The framework that will eventually accredit DPP service providers is still being written. ESPR (Regulation (EU) 2024/1781) sets the legal basis for the passport and for the role of third-party platforms that manage and serve product data, but the detailed requirements for service providers come through delegated and implementing acts — and those are arriving in sequence, not all at once. The realistic read in mid-2026 is that the service-provider accreditation regime is not yet a finished, enforceable scheme.
That matters less than it first appears, and for a reason worth being precise about.
What is actually fixed versus still moving
Two things are fixed. The battery passport is mandatory from 18 February 2027 under the Battery Regulation (EU) 2023/1542 — a sector-vertical regulation that applies on its own terms and needs no delegated act to switch it on. And the EU is standing up a central product-passport registry, expected to be operational around mid-2026, to hold the unique identifiers of every passport.
What is still moving is the surrounding scaffolding: the ESPR product-category delegated acts (iron and steel first, textiles and others following), the formal accreditation requirements for service providers, and the citation of the technical standards in the Official Journal that would give a conformant passport presumption of conformity. None of that scaffolding is required for a battery passport to be valid on 18 February 2027 — the Battery Regulation's own Annex XIII and Article 77 are the binding text.
Why a delay in the accreditation scheme is not a reason to wait
It is tempting to read "the service-provider scheme isn't finalised" as "there is no rush." For anyone placing batteries on the EU market, the opposite holds. The deadline is the 18 February 2027 passport date, and the work to be ready for it — collecting Annex XIII data across the supply chain, structuring it, validating it, getting it registered — is substantial enough that it has to begin well before any accreditation scheme is settled. The two timelines run in parallel; the binding one is the passport date.
So the gap between "the obligation is live" and "the accreditation scheme is finalised" is simply the window in which the compliance work has to happen anyway. A passport built now against the Battery Regulation's own requirements — structured Annex XIII data, GS1 Digital Link QR, registry submission, an immutable audit trail — is the same passport a later accreditation scheme will recognise. Building to the regulation rather than waiting for the meta-regulation is the defensible position.
What to watch
Three signals are worth tracking as the year progresses: the registry going live (which firms up how submissions are actually accepted), the citation of the EN DPP standards in the Official Journal (which would let a conformant passport claim presumption of conformity), and the publication of the service-provider accreditation requirements themselves. Until those land, the sound posture is to build to the binding Battery Regulation text and keep the architecture flexible enough to adopt the accreditation scheme when it arrives.
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