
Summary
Europe's regulated data landscape is moving from regulation to operation. New Annex X deadlines are taking effect, new carmakers are entering Europe, and deciding who gets access is becoming as important as making data available.
Key findings
- A new Annex X deadline takes effect on 23 September 2026, the first in a series of operational requirements running to June 2028.
- Chery, GAC, Dongfeng, XPeng, Lucid and others are expanding in Europe, bringing new needs for regulated data access.
- When Skywell's UK importer stopped trading, the cars stayed on the road, and so did their need for repair and data access.
- From 18 February 2027 the Battery Passport applies, and verifying who gets access becomes an operational question.
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