As part of the automotive competitiveness package expected to be published on 10 December 2025, the European Commission is finalising two major initiatives with direct implications for vehicle manufacturers, suppliers, fleet operators and mobility providers: the Greening Corporate Fleets proposal and the revision of the 2035 CO₂-emission standards for cars and vans.

The Greening Corporate Fleets initiative, initially foreseen in the 2023 revision of the Clean Vehicles Directive, aims to accelerate the decarbonisation of corporate and publicly owned fleets, which represent a significant share of vehicle turnover in several Member States. Internal discussions within the Commission over recent months have highlighted substantial political sensitivities surrounding the design of the measure. Divergences persist among Member States regarding the feasibility of national-level targets, the proportionality of possible local content criteria, and the administrative burden of new reporting requirements. As a result, the scope and structure of the final proposal remain subject to refinement.

Early indications suggest that the Commission may adopt a Member State–focused approach, setting national objectives for the gradual uptake of low- and zero-emission vehicles in corporate fleets. These objectives may be complemented by data-reporting and traceability obligations requiring operators to submit standardised information on vehicle characteristics and emissions performance to national authorities. Discussions are also ongoing regarding the potential inclusion of local content provisions for specific components or manufacturing stages, an issue on which Member State views remain divided.

In parallel, the Commission is finalising a revision of the 2035 CO₂ standards for new passenger cars and light commercial vehicles. While the target architecture established under Regulation (EU) 2019/631 is expected to remain intact, the Commission is examining options to introduce greater technological neutrality within the post-2035 framework. Among the elements under consideration are potential compliance pathways for plug-in hybrid electric vehicles (PHEVs), the regulatory treatment of range-extender architectures, and the possible recognition of synthetic and renewable fuels under defined certification conditions. The accompanying impact assessment is also exploring adjustments to lifecycle-based emissions methodologies and potential refinements to type-approval procedures. Questions have emerged regarding the scope of transitional provisions, the viability of existing hybrid portfolios under revised conformity requirements, and the interaction between future emissions methodologies and current type-approval certifications..

With several Commission services now engaged in the final drafting phase, and publication expected within weeks, both the Greening Corporate Fleets initiative and the revision of the 2035 CO₂ standards are expected to be released as full legislative proposals. Once issued, each proposal will be transmitted to the European Parliament and the Council under the ordinary legislative procedure. The Parliament will designate a committee and appoint a rapporteur and shadow rapporteurs, while Council working parties begin their technical examination. These early stages will frame the initial interpretation of the texts, influence the amendments proposed by co-legislators, and help operators understand where compliance burdens or operational impacts may arise.

How Does This Affect Your Company?

For companies, this initial scrutiny phase is critical for identifying provisions requiring clarification, preparing internal governance adjustments, and anticipating where delegated or implementing acts may introduce further obligations.

How We Can Assist

Given that both initiatives will shortly be tabled as legislative proposals and will proceed through the ordinary legislative procedure, companies across the automotive sector are preparing for the initial scrutiny phase. In this context, we can support clients with targeted, concrete services, including:

  • Early-stage analysis of the legislative proposals, identifying obligations, transitional provisions, delegated-act mandates, and points likely to attract amendments from Parliament or Council.
  • Monitoring of the parliamentary and Council process, including committee allocation, rapporteur and shadow appointments, Council working party discussions, and emerging amendment trends.
  • Preparation of technical-legal briefings to facilitate company participation in stakeholder hearings, committee discussions, or targeted exchanges with Member States.
  • Contractual risk and readiness analyses, assessing whether procurement, supply-chain or fleet-management contracts require adjustment in light of expected obligations.
  • Technology-specific regulatory opinions regarding the treatment of PHEVs, range extenders and synthetic-fuel pathways under the proposals and future delegated acts.

We will continue to monitor developments closely and provide further updates once the Commission publishes the legislative proposals. If you would like to discuss how these measures may affect your business, please contact our team.