IR 2026/1778 binds from 6 August. Every change from draft to adopted — in full

First, a correction of our own

On 20 July, the day the registry went operational, we wrote that operator verification was the one point where the adopted text differed from our reading of the draft — and that proof of registration "works the way the draft described". Having now compared every article of the adopted regulation against the draft, both statements were too narrow. Material differences exist across the definitions, verification, delegation, proof and responsibilities articles; two articles were added; one requirement was dropped. Proof of registration — the article we called unchanged — changed in two ways that matter.

We sell the discipline of gating on adopted text, with every field and rule carrying a recorded source. That discipline only means something if it is applied to our own published words. So: here is the complete diff, and the earlier article now carries a dated note pointing here.

The regulation binds from tomorrow

Implementing Regulation (EU) 2026/1778 was published in the Official Journal on 17 July and enters into force on 6 August. Entry into force changes the legal status of the rules, not your timeline: the date that binds an economic operator remains 18 February 2027, when each LMT battery, EV battery and industrial battery above 2 kWh placed on the EU market needs a registered passport under Article 77 of the Battery Regulation.

The changes that bite operators

Expired verification now blocks writing, not just access (Article 5). The draft said an actor whose verification expired could access the registry again only after re-verifying. The adopted text is harder: they "shall no longer be able to perform registrations or modify any data" until re-verified. Credential renewal is now a write-blocker — let a qualified seal lapse and passport operations stop with it. The adopted text also states plainly that only verified actors have registry access at all, and adds a rule the draft carried only in a recital: an actor already identity-verified in an equivalent Union system need not verify twice.

Proof of registration changed twice (Article 9). The proof document now carries the unique product identifier — the draft specified the registration identifier, a different field. And where the draft required a qualified electronic timestamp alongside the Commission's seal, the adopted text instead embeds the Commission's own electronic timestamp as a data field. The adopted text also extends the right to generate proof to a third party acting on the operator's behalf — which brings us to the next point.

Your platform must itself be verified (Article 19). The draft said a verified operator authorising a third party to perform registration actions "shall remain fully responsible". The adopted text keeps that sentence and adds an obligation: the third party must itself complete verification under Article 5. Both halves matter. A passport platform acting for you must hold its own verified status — and your responsibility as the economic operator is untouched. No provider moves that liability, including us; what a provider moves is the work.

Delegation is narrower (Article 6). The draft let verified operators delegate access rights to users generally. The adopted text permits delegation "where provided by Union law", to third-party users. The article was also refocused on profile management, with the responsibility language consolidated into Article 19.

The definitions were rewritten (Article 2). This is the heaviest edit in the regulation. "Unverified economic operator" is gone; "value chain actor" and "verified value chain actor" are added; "semantic conformity" is redefined as a three-limb test; "massive data download" enters the text. If your compliance documentation quotes draft definitions, it quotes text that no longer exists.

One requirement was dropped (Article 10). The draft required the registry to link each new passport version to the original registration identifier. The adopted text requires versioning and a Commission timestamp — the linkage requirement is gone.

Two articles are new. Article 6a governs transfer of registered passports between operators — the mechanism for what happens when a client changes provider or ownership changes hands. Article 23 commits the Commission to evaluate the regulation by the end of 2032 and every six years after.

Two dates worth diarising. Member States must designate their national administrator by 18 February 2027 (Article 7). And the Commission's helpdesk moves to year-round 08:00–20:00 Brussels-time support, with an automated always-on support tool committed by February 2029 (Article 13).

For balance: several articles did not materially change — the log system, information-system security, personal data and the Commission's responsibilities are drafting-level edits only.

Why publish a correction at all

Because the alternative is worse. An operator relying on our 20 July piece would believe proof of registration was settled in the draft's terms; it was not. Every rule on our registry readiness page carries its source by article and paragraph, and when the source moves, the page moves — in public, with a date. That page, including what the platform now aligns to under the adopted text, is here: where the registry stands.