The battery passport after 19 October: what version 3.2 changed
On 19 October 2026 the European Commission published a new version of the table that sets out what goes into the battery passport. There are still 71 data points. But row 40 is now a different data point, rows 41–47 have been reshuffled, and industrial batteries have 31 mandatory data points instead of 32.
If you made a list of the data points by number in August, it now points to the wrong data. The offset is just one row, but that is enough to put the cathode composition where the spare parts should be.
Version 3.2 is the guidance the whole market will work from
The document is called "Digital Batteries Passport – data point by category" and sits on the Commission's battery passport page with the note "last update 19 October 2026". The cover reads "Version 3.2" and "3rd Edition". Version 1.0 dates from 28 July 2026 and version 2.0 from 15 August, so three editions have appeared in less than three months. We wrote our article on the 71 data points from version 2.0.
The table is not a legal act. The mandatory information is listed in Annex XIII to Regulation (EU) 2023/1542, and the passport is required from 18 February 2027 for three categories: electric vehicle (EV) batteries, light means of transport (LMT) batteries and industrial batteries with a capacity greater than 2 kWh (Article 77(1)). In practice, though, software vendors, laboratories and buyers will read Annex XIII through this table, because it states the format of each data point and who has access to it.
The Commission itself advises checking for a newer version before each use.
Battery passport data points 40–47 have new numbers
The change in version 3.2 with the most direct practical effect is the numbering. The Commission added a new data point 40: the discharge C-rate used in the cycle-life test. It is optional for all three battery categories. Because of it, the old data points 40–44 become 41–45, and the detailed composition of the cathode, anode and electrolyte moves from 45 to 46.
The old data points 46 and 47 (part numbers for spare parts and the contact details of their suppliers) have been merged into a new data point 47, provided as a web link. It is mandatory for EV, LMT and industrial batteries. From data point 48 onwards, the numbering matches version 2.0.
If your Excel sheet, your ERP export or the integration with your passport provider relies on data point numbers, check it row by row. The safer approach is to track each data point by its name and the Annex XIII point it comes from, and keep the number from the guidance as a reference, together with the version it was taken from.
Who sees restricted data points 46–49 under version 3.2
Data points 46–49 of the battery passport are not public: the detailed composition, spare parts, dismantling information and safety measures. Until now, persons with a legitimate interest and the Commission had access to them. Version 3.2 explicitly adds Member State authorities and notified bodies. Test reports (data point 50) remain restricted to notified bodies, Member State authorities and the Commission.
Who exactly has a legitimate interest will be settled by a separate implementing act under Article 77(9) of the Batteries Regulation. Its draft was also published on 19 October (Ares(2026)9814179) and is open for feedback until 16 November 2026. It has not been adopted yet. As currently drafted, it gives repairers, remanufacturers and recyclers access to the composition and dismantling data, and gives the buyer, and third parties acting on the buyer's behalf, access to the data on the battery's state of health and use.
For a manufacturer, this means the same passport will look different depending on who opens it. A repairer and a recycler do not see the same things, and a buyer sees something else again. It is easier to design for this now than to add it after February.
Industrial batteries have 31 mandatory data points, and state of health stays
In the column for industrial batteries with a capacity greater than 2 kWh, version 3.2 lists 31 mandatory data points, 26 conditional, 2 optional and 12 that are not filled in as of February 2027. Under version 2.0 there were 32 mandatory ones. The difference comes from merging the spare parts data points.
Version 3.2 also specifies that data points 51–66 apply only to certain industrial batteries. The data points for capacity fade, power fade and internal resistance increase (51–60) apply only to rechargeable batteries. The state of health data points (62–66) apply only to stationary battery energy storage systems, and only if those have a battery management system (BMS).
It is easy to read this as state of health being dropped for all industrial batteries. It is not. For industrial batteries only data point 61 drops out: the state of certified energy (SOCE), which is filled in for EV batteries only. Data points 62–66 remain mandatory for a stationary system with a BMS, and their legal basis is Article 14 and Annex VII.
There is one subtlety. Version 3.2 attaches the condition "where possible" to data points 63–66, while Annex VII to the Regulation attaches it to power capability, round-trip efficiency and ohmic resistance, but not to the evolution of self-discharging rates. Until a delegated act changes that, the safer course is to fill in the self-discharge data point.
Temperature and charge go into the battery passport as histograms
Data points 70 and 71 of the battery passport show how long the battery has spent in different temperature ranges and at different states of charge. Version 3.2 specifies that they are reported as histograms, not as a single value. They are filled in once the battery is put into use. The Commission's questions and answers (FAQ) on batteries, published in September 2026, say that real-time communication is not required; the data is updated when the status of the battery changes.
The industry data model BatteryPass-Ready (JSON schemas v2.0.1, September 2026) follows the version 2.0 numbering, and its schema for stationary systems records temperature and charge as a single integer. If the system you use is built on that model, ask how it will report a histogram. Asked in November, it takes one meeting; if it surfaces in February, it becomes a problem.
What to check in your battery passport before 18 February 2027
There are 107 days left until the battery passport becomes mandatory. Working from version 3.2 of the guidance (19 October 2026), this is what we would check now:
- Track data points by name and by their point in Annex XIII. Record which version of the guidance you used to order them.
- Check which column of the table your battery falls into. An industrial battery may have data points 62–66 as mandatory (a stationary system with a BMS) or not have them at all (any other industrial battery).
- Prepare the documents for data points 46–49 as web links with restricted access.
- Agree with your BMS supplier how the temperature and charge histograms will be exported.
- Check the Commission's page again in January. A version 3.3 is entirely possible.
When version 3.2 came out, we checked our battery templates against it row by row and column by column. To see what this looks like for your type of battery, take a look at the digital product passport for batteries or the sample passport. The legal framework is set out on the Batteries Regulation page.
