakdowns are available in aggregate (number of SMEs vs. total businesses) but not cross-analysed 
by specific question or issue. 

163 

 
 
 
 
of ZEVs in corporate fleets.  

Costs and financing: SMEs reported that they face disproportionate transition costs and lack the capital 
resources of larger companies. 8.7% of respondents to the CfE (26 of 483) mentioned that SMEs would be 
disproportionately  affected  by  ZEV  costs.  They  asked  for  simple,  easily  accessible  grants  or  fiscal 
incentives  and  warned  that  new  reporting  or  monitoring  requirements  could  create  excessive 
administrative burdens. 

Second-hand market: Several respondents to the CfE also noted that SMEs are expected to gain more 
from higher supply and lower-cost ZEV on the second-hand market. According to 26.1% of respondents 
to the CfE (124 of 483), faster new zero-emission vehicle uptake could increase used-vehicle supply and 
stabilise residual values, improving affordability for SMEs. However, 24.6% of respondents to the CfE 
(117 of 483) expressed concern about uncertain resale values and the early-stage nature of second-hand 
markets for ZEVs, noting that extended lease terms delay the entry of used ZEVs into the market. SMEs 
cautioned  that  mandates  could  worsen  this  imbalance  if  resale  confidence  and  price  certainty  are  not 
addressed. 

Incentives and fiscal treatment: Many SMEs saw clear environmental benefits from electrification but 
called for continued, well-designed fiscal support to ease investment costs and align phase-out timelines 
with infrastructure deployment and vehicle availability. 

Overall,  SMEs’  responses  reflected  similar  concerns  to  other  business  stakeholders,  e.g.  costs, 
infrastructure,  and  administrative  complexity.  SMEs  placed  greater  emphasis  on  proportionality, 
flexibility, and access to finance, while larger companies highlighted the need for regulatory clarity and 
long-term investment certainty. 

(3)  ASSESSMENT OF IMPACTS ON SMES 

What are the estimated direct impacts for SMEs of the preferred policy option?  

Qualitative assessment 

There are no direct impacts associated to the preferred policy option.  

Quantitative assessment 

There are no direct impacts associated to the preferred policy option. 

What are the estimated direct benefits/cost savings for SMEs of the preferred policy option? 

Qualitative assessment 

There are no direct benefits/costs savings associated to the preferred policy option. 

Quantitative assessment 

There are no direct benefits/costs savings associated to the preferred policy option. 

What are the indirect impacts of this initiative on SMEs?  

164 

 
 
Costs 

Adjustment costs: In the short term, the increased demand for new ZEVs by large companies is expected 
to reduce the availability of new ZEVs for SMEs, assuming that vehicle manufacturers do not exceed the 
minimum share of ZEVs in new registrations required to meet their emission reduction targets under the 
CO2  emission  performance  standards.  As  a  result,  a  higher  number  of  new  conventional  vehicles  is 
expected to be purchased by SMEs relative to the baseline, leading to higher fuel and other operation costs 
compared to the baseline. Adjustment costs for SMEs are estimated at EUR 16.1 billion in PO1A, EUR 
20.9 billion in PO1B and EUR 25.2 billion in PO1C, expressed as present value over 2029-2050 relative 
to the baseline.  

Increase in tax expenditure: In the short term, the increase in the number of new conventional vehicles 
and thus fuel costs for SMEs are also expected to result in higher fuel tax expenditures, estimated at EUR 
9.7 billion in PO1A, EUR 12.2 billion in PO1B and EUR 14.3 billion in PO1C, expressed as present value 
over 2029-2050 relative to the baseline.  

Benefits 

Adjustment  cost  savings:  In  the  short  term,  the  purchase  of  new  conventional  vehicles  by  SMEs  will 
result in lower capital costs relative to the baseline. In the medium to long term, as the availability of ZEVs 
in second-hand markets increases, the uptake of second-hand ZEVs by SMEs is expected to accelerate, 
leading  to  adjustment  cost  savings  due  to  lower  capital  costs,  fuel  costs  and  other  operation  costs.  As 
explained in section 6.1.1 (see Table 12), the total increase in zero-emission second-hand vehicles (cars, 
vans and lorries) is estimated at 721,000 on average per year over 2031-2050 relative to the baseline in 
PO1A, 1.1 million  in  PO1B  and  1.4 million in PO1C.  The  increase  in the  zero-emission second-hand 
lorries will benefit entirely to SMEs, of vans mostly to SMEs and of cars to both SMEs and citizens. The 
adjustment costs savings for SMEs are estimated at EUR 9.5 billion in PO1A, EUR 12.9 billion in PO1B 
and EUR 16.3 billion in PO1C. 

Reduction in tax expenditure: As SMEs start purchasing ZEVs from the second-hand market, they are 
expected to experience lower energy consumption due to the higher energy efficiency of ZEV and thus 
lower fuel tax expenditures. The reduction in tax expenditures is estimated at EUR 0.8 billion in PO1A, 
EUR  1.5  billion  in  PO1B  and  EUR  2.6  billion  in  PO1C,  expressed  as  present  value  over  2029-2050 
relative to the baseline. 

Net impacts  

Overall, the net costs for SMEs are estimated at EUR 15.6 billion in PO1A, EUR 18.7 billion in PO1B 
and EUR 20.5 billion in PO1C, expressed as present value over 2029-2050 relative to the baseline (see 
Table 24 in section 6.1.6).  

It should however be noted that although SMEs are expected to experience overall net costs, expressed as 
present value over 2029-2050 relative to the baseline, in the medium to longer term in PO1B and PO1C 
they are projected to experience net benefits, due to the higher ZEV uptake in the second-hand market. In 
addition, the net costs are estimated at up to EUR 21.1 per vehicle per year in PO1A, EUR 29.6 in PO1B 
and EUR 38.5 in PO1C (see Table 26 in section 6.1.6). 

(4)  MINIMISING NEGATIVE IMPACTS ON SMES 
Are SMEs disproportionately affected compared to large companies? If yes, are there any specific 

165 

 
 
subgroups of SMEs more exposed than others? 

The preferred policy option is estimated to result in net costs for SMEs, estimated in total at EUR 15.6 
billion in PO1A, 18.7 billion in PO1B and 20.5 billion in PO1C, expressed as present value over 2029-
2050 relative to baseline. As explained in section 3 of Annex 6, in terms of net costs per vehicle per year 
these are limited to up to EUR 21.1 in PO1A, EUR 29.6 in PO1B and EUR 38.5 in PO1C, while in the 
medium to long term in PO1B and PO1C SMEs are expected to experience net benefits.  

It  should  be  noted that the  SMEs  are  not directly targeted  by PO1A, PO1B  and PO1C.  The  net  costs 
estimated for SMEs are due to the assumption that vehicle manufacturers do not exceed the minimum 
share  of  ZEVs  in  new  registrations  required  to  meet  their  emission  reduction  targets  under  the  CO2 
emission performance standards and thus they reduce the availability of new ZEVs for SMEs. This is a 
conservative assumption that shows the upper bound costs estimates for SMEs.  

Have mitigating measures been included in the preferred option/proposal?  

PO1A, PO1B and PO1C do not target the SMEs, which are excluded from the scope of the targets.  

As explained above, the estimated indirect impacts represent the upper bound costs estimates under the 
assumption that vehicle manufacturers do not exceed the minimum share of ZEVs in new registrations 
required to meet their emission reduction targets under the CO2 emission performance standards and thus 
they reduce the availability of new ZEVs for SMEs. The SMEs are expected to benefit of the increase in 
the zero-emission vehicles in the second-hand market, even if this would not be able to full compensate for 
the additional costs.    

CONTRIBUTION TO THE 35% BURDEN REDUCTION TARGET FOR SMES 

Are there any administrative cost savings relevant for the 35% burden reduction target for 
SMEs? 

For the purpose of the ‘one in, one out’ approach and the Calculator of Administrative Costs (AC) & 
Administrative Burdens (AB), the SMEs are not expected to experience additional administrative costs 
or costs savings in PO1A, PO1B and PO1C.  

166 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 7: DISCARDED POLICY OPTIONS 

This annex provides more detailed explanations on the discarded policy options and the reasons why they 
were discarded. 

Discarded policy 
option 

(i) Voluntary 
commitments by large 
shippers and large 
fleets operators 

(ii) Commission 
Recommendations on 
the fiscal treatment of 
corporate vehicles 

Reason for discarding 

This option would entail facilitating a voluntary commitment by large operators to meet a 
minimum share of zero-emission vehicles by a given date. It would build on commitments 
already  set  by  certain  private  actors  on  a  voluntary  basis.  This  option  would  allow  the 
Commission to provide additional political visibility to those commitments and a supporting 
tool to monitor their implementation through purchase of data on commercial vehicles sales.  

This option was discarded because such an approach would fail to sufficiently address the 
identified  problems  and  problem  drivers.  Stakeholders  (especially  shippers  and  logistics 
users) criticised voluntary or non-binding approaches, noting that such option would transfer 
the risk to buyers without solving operational bottlenecks and would not create predictable 
demand for ZEVs. This option would neither reduce the existing fragmentation of national 
support  frameworks,  nor  create  better  conditions  in  terms  of  purchase  price,  TCO  or 
operational  conditions  for  corporate  ZEVs.  Furthermore,  this  option  would  also  fail  to 
provide  additional  certainty  to  vehicle  manufacturers  that  the  demand  would  materialise. 
Several respondents to the consultation activities stressed that market forces alone (without 
mandatory  measures)  already  determine  the  level  and  speed  of  clean-vehicle  uptake  and 
result in fragmented national policies. This option was therefore discarded on the basis of 
lack of effectiveness.  

This option would mandate the Commission to adopt Recommendations for Member States 
on the taxation of corporate vehicles, with the aim of encouraging a more favourable fiscal 
treatment of zero-emission corporate vehicles than of conventional ones.  

This option was discarded because, although it could partially address the relevant problems 
and  problem  drivers  by  reducing  fragmentation  of  national  support  and  improving  the 
economic  performance  of  corporate  ZEVs,  it  would  not  sufficiently  ensure  that  concrete 
action is taken, and impacts achieved. Out of the respondents to the CfE, 36.6% (174 of 
483),  including  a  few  public  authorities,  underlined  the  need  for  stronger  EU-level 
coordination  on  taxation  and  incentives,  noting  that  existing  tax  rules  and  incentives  are 
either insufficient, inconsistent across Member States, or volatile. The added value of these 
Recommendations would be limited compared to the promotion of the use of fiscal levers 
already presented in the Communication “Decarbonise corporate fleets”231 in March 2025, 
lacking additional weight or direct legal effect. Around one-third of the CfE respondents 
highlighted fiscal measures as a key barrier, with many SMEs and fleet operators stressing 
that  short-term  or  fragmented  incentives  undermine  investment  predictability.  Since  a 
Commission Recommendation would have no binding effect and could not ensure coherent 
or  stable fiscal treatment  across Member  States, this  option  was considered  not  effective 
enough, and therefore it was discarded. 

(iii) Harmonising the 

This option would harmonise the fiscal treatment of corporate vehicles, requiring Member 

231 COM(2025) 96 final 

167 

 
 
 
fiscal treatment of 
corporate vehicles to 
prevent Member 
States from providing 
financial incentives to 
corporate vehicles 
other than ZEVs 

States to set up  financial incentives  in  a way that excludes  corporate  vehicles other than 
ZEVs. From the year following adoption, Member States would be required to adapt their 
relevant financial and fiscal instruments and norms to comply with these requirements. This 
would  effectively  result  in  the  financial  treatment  of  any  conventional  vehicle  being  the 
same  irrespective  of  whether  that  vehicle  is  registered  by  a  legal  entity  or  by  a  physical 
person, while reserving any more favourable financial treatment to ZEVs.  

This  option  was  discarded  because  it  was  not  considered  to  meet  the  requirement  for 
proportionality and subsidiarity. It would heavily impact on Member States’ prerogatives in 
the area of fiscal policies. 

(iv) Targets for 
Member States based 
on the total number of 
corporate vehicles 
registered on their 
territory 

(v) Targets for 
Member States on 
share of ZEVs in new 
corporate 
registrations, with the 
same level of ambition 
for light-duty vehicles 
across all Member 
States 

(vi) Targets for 
Member States on 
share of ZEVs in new 
corporate 
registrations, with 
differentiated levels of 
ambition for heavy-

This option would set targets for Member States on corporate ZEVs, on the basis of  the 
number of corporate vehicles registered on their territory. This option, while sharing some 
similarities with PO1A, PO1B and PO1C, would be based on the overall stock of corporate 
vehicles,  instead  of  the  newly  registered  vehicles  during  a  given  year  as  in  the  retained 
policy options.  

This option was discarded because it would introduce significant uncertainty, due to the fact 
that the impact of national measures on the operation of fleets is less direct than on new 
vehicle acquisition. Furthermore, Member States would be exposed to the risk of missing 
their targets due to circumstances outside their control in a situation  such as, e.g., a large 
operator  closing  operations  in  their  territory,  or  deciding  to  phase  out  a  part  of  its  zero-
emission  fleet  faster  than  initially  planned232.  In  addition,  for  some  Member  States  a 
significant part of freight transport is performed by vehicles registered in another Member 
State. This option was therefore considered not sufficiently effective. Moreover, 16.2% of 
respondents to the CfE (77) identified administrative burden as a key barrier, and several 
stakeholders, including public authorities and leasing companies, cautioned against complex 
or  disproportionate  reporting  frameworks.  Stakeholders,  particularly  SMEs  and  fleet 
operators,  underlined  that  any  new  reporting  or  monitoring  obligations  should  remain 
proportionate. This option would entail higher compliance and administrative costs due to 
the need to ensure additional monitoring of the total fleet on a Member State’s territory and 
was therefore discarded on the basis of proportionality and not sufficient effectiveness. 

This option would be similar to PO1 but without differentiating between Member States in 
terms  of  the  level  of  ambition  for  light-duty  vehicles.  Several  respondents  to  the  CfE 
underlined  the  diversity  of  national  starting  points  and  market  maturity,  noting  that 
infrastructure and ZEV availability are more advanced in some Member States than others. 
This  approach  would  fail  to  adequately  take  into  account  each  Member  State’s  starting 
point,  national  circumstances,  and  specific  transport  and  economic  characteristics.  This 
option was therefore discarded on the basis of subsidiarity and proportionality. 

This option would be similar to PO1, but with a differentiation between Member States in 
terms  of  the  level  of  ambition  for  heavy-duty  vehicles.  For  heavy-duty  vehicles,  the 
differences  in  levels  of  ambition  could  create  challenges  for  fair  competition  between 
transport operators in different Member States. Cross-border competitiveness concerns and 
the need for level playing field across the internal market were highlighted by logistics and 
haulage stakeholders in the CfE. This option was therefore discarded on the basis of lack of 

232 This happened for example in the case of Hertz, which announced significant changes in its fleet strategy and re-sold 
initially  planned: 
its  electric  vehicles  between  2023  and  2024,  well  before 
a 
https://www.electrive.com/2024/04/26/hertz-plans-to-phase-out-10000-more-electric-cars-in-2024/  

share  of 

large 

168 

 
 
duty vehicles across 
Member States    

(vii) Targets for 
Member States on the 
share of zero-emission 
vehicles (cars, vans 
and lorries) in yearly 
new corporate 
vehicles registrations, 
including by SMEs 

(viii) Binding 
minimum targets on 
the share of zero-
emission vehicles for 
specific types of 
corporate fleets 

(ix) Binding minimum 
targets on the share of 
zero-emission vehicles 
for corporate fleets 
above a certain size 

coherence with the internal market principles and lack of effectiveness.  

This option would be similar to PO1, but  with a broader scope, including also  corporate 
vehicles registered by SMEs and not only by large companies.  

SMEs would be disproportionately affected due to the difficulty in ensuring the access to 
finance required for the higher purchase costs of ZEVs, as they are generally considered less 
bankable and face higher revenue risks. This option was therefore discarded on the basis of 
proportionality.   

This option would set binding minimum targets on the share of zero-emission vehicles for 
specific types of corporate fleets (e.g. taxi fleets, rental companies, company cars) across the 
EU.  The  owners/operators  of  the  fleets  within  the  scope  (e.g.  all  fleets  of  more  than  a 
specified number of lorries, all van rental fleets, all taxi fleets of more than 20 cars, etc.) 
would be required to ensure that, by a predetermined year, a given % of the vehicles in their 
fleet are zero-emission, or that a given % of the new vehicles procured in a specific year for 
that fleet are zero-emission. In the CfE, several SME and operator respondents cautioned 
against  rigid  ZEV  mandates  and  called  instead  for  gradual,  incentive-based  approaches. 
Their  feedback  indicates  that  binding  targets  for  specific  fleet  types  could  be  seen  as 
disproportionate and administratively burdensome. 

The option would also need to introduce a definition of each type of fleet to be included, 
ensuring that it is broad enough to cover all the fleets of that kind, while minimising the risk 
that fleets of other kinds fall within the scope. In this case as well, the option would need to 
set rules on what qualifies a “fleet” in the cases of e.g. subsidiaries of the same company, or 
different  legal  entities  within  the  same  group,  or  under  the  same  ownership,  controlling 
different  vehicles.  In  order  to  ensure  a  sufficient  coverage  and  minimise  the  risk  of 
avoidance, this option would need to include all fleets of the identified categories, without 
excluding SMEs (as a company can still be a SME but operate a bigger fleet). While this 
option would allow a targeted intervention focused on specific types of fleets (provided the 
scope  could  be  defined  with appropriate details and clarity),  this  would  also entail lower 
benefits, due to the more limited scope.  

This option was discarded because the level of complexity required for the definition of the 
scope and the allocation of the obligations to different legal entities would be high, and there 
would  be  a  very  high  risk  of  loopholes  allowing  avoidance  of  the  obligations  or  of 
unintended consequences. For example, setting mandatory targets e.g. for leasing companies 
might result in a shift from leasing to purchase of vehicles, or from operational to financial 
leasing; a target for taxi companies and/or ride hailing companies that own the vehicles of 
their fleet might damage their competitiveness compared to ride hailing companies using a 
higher  share  of  their  drivers’  private  vehicles.  Furthermore,  given  the  complexity  and 
expected  high administrative burden,  and the limited  scope, the  overall  effectiveness and 
efficiency of this option were expected to be low.  

This option would set binding minimum targets on the share of zero-emission vehicles for 
all corporate fleets of more than a predetermined amount of vehicles across the EU. The 
owners/operators of those fleets would be required to ensure that, by a given year, a given % 
of  the  vehicles  in  their  fleet  are  zero-emission,  or  that  a  given  %  of  the  new  vehicles 
procured  in  a  certain  year  for  that  fleet  are  zero-emission.  Some  respondents  to  the  CfE 
(4.2%; 20) warned against onerous reporting and changing rules and reporting burdens that 
add risk or cost.  

All companies registered in the EU, across all economic sectors, would need to report yearly 
about  the  average  number  of  vehicles  they  owned/operated  during  that  year  (by  vehicle 
category: cars, vans, trucks), either to demonstrate that they are outside the scope, or, if they 

169 

 
(x) Binding minimum 
targets on the share of 
zero-emission vehicles 
for corporate fleets of 
large companies, 
based on vehicle stock 

(xi) Prohibiting the 
registration of new 
conventional 
corporate vehicles 
after a certain date 

are in the scope, to confirm that the share of zero-emission  vehicles in the total number 
meets the legal requirement. Member States would be required to compile reports from all 
companies on their territory and submit them to the Commission.  By imposing complex 
reporting  requirements  on  every  company  established  in  the  EU,  this  option  would  be 
expected to generate disproportionate administrative burden. Furthermore, by defining the 
scope  based  on  the  number  of  vehicles,  this  option  would  entail  a  significant  risk  of 
imposing  stringent ZEV targets on  companies and operators for  whose use  case suitable 
zero-emission  options  are  not  yet  sufficiently  available  (for  instance,  some  companies 
performing specialised transport such as some long-haul refrigerated transport or transport 
of  chemicals,  or  focused  on  specialised  vehicles  such  as  cement  mixers)  with  a 
disproportionate  negative  impact on those operators.  This  option  was therefore discarded 
because  it  would  generate  an  extremely  high  level  of  administrative  burden,  not  being 
proportionate, and due to its lack of efficiency. 

This  option  would  apply  to  all  large  companies  established  in  the  EU.  They  would  be 
required to report yearly on the average number of vehicles they owned during that year (by 
vehicle category: cars, vans, lorries), and ensure that at least a certain share of those are zero-
emission  vehicles.  Member  States  would  be  required  to  compile  reports  from  all  large 
companies on their territory and submit them to the Commission.  

This option would entail a very high risk of avoidance of the obligations and of unintended 
consequences. For example, companies within the scope could avoid the obligation to meet 
the targets by making more extensive use of solutions such as leasing or sub-contracting. 
This could in turn result in a higher share of vehicles registered by smaller operators, which 
face higher barriers to the switch to ZEVs, thus undermining the objective of decarbonising 
road  transport.  This  option  would  also  impose  complex  reporting  requirements  on  every 
large company established in the EU, generating a disproportionate level of administrative 
burden.  There  would  also  be  a  significant  risk  of  imposing  stringent  ZEV  targets  on 
companies  and  operators  for  whose  use  case  suitable  zero-emission  options  are  not  yet 
sufficiently  available,  resulting  in  a  disproportionate  negative  impact  on  those  operators. 
This option was therefore discarded because of not sufficient proportionality, effectiveness, 
and efficiency. 

This option would prohibit the registration of new conventional corporate vehicles after a 
certain date. An end date for the registration of new corporate vehicles would be set in the 
legislation, using the identified technology (e.g. conventional vehicles, or non zero-emission 
vehicles). From that date onwards, it would not be possible for any legal entity to register a 
new vehicle of that type, while physical persons would still be allowed to do so. The criteria 
could be made progressively more stringent (e.g. conventional vehicles banned from 2029, 
hybrid  vehicles  from  2030,  etc.).  This  policy  option  would  not  require  setting  stringent 
targets or monitoring and reporting obligations for companies, and it would therefore entail 
very limited administrative burden. By focusing on technologies to be prohibited instead of 
mandating  zero-emission  options,  it  would  allow  companies  to  plan  the  progressive 
decarbonisation of their fleets over a longer timeframe.  

This  option  was  discarded  because  a  complete  ban  on  identified  technologies  for  new 
corporate  vehicle  registrations  would  provide  no  flexibility  and  entail  significant  risk  of 
unintended  consequences  for  specific  fleets  and  use  cases  where  suitable  zero-emission 
alternatives  are  not  yet  sufficiently  available,  such  as  some  companies  performing 
specialised transport such as some long-haul refrigerated transport or transport of chemicals, 
or  focused  on  specialised  vehicles  such  as  cement  mixers,  or  remote  outdoor  activities.  
Several stakeholders in the CfE cautioned against rigid or mandatory measures, stressing 
that any new requirements should reflect current market realities, infrastructure availability, 
and  technology  readiness.  SMEs  and  logistics  operators  requested  phased  and  realistic 
implementation timelines, warning that premature bans could create significant operational 

170 

 
(xii) Targets for other 
vehicles than zero-
emission 

(xiii) Inclusion of 
buses and coaches 

and investment challenges. 

This option would also significantly limit vehicle manufacturers’ flexibility in meeting CO2 
emission  performance  standards,  especially  for  heavy-duty  vehicles  where  corporate 
vehicles represent the totality of the market. For example, a ban on diesel lorries from 2030 
would effectively force lorries manufacturers to either fully switch to zero-emission options 
already from 2030, or to convert their entire non-ZEV supply chain to alternatives such as 
plug-in hybrid electric vehicle or natural gas vehicles. Consequently, this option would fail 
to ensure sufficient external coherence, especially regarding the CO2 emission performance 
standards for heavy-duty vehicles set out in Regulation 2019/1242. Moreover, the scale of 
investment required for such a rapid industrial conversion is unlikely to be mobilised within 
the  expected  timeframe,  creating  a  serious  risk  of  severe  market  disruption  in  the  EU 
automotive sector. This option was therefore discarded because of lack of efficiency and 
proportionality. 

This option considered setting targets for low- and zero-emission vehicles under the options 
presented above.  

This option was discarded because such an approach would be inconsistent with existing 
legislation: the Clean Vehicles Directive already sets targets for zero-emission vehicles only 
in  the  light-duty  segment,  and  sub-targets  for  zero-emission  vehicles  for  urban  buses.  It 
would also fail to contribute to the objectives of making ZEVs more attractive and would 
not  give  sufficient  certainty  to  vehicle  manufacturers.  Additionally,  Member  States  have 
been decreasing public support for company-car  plug-in hybrids citing higher real-world 
fuel,  as  these  vehicles  are  charged  and  driven  electrically  far  less  than  assumed  with  an 
insufficient electric only range233. This option is therefore discarded because of the lack of 
external coherence as well as lack of effectiveness.  

This option considered including buses and coaches (vehicles of category M2 and M3) in 
the scope of the initiative. This would result in a broader scope. The use cases and market 
dynamics  for  buses  and  coaches  are  significantly  different  than  those  of  cars,  vans,  and 
lorries.  Buses  and  coaches  are  used  for  collective  transport,  and  in  particular  public 
transport. Public procurement plays a leading role on the market for vehicles and services in 
this segment (in particular for buses the impact assessment accompanying the 2019 revision 
of  the  Clean  Vehicles  Directive  estimated  that  it  covered  more  than  70%  of  new 
registrations) and national targets for the public procurement of zero-emission urban buses 
are  already  set  by  the  Clean  Vehicles  Directive.  Because  that  Directive  covers  also  the 
procurement of services, any measure  targeting  urban buses  would carry  serious risks of 
duplication, with the same vehicle being subject to two parallel demand-side measures: one 
for  the  transport  operator  under  this  initiative  and  one  for  the  contracting  entity  or 
contracting authority procuring the services, under the Clean Vehicles Directive. This would 
in turn impact the interactions between different services procured and provided using buses 
and coaches, for example in the case of urban, peri-urban, and regional public transport. The 
support for measures addressing coaches was low in both the 2024 OPC and in the 2025 
CfE. In the CfE, the arguments provided by respondents highlighting the benefits and need 
for EU intervention generally focused on cars, vans, and lorries, while several respondents 
highlighted the challenges of operating zero-emission coaches. Buses and coaches are also 
treated differently under the CO2 emission performance standards for heavy-duty vehicles: 
manufacturers have progressively higher mandates for a minimum share of zero-emission 
urban  buses  in  new  registrations  (90%  in  2030  and  100%  in  2035),  while  coaches  are 
subject to emission reduction targets similar to lorries. For these reasons, the inclusion of 
buses and coaches within the scope of the initiative would risk creating inconsistencies and 

233 https://publications.tno.nl/publication/34622243/22jtHB/TNO-2016-R10938.pdf  

171 

 
 
(xiii) Inclusion of 
criteria on vehicle-to-
grid capability 

overlaps,  both  within  the  initiative  itself  and  in  its  interactions  with  the  existing  legal 
framework;  this  option  has  therefore  been  discarded  on  the  basis  of  considerations  of 
internal and external coherence.   

This option would require (some of) the electric vehicles counted for the targets under the 
options above to be capable of bi-directional charging234. 

The  benefits  of  such  a  requirement  would  vary  significantly  from  one  fleet  to  another, 
depending  on  the  type  of  vehicle  and  its  use  case.  As  noted  by  some  CfE  respondents, 
solutions  should  take  into  account  diversity  of  fleet  types.  For  example,  large  shippers 
indicate  that  the  lorries  they  use  for  long-distance  transport  between  major  hubs  do  not 
usually spend more time parked than is strictly necessary to recharge, so there would be no 
opportunity  to  take  advantage  of  this  capability.  This  requirement  would  also  result  in 
additional purchase costs – further exacerbating the main identified barrier to the switch to 
ZEVs,  i.e.  their  high  CAPEX  –  and  significantly  higher  administrative  burden  to  prove 
compliance with targets. This option was therefore discarded because of lack of efficiency 
and proportionality.  

234 Bi-directional charging allows electric vehicles to both draw electricity from the grid to charge their batteries, and 
feed electricity back from their batteries into the grid when needed. 

172 

 
 
 
ANNEX 8: MODULATION OF THE TARGETS FOR CARS AND VANS 

This annex presents the targets for Member States, calculated by multiplying the EU-level targets in section 
5.2.3 under the different policy options by each Member State’s modulation factor presented in section 5.2.3. 

PO1A / PO2A 

Table 118: Minimum target level for zero-emission new corporate cars registrations by large companies (share 
of new registrations by large companies) in PO1A/PO2A 

From 2035 onwards 
100%, resulting from the CO2 
emission performance 
standards  

Country 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

2029  

46% 

46% 

25% 

25% 

28% 

25% 

46% 

25% 

46% 

42% 

42% 

25% 

25% 

46% 

25% 

25% 

25% 

46% 

46% 

46% 

25% 

35% 

25% 

25% 

25% 

25% 

46% 

2030 

85% 

85% 

46% 

46% 

52% 

46% 

85% 

46% 

85% 

78% 

78% 

46% 

46% 

85% 

46% 

46% 

46% 

85% 

85% 

85% 

46% 

65% 

46% 

46% 

46% 

46% 

85% 

Table  119:  Minimum  target  level  for  zero-emission  new  corporate  light  commercial  vehicles  registrations  by 
large companies (share of new registrations by large companies) in PO1A/PO2A 

Country 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

2029  

33% 

33% 

18% 

18% 

20% 

2030 

72% 

72% 

39% 

39% 

44% 

From 2035 onwards 
100%, resulting from the CO2 
emission performance 
standards  

 
 
 
From 2035 onwards 

Country 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

PO1B / PO2B 

2029  

18% 

33% 

18% 

33% 

30% 

30% 

18% 

18% 

33% 

18% 

18% 

18% 

33% 

33% 

33% 

18% 

25% 

18% 

18% 

18% 

18% 

33% 

2030 

39% 

72% 

39% 

72% 

66% 

66% 

39% 

39% 

72% 

39% 

39% 

39% 

72% 

72% 

72% 

39% 

55% 

39% 

39% 

39% 

39% 

72% 

Table 120: Minimum target level for zero-emission new corporate cars registrations by large companies  (share 
of new registrations by large companies) in PO1B/PO2B 

From 2035 onwards 
100%, resulting from the CO2 
emission performance 
standards  

Country 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

2029  

59% 

59% 

32% 

32% 

36% 

32% 

59% 

32% 

59% 

54% 

54% 

32% 

32% 

59% 

2030 

91% 

91% 

49% 

49% 

56% 

49% 

91% 

49% 

91% 

84% 

84% 

49% 

49% 

91% 

174 

 
 
 
From 2035 onwards 

Country 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

2029  

32% 

32% 

32% 

59% 

59% 

59% 

32% 

45% 

32% 

32% 

32% 

32% 

59% 

2030 

49% 

49% 

49% 

91% 

91% 

91% 

49% 

70% 

49% 

49% 

49% 

49% 

91% 

Table  121:  Minimum  target  level  for  zero-emission  new  corporate  light  commercial  vehicles  registrations  by 
large companies (share of new registrations by large companies) in PO1B/PO2B 

From 2035 onwards 
100%, resulting from the CO2 
emission performance 
standards  

Country 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

2029  

46% 

46% 

25% 

25% 

28% 

25% 

46% 

25% 

46% 

42% 

42% 

25% 

25% 

46% 

25% 

25% 

25% 

46% 

46% 

46% 

25% 

35% 

25% 

25% 

25% 

25% 

2030 

78% 

78% 

42% 

42% 

48% 

42% 

78% 

42% 

78% 

72% 

72% 

42% 

42% 

78% 

42% 

42% 

42% 

78% 

78% 

78% 

42% 

60% 

42% 

42% 

42% 

42% 

175 

 
 
 
Country 

Sweden 

2029  

46% 

2030 

78% 

From 2035 onwards 

PO1C / PO2C 

Table 122: Minimum target level for zero-emission new corporate cars registrations by large companies (share 
of new registrations by large companies) in PO1C/PO2C 

From 2035 onwards 
100%, resulting from the CO2 
emission performance 
standards  

Country 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

2029  

65% 

65% 

35% 

35% 

40% 

35% 

65% 

35% 

65% 

60% 

60% 

35% 

35% 

65% 

35% 

35% 

35% 

65% 

65% 

65% 

35% 

45% 

35% 

35% 

35% 

35% 

65% 

2030 

98% 

98% 

53% 

53% 

60% 

53% 

98% 

53% 

98% 

90% 

90% 

53% 

53% 

98% 

53% 

53% 

53% 

98% 

98% 

98% 

53% 

70% 

53% 

53% 

53% 

53% 

98% 

Table  123:  Minimum  target  level  for  zero-emission  new  corporate  light  commercial  vehicles  registrations  by 
large companies (share of new registrations by large companies) in PO1C/PO2C 

Country 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus 

2029 

59% 

59% 

32% 

32% 

36% 

2030 

85% 

85% 

46% 

46% 

52% 

176 

From 2035 onwards 
100%, resulting from the CO2 
emission performance 
standards  

 
 
 
 
From 2035 onwards 

Country 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

Latvia 

Lithuania 

Luxembourg 

Malta 

Netherlands 

Poland 

Portugal 

Romania 

Slovakia 

Slovenia 

Spain 

Sweden 

2029 

32% 

59% 

32% 

59% 

54% 

54% 

32% 

32% 

59% 

32% 

32% 

32% 

59% 

59% 

59% 

32% 

45% 

32% 

32% 

32% 

32% 

59% 

2030 

46% 

85% 

46% 

85% 

78% 

78% 

46% 

46% 

85% 

46% 

46% 

46% 

85% 

85% 

85% 

46% 

65% 

46% 

46% 

46% 

46% 

85% 

177 

 
 
 
 
 
 
 
 
ANNEX 9: MONITORING AND EVALUATION  

The  Commission  services  will  monitor  the  implementation  and  effectiveness  of  this  initiative  through  a 
number of actions and a set of core indicators that will measure progress towards achieving the objectives. 
Five years after the implementation date of the legislation, the Commission services should carry out an 
evaluation to verify to what extent the objectives of the initiative have been reached.  

The  primary  references  for  assessing  the  uptake  of  ZEVs  in  the  corporate  segment  and  for  monitoring 
progress toward the initiative’s objectives will be  vehicle registration data to be submitted by Member 
States, data from the European Alternative Fuels Observatory (EAFO), and from Eurostat, as well as 
existing reporting by Member States under the Alternative Fuels Infrastructure Regulation (AFIR). 
This will allow the Commission to monitor overall fleet greening trends and identify gaps or shortcomings. 

As  regards  Specific  Objective  1  (Stimulate  the  demand  for  ZEVs  in  the  corporate  segment),  the  main 
milestone to achieve is the increase of the share of ZEVs in new corporate vehicle registrations. This will be 
mainly achieved through Member States’ annual reports on corporate fleets composition. These reports, 
which will contain the number of corporate vehicles registered by large companies and the share of ZEVs 
thereof, extracted from the national vehicle registries, will be submitted   in the framework of the central 
register for CO2 standards for vehicles maintained by European Environment Agency (EEA). 

Concerning  Specific  Objective  2  (Reduce  fossil  fuels  expenditures  in  the  road  transport  sector),  the 
monitoring of the advancement towards the objective will be based on the annual data made available by 
Member States on energy statistics. Namely, the identified indicator is: 

•  Final energy consumption in the road transport sector (by fuel type) in the EU and by Member State. 

Finally, the monitoring of the achievement of Specific Objective 3 (Accelerate the ZEV availability on the 
second-hand market) will entail a combination of sources to derive the needed indicators: 

•  Share of ZEVs in registrations of second-hand vehicles in Member States 
•  Average age of corporate ZEVs entering the second-hand market 

In this context, the following information needs to be collected: 

•  Data  on  the  share  of  ZEVs  in  registrations  of  second-hand  vehicles,  and  the  average  age  of 
corporate ZEVs entering the second-hand market will be used to assess the effects of the initiative 
on the second-hand market and help monitor the spread of cleaner vehicles to private users and SMEs. 
This  information  should  be  compiled  through  dedicated  studies  conducted  for  the  European 
Commission and made publicly available through the EAFO. 

The links between specific objectives, operational objectives, indicators and data sources is presented in the 
table below. 

Table 124: Link between specific objectives, operational  objectives, indicators for monitoring and related data 
sources 
Specific objective  

Operational objectives 

Data sources 

Indicators 

Stimulate  the  demand  for 
the  corporate 
ZEVs 

in 

•  Increase  the  share  of 
ZEVs  in  new  corporate 

•  Number 
emission 

of 

zero-
corporate 

• Registration  figures  by 
each Member State on an 

 
 
 
Specific objective  

Operational objectives 

Indicators 

Data sources 

segment 

vehicle registrations. 

vehicles registered  

annual basis 

fossil 

fuels 
Reduce 
expenditures  in  the  road 
transport sector 

•  Support  the  shift  from 
conventional  vehicles to 
ZEVs  within  corporate 
fleets 

the 

Accelerate 
ZEV 
availability  on  the  second-
hand market 

•  Promote  circularity  and 
affordability  of  ZEVs 
through  a  more  active 
second-hand 
ZEV 
market 

•  Final 

energy 
consumption 
the 
in 
road  transport  sector 
(by  fuel  type)  in  the 
EU  and  by  Member 
State 

•  Share  of  zero-emission 
vehicles  in  registrations 
of  second-hand  vehicles 
in Member States 

•  Average age of corporate 
the 

ZEVs 
second-hand market 

entering 

• Annual data submitted to 
line  with 
in 
Eurostat 
Regulation 
(EC) 
1099/2008  on  energy 
statistics 

• Study to analyse progress 
in uptake of ZEVs in the 
second-hand 
vehicle 
markets in each Member 
State  for  the  European 
Commission, to be made 
available 
the 
Commission's  European 
Alternative 
Fuels 
Observatory (EAFO) 

through 

• Eurostat  /  Member  State 

registration data 

179 

 
 
 
 
 
 
 
ANNEX 10: INCENTIVES FOR ZERO-EMISSION CORPORATE VEHICLES AT 
NATIONAL LEVEL 

The following table presents an overview of the main incentives for corporate ZEV across Member 
States. 

Table 125: Overview of corporate ZEV incentives across Member States235 

MS 

Corporate purchase 
grant (cars) 

Registration / 

Ownership/ 

Acquisition tax relief for 
BEVs 

Annual tax relief for 
BEVs 

Company car benefit-
in-kind (BIK) 
advantage for EVs 

Corporate VAT 
deductibility  

AT 

Not federal (but Länder 
business grants) 

Yes (BEVs exempt from 
registration tax) 

No 

Yes (preferential BIK 
versus ICE) 

Full depreciation; 
standard VAT reclaim 

BE 

No national BEV grant; 
regional charging support 

Yes (registration tax 
exemptions in 
Flanders/Brussels) 

Yes (lower or zero 
annual tax) 

Yes (BIK advantage) 

100% deductibility until 
12/2026; reduce to max 
67.5% by 2031 

BG 

No 

Partial 
(registration/product tax 
relief) 

HR 

Yes (new 2025 grant aimed 
solely at corporate 
vehicles) 

Yes (CO₂-based; BEVs 
exempt) 

Partial (local fee 
reductions) 

Neutral/limited 

Standard VAT/corporate 
tax 

Yes (lower annual tax) 

Partial/neutral 

Standard VAT 

CY 

Yes (including specialized 
for taxis) 

Yes (favourable 
registration tax) 

Yes (road tax linked to 
CO₂) 

Partial/neutral 

Standard VAT 

CZ 

DK 

EE 

FI 

No 

No 

No 

No 

Yes (registration/road tax 
relief) 

Yes (reduced 
ownership charges) 

Partial/neutral 

Standard VAT; 
accelerated depreciation 
for charging 

Yes (reduced registration 
tax for BEVs) 

Yes (lower 
ownership/green tax) 

Neutral 

Standard VAT 

Yes (favourable 
registration tax) 

Yes (ownership tax 
reductions) 

Neutral/partial 

Standard VAT 

Yes (zero registration tax)  Yes (lower annual tax)  Yes (favourable BIK) 

Standard VAT; employer 
charging advantages 

FR 

Yes (bonus for SMEs and 
increased for EU produced) 

Yes (malus/bonus; BEVs 
exempt) 

Yes (local ownership 
relief) 

Yes (70% BIK 
reduction, cap EUR 
4,582 for 2025-2027) 

Standard VAT; 
accelerated depreciation 

DE 

No 

Yes (zero registration tax) 

Yes (exemption until 
12/2025) 

Yes (0.25–0.5% BIK) 

New 2025: 
super‑depreciation for 
electric vehicles 

EL 

Yes (grants) 

Yes (registration relief) 

Yes (circulation tax 
relief) 

Yes (favourable BIK 
tiers) 

Reduced VAT rate 

235  In  the  table  VAT  stands  for value  added  tax,  BIK  stands  for  benefit  in  kind,  ICE  for  internal  combustion  engine 
vehicle, BEV for battery electric vehicle.  

 
 
 
HU 

Yes (periodic grants, 
specific for companies in 
2025) 

Yes (registration/excise 
duties relief) 

Yes (ownership tax 
reductions) 

Partial/neutral 

Standard VAT; higher 
depreciation caps 

IE 

IT 

Yes (commercial vehicles 
higher grants) 

Yes (registration tax)  Yes (lower motor tax) 

Yes (temporary BIK 
relief bands) 

VAT reclaim limited; 
leasing advantages 

Yes (grants in 2025 
increased for SMEs) 

Yes (regional registration 
tax relief) 

Yes (5‑years exemption 
then reduction) 

Yes (favourable BIK) 

Standard VAT; higher 
depreciation caps 

LV 

No 

Yes (registration tax 
relief) 

Yes (annual tax 
reductions) 

Partial/neutral 

Standard VAT 

LT 

Yes 

Yes (registration relief) 

Yes (ownership 
reductions) 

Yes 

Standard VAT, 

Companies can claim up 
VAT  

LU 

Yes (purchase bonus, 
linked to energy efficiency) 

Yes (favourable 
registration tax) 

Yes (lower annual tax) 

Yes (BIK 0.5–0.6% vs 
2%) 

Standard VAT 

MT  Yes (including scrappage) 

Yes (registration 
exemptions) 

Yes (lower annual tax) 

Partial/neutral 

Standard VAT 

NL 

No  

Yes (tax on vehicles EUR 
0) 

Yes (exemption) 

Yes (lower tax 
surcharge for private 
use of a company car, 
with cap) 

Standard VAT 

PL 

PT 

RO 

SK 

SI 

Yes (grants for 
microenterprises only) 

Yes (excise/registration 
relief) 

Yes (lower ownership 
taxes) 

Partial/neutral 

VAT 50–100%; higher 
depreciation caps 

No 

Yes (vehicle tax 
exemption) 

Yes (vehicle circulation 
tax exemption) 

Yes (favourable BIK 
valuation) 

Fully deduced VAT ≤ 
EUR 62,500; no extra 
corporate car tax 

Yes  

Yes (registration relief) 

No 

Yes (registration relief) 

Yes (ownership taxes 
reduced) 

Yes (ownership taxes 
lower) 

Partial/neutral 

Standard VAT 

Partial/neutral 

Standard VAT 

Yes (part specific for 
companies) 

Yes (registration relief) 

Yes (annual tax 
reductions) 

Partial/neutral 

Standard VAT 

ES 

Yes (until 12/2025) 

Yes (registration 
exemption) 

Yes (ownership tax 
reduced locally) 

BIK lower for vehicles 
under EUR 40,000 

Corporate income tax 
deduction (15%) until 
end‑2025 

SE 

No purchase grant 

Same for all vehicles  Yes (lower annual tax) 

Yes (from 2025: SEK 
350,000 BIK 
deduction, max 50%) 

Standard VAT 

181