COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE 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) 1061 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE 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) 1060 final}  
 
 
A.  Need for action  

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

This initiative seeks  to  boost  the uptake of  zero-emission vehicles (ZEV) in corporate fleets  of 
cars,  vans  and  lorries.  Corporate  vehicles  represent  around  58%  of  new  registrations  of  cars, 
around 90% of new registrations of vans and virtually all new registrations of lorries in the EU. 
Corporate cars typically have significantly higher yearly mileage than cars owned by citizens and 
reach  the  second-hand  market  much  faster,  which  is  very  relevant  considering  that  75%  of  car 
registrations are second-hand registrations. Corporate fleets such as rental and leasing car fleets, 
company cars, and logistics fleets have a significant potential to accelerate the ZEV uptake, which 
will help  reduce transport emissions,  boost the  competitiveness of the  EU  automotive industry, 
and ensure a fair transition. This potential, however, remains underexploited.  

The first problem that the initiative aims to address  concerns the current low share of  ZEVs in 
corporate fleets (i.e. 17% of new registrations for cars, 8% for vans and 3.7% for lorries in the first 
half of 2025). The share of ZEVs in rental fleets is significantly below the market average, but the 
share in leasing fleets, corporate cars, logistics fleets and true fleets such as taxis and ride-hailing 
is also insufficient.   

The second problem addressed by the initiative is the insufficient availability of affordable ZEVs 
for citizens and SMEs. The portfolio of zero-emission car models is still mostly focused on the 
higher end of the market; smaller, more affordable models have started to enter the market only 
recently. The higher purchase cost of new ZEVs represents a significant barrier to their uptake, 
resulting in missed opportunities for savings on the total cost of ownership and competitiveness, 
when this higher purchase cost is not addressed through tailored financial solutions. Furthermore, 
ZEVs  availability  on the  second-hand  vehicle market  is still limited, due to the  relatively short 
time  since  their  increased  uptake  in  terms  of  new  registrations.  This  hinders  consumers’  and 
SMEs’  capacity  to  benefit  from  potential  savings  offered  by  ZEVs.  Corporate  cars  reach  the 
second-hand market much faster than cars purchased by citizens. Rental cars are typically re-sold 
within one year, and leased vehicles within 3-5 years, and could therefore play a critical role in 
accelerating the availability of second-hand ZEVs. Similarly, 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, so the share of ZEVs in new registrations by large companies is a critical factor 
in determining the availability of affordable ZEVs for SMEs and smaller logistics operators. 

What should be achieved?  

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,  in  line  with  the  European  Green  Deal,  the  Sustainable  and  Smart  Mobility 
Strategy  and  the  Competitiveness  Compass.  A  shift  towards  zero-emissions  road  transport  is 
essential  to  the  EU’s  economy-wide  greenhouse  gas  emissions  reduction  targets,  and  for  the 
global competitiveness of the EU automotive sector, as clearly noted in the Clean Industrial Deal 
and particularly in the Industrial Automotive Action Plan.  

The  initiative  will  contribute  to  this  general  objective  by  pursuing  three  specific  objectives 
designed  to  address  the  two  problems  identified:  (1) stimulate  the  demand  for  ZEVs  in  the 
corporate  segment;  (2) reduce  fossil  fuels  expenditures  in  the  road  transport  sector; and 
(3) accelerate the ZEV availability on the second-hand market.   

1 

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

A rapid increase in ZEVs’ demand in corporate vehicles across the EU is necessary, and national 
measures alone will lead to an insufficient result. Without an overall regulatory push at the EU 
level  ensuring  that  Member  States  take  sufficient  action  in  order  to  reach  a  common,  but 
differentiated ambition level, ZEVs demand will not be sufficiently stimulated, and a patchwork 
of  insufficient  actions  may  disadvantage  fleets  operating  across  borders  and  limit  the  efficient 
allocation of ZEVs in the internal market.  

EU  level  action  will  ensure  greater  market  certainty  regarding  the  demand  for  ZEVs  from 
corporate  fleet  operators  across  the  EU,  sending  a  necessary  market  signal  for  vehicle 
manufacturers as well as charging infrastructure providers. It will also ensure a faster impact on 
market build-up everywhere in the EU, thanks to clearer and harmonised market signals. It will 
help safeguard the  competitiveness of the EU  automotive industry  and  accelerate the uptake  of 
ZEVs in second-hand markets in the EU. Furthermore, existing EU level supply-side measures, 
such as CO2 emission performance standards for road transport vehicles, will be complemented 
more effectively by demand-side measures taken at the same level, rather than relying on national 
measures.  

B.  Solutions  

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

Two  main  groups  of  policy  options  have  been  designed  (PO1  and  PO2),  each  including  three 
different levels of ambition for the uptake of zero-emission cars, vans and lorries (PO1A, PO1B, 
PO1C, and PO2A, PO2B, PO2C, respectively). An assessment of the possible inclusion of certain 
minimum EU content criteria in line with the Industrial Accelerator Act was also undertaken. 

The first group of options (PO1) sets targets for Member States. It will require each Member State 
to ensure that, starting from 2029, ZEVs represent at least a certain share of new registrations of 
corporate  cars,  vans,  and  lorries  by  large  companies  in  its  territory  during  that  year.  Corporate 
vehicles  registered  by  SMEs  or  citizens  are  not  included  in  the  scope.  The  minimum  national 
targets are set at different levels of ambition for cars, vans, and lorries, to ensure consistency with 
the CO2 emission performance standards and reflect the different level of technology and market 
development. For cars and vans, additionally, the level of ambition is modulated across Member 
States based on GDP per capita and on the share of ZEVs in new registrations in 2024, to reflect 
the capacity to absorb higher initial capital costs and the presence of relevant enabling conditions 
such as charging infrastructure. For lorries, the targets are set at the same level across all Member 
States, because of the significant share of long-distance transport activity across Member States 
and the resulting risk that differentiated targets would distort the internal market. This group of 
policy options will require Member States to activate key national policy levers such as incentives 
for  ZEVs  uptake  in  corporate  fleets  through  differentiated  vehicle  and  income  taxation  or  e.g. 
favourable road charging regimes. It will ensure the necessary flexibility and minimise 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  lorries  through  a  target  on  minimum  shares  of  ZEVs  in  transport  activity  of 
individual large companies. By addressing certain companies directly, this group of policy options 
secures a specific implementation pathway but also increases compliance costs. Large companies 

2 

 
 
will be required to report yearly the total road freight transport activity performed on their behalf – 
by their own lorries and by direct and indirect sub-contractors – in tonne-kilometres, and ensure 
that  a  minimum  share  of  that  activity  has  been  performed  with  ZEVs.  This  approach  aims  to 
provide certainty of demand from large shippers for freight transport services performed through 
ZEVs.  It  relies on this  guaranteed  shippers’ demand to push transport operators  to increase the 
share of ZEVs in their fleets.  

PO1 is the preferred option, given that it is considered effective in reaching the policy objectives, 
it presents  net benefits,  and  it  avoids the  risk of imposing significant burdens.  It  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.  

The choice between PO1A, PO1B, and PO1C, which only differ in terms of level of ambition of 
the national targets, requires political decision. This choice has implications in terms of the overall 
costs and benefits for large companies, SMEs, citizens and national administrations. PO1A, PO1B 
and PO1C would all result in net economic, social, and environment benefits, albeit to varying 
degrees. The assessment 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  administrations.  PO1B  also 
shows  relatively  high  effectiveness  and  similar  benefits  to  costs  ratio  with  PO1C.  It  leads  to 
somewhat  lower  indirect  net  costs  for  SMEs,  lower  losses  in  tax  revenues  for  national 
administrations 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. It shows the lowest net costs for SMEs and lowest losses in 
tax revenues for national administrations, while its net costs for citizens are relatively similar to 
those of PO1B. 

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

Stakeholders broadly agree that the ZEVs uptake in corporate fleets remains too limited compared 
to the  EU’s climate  and industrial policy  goals,  and  that  a higher  corporate  ZEVs  share would 
bring benefits in terms of emission reduction and affordability of ZEVs through the second-hand 
market.  Stakeholders  generally  support  financial  incentives  to  accelerate  this  transition,  while 
support  for  ZEVs  mandates  at  the  level  of  companies  or  fleets  is  more  limited.  Environmental 
NGOs  strongly  support  the  proposal,  including  both  national  targets  (PO1)  and  targets  for 
shippers  (PO2),  while  vehicle  manufacturers  and  consumer  associations  generally  expressed 
conditional  support  for  the  proposal’s  objectives,  with  divergent  views  about  the  options.  The 
level of support is generally lower among transport operators. Some large logistics companies and 
transport  operators  oppose  any  initiative  in  this  field,  while  others  indicate  support  for  some 
measures,  such  as  financial  incentives  or  national  targets  (PO1),  but  not  for  mandates  for 
individual companies. Leasing and rental companies and associations also generally oppose ZEVs 
mandates. Freight transport operators specifically expressed concerns about possible mandates on 
shippers  (PO2),  noting  that  they  would  not  expect  to  be  able  to  pass  on  the  extra  costs  of 
switching to ZEVs to the shippers. 

3 

 
 
C.  Impacts of the preferred option  

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

Total benefits are estimated at EUR 68.8 billion for PO1A, EUR 98.3 billion for PO1B and EUR 
132.2 billion for PO1C, expressed as present value over 2029-2050 relative to the baseline. More 
specifically: 

•  Large  businesses  will  benefit  of  adjustment  costs  savings  (mainly  fuel  and  other  operation 
costs savings), as well as reduced tax expenditure, deriving from the shift to ZEV in their fleet. 
The total benefits for large businesses are estimated at EUR 40.3 billion in PO1A, EUR 56.9 
billion in PO1B and EUR 74.9 billion in PO1C. 

•  SMEs and citizens will indirectly benefit from fuel and operational cost savings and reduced 
tax expenditure, in their case deriving from the increased availability of second-hand ZEV. The 
total benefits for SMEs are estimated at EUR 10.3 billion in PO1A, EUR 14.4 billion in PO1B 
and EUR 18.9 billion in PO1C and for citizens at EUR 2.9 billion in PO1A, EUR 6.1 billion in 
PO1B and EUR 11.6 billion in PO1C.  

•  National administrations would benefit of an increase in tax expenditures, due to the uptake of 
ZEV, estimated at EUR 13.5 billion in PO1A, EUR 16.6 billion in PO1B and EUR 18.9 billion 
in PO1C.   

•  From  a  societal  perspective,  the  main  benefits  refer  to  savings  in  external  costs  of  CO2 
emissions, noise and air pollutant emissions resulting from the increase in the share of ZEVs in 
vehicle  fleets  of  large  companies,  with  higher  yearly  mileage,  and  the  faster  availability  of 
second-hand ZEVs leading to an overall increase of the share of ZEVs on the road. External 
costs savings are estimated at EUR 1.9 billion in PO1A, EUR 4.3 billion in PO1B and EUR 
7.9 billion in PO1C, expressed as present value over 2029-2050 relative to the baseline. 

When also considering the total costs, the net benefits are estimated at EUR 6.5 billion in PO1A, 
EUR 13.6 billion in PO1B and EUR 23 billion in PO1C, expressed as present value over 2029-
2050 relative to the baseline. The corresponding benefits to costs ratio is 1.1 for PO1A and around 
1.2  for  PO1B  and  PO1C.  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. 

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

Total costs are estimated at EUR 62.3 billion in PO1A, EUR 84.8 billion in PO1B and EUR 109.2 
billion in PO1C, expressed as present value over 2029-2050 relative to the baseline. These costs 
mainly  consist  of direct  adjustment costs for  large  businesses (EUR  8.3 billion in PO1A, EUR 
11.9 billion in PO1B and EUR 15.6 billion in PO1C), indirect costs for SMEs (EUR 25.8 billion 
in PO1A, EUR 33.1 billion in PO1B and EUR 39.4 billion in PO1C) and for citizens (EUR 9.7 
billion in PO1A, EUR 12.1 billion in PO1B and EUR 15 billion in PO1C), losses in tax revenues 
for national administrations (EUR 18.4 billion in PO1A, EUR 27.7 billion in PO1B and EUR 39.1 
billion  in  PO1C)  and  some  limited  administrative  costs  for  national  administrations  and  the 
European Environment Agency.  

4 

 
 
What are the impacts on SMEs and competitiveness?  

SMEs  are  not  directly  affected  by  the  preferred  option.  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 
lower capital costs and higher fuel and other operation costs in the short to medium  term. This 
will  be  partly  compensated  by  fuel  costs  and  other  operation  costs  savings  resulting  from  the 
increased  availability  of  second-hand  ZEVs.  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. Per vehicle per year this would however represent 
up to EUR 21.1 in PO1A, EUR 29.6 in PO1B and EUR 38.5 in PO1C, while PO1B and PO1C are 
projected to lead to net benefits in the medium to long term. PO1A, PO1B and PO1C are expected 
to  help  increase  the  competitiveness  of  road  transport  operators,  companies  making  use  of 
transport and logistics services, thanks to a reduction in fuel and other operation costs, as well as 
vehicle  manufacturers  thanks  to  greater  certainty  of  demand.  At  aggregate  level,  for  large 
businesses  and  SMEs,  the  net  benefits  are  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.   

Will there be significant impacts on national budgets and administrations?  

The  preferred  policy  option  is  expected  to  generate  limited  administrative  costs  for  national 
administrations. 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 (estimated at EUR 10,350 per year at EU level in PO1A, PO1B and PO1C). While 
Member States are already able to differentiate corporate from private vehicles in their registry, 
the exclusion of corporate vehicles registered by SMEs  will require a one-off adaptation of the 
registries (estimated at EUR 0.23 million in PO1A, PO1B and PO1C). At the same time, national 
administrations are expected to experience losses in tax revenues due to the higher uptake of ZEV 
and the associated reduction in fuel consumption, estimated at EUR 4.9 billion in PO1A, EUR 
11.1 billion in PO1B and EUR 20.2 billion in PO1C. 

Proportionality 

The preferred policy option is considered proportionate as action at EU level is limited to what is 
necessary to accelerate the uptake of ZEVs in the corporate segment, support the competitiveness 
of  the  sector,  and  accelerate  ZEVs  availability  on  the  second-hand  market  to  the  extent  it  is 
needed to ensure a fair and just transition. It leaves full flexibility for public authorities at national, 
regional and local levels to decide the necessary measures to spur uptake while ensuring that the 
proposal’s objectives are satisfactorily met. 

D.  Follow up 

When will the policy be reviewed?  

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

5