Regulations Update September 2026

What's Changing

Starting 1 January 2027, new PHEV type approvals will use a different test method called Euro6e-bis-FCM, replacing the current Euro6e-bis standard.

The number that matters most is CO2. Under the new method, the official CO2 figure on the Certificate of Conformity can come out 3 to 4 times higher than it does today. That's a meaningful shift, and one that can have fiscal implications depending on the market.

Why the CO2 Number Matters

Registration tax and road tax in most of Europe are tied directly to the CO2 value on the COC. Because of that, a change of this size to how CO2 is calculated is worth paying attention to on every deal, particularly as it can play out differently from one country to the next.

New Models, New Numbers

This change is unlikely to affect a model you already know. Manufacturers don't typically request a new type approval for a model that's already on the market, so existing models tend to keep their current, lower CO2 figures.

Where you'll see the difference is with new brands and models entering the market from 2027 onward. As they get homologated under the new test method, their CO2 figures will land 3 to 4 times higher than comparable existing models, purely because of the method used to test them.

From 2028

From 1 January 2028, every type approval, including the ones already in use, has to convert to Euro6e-bis-FCM. A conversion method already exists for this.

There's talk of a transitional arrangement for stock not yet registered by that point, but nothing has been confirmed. We're watching this closely and will share more as soon as it's clear.

What to Expect in 2027

With the current test method still valid for existing models, we don't expect major disruption to today's PHEV stock. The bigger story will be new market entrants under the new method, and how buyers and sellers adjust to comparing type approvals that aren't quite like-for-like anymore.