The Platform supports the introduction of binding minimum shares of clean vehicles in new corporate registrations. That said, the level and design of the targets require careful adjustment to be impactful.

Recommendations:

• Setting ambitious, proportionate and attainable targets that go beyond current market trends, ensuring the whole ecosystem moves forward and drives innovation and investment while fostering the second-hand car market for European citizens.
• Setting a clear, long-term decarbonisation target and credible pathways towards full decarbonisation for all Member States for fleets covered by the proposal in order to reach carbon neutrality by 2050.

The proposal introduces Member State–specific targets, reflecting differences in economic conditions. While this granularity is understandable, it should not undermine the core objective of convergence towards zero-emission mobility across Europe evenly. While we recognise that differentiated targets aim to account for variations in purchasing power across Member States, this rationale must be relativised in the context of multinational corporate fleets operating across Europe. More broadly, the objectives of clean air and access to modern mobility solutions are shared across the Union.

Recommendation:

• While maintaining national targets, the regulation should explicitly ensure that lagging Member States are encouraged—and supported—to catch up, in particular in infrastructure deployment[i], rather than locking in structural disparities and creating a two-speed Europe in corporate electrification.

[i] Platform for Electromobility. (2025, December 5). From targets to consumer-friendly deployment of publicly accessible charging points for EVs. https://www.platformelectromobility.eu/2025/12/05/from-targets-to-consumer-friendly-deployment-of-publicly-accessible-charging-points-for-evs/

The inclusion of low-emission vehicles (LEVs) alongside zero-emission vehicles raises concerns. This approach dilutes the signal towards full electrification; diverting investments from future-proof, zero-emission technologies towards transitional solutions that still emit CO2.

Recommendation:

Prioritising zero-emission vehicles across the Regulation, with a clear and credible pathway towards its future uptake in corporate fleets.

We support the principle, set out in Article 4 of ending public financial support for CO2-emitting vehicles but we urge to end any support to low-emission vehicles too. This is essential to ensure coherence between public spending and climate objectives. Moreover, the proposal remains vague as to what precisely constitutes “financial support” and how this prohibition will be implemented and enforced at national level.

Recommendations:

• The scope of prohibited financial support should be clearly defined, and financial support for the procurement or purchase of a new vehicles, as well as their operation, should be strictly reserved for zero-emission solutions.
• Article 4 should apply to all incentives, not only those for large fleets included in the scope of the regulation.

We support conditioning public financial support for uptake of corporate cars on “Made-in-Europe” criteria. This measure must be used carefully and smartly to avoid possible negative side effects. Industrial realities, notably the complexity of broader European supply chains, must be properly acknowledged to make sure that it does not result in making EVs less competitive and thus less affordable, which would ultimately slow down the electric transition.

The proposal shifts all responsibility for demand-side incentives to Member State implementation. Following up on previous guidance, the Commission missed the opportunity to create a comprehensive list of measures that Member States should implement, both for new vehicle acquisition, operations, and residual value guarantees.

Recommendation:

• The Regulation should be more precise on demand-side incentives that Member States should include.

The proposal does not recognise the growing role of multimodal, public, and light electric mobility solutions for corporate needs. Companies increasingly rely on a mix of solutions to meet mobility needs: small cars, public transports (buses, trams, metros, local and regional trains, etc.), sharing of e-cars, e-bikes and e-scooters, etc.

Recommendation:

• A broader and more forward-looking perspective on corporate mobility, encouraging the use of all electric mobility solutions, should be promoted, for example through a recital within the regulation and through strong accompanying measures such as recommendations for tax incentives at Member States level.

Corporate fleets are ideally suited to become early adopters of smart and bidirectional charging, given their predictable usage patterns and focus on cost efficiency. Vehicle-to-Grid (V2G) and smart charging technologies can support a grid-friendly rollout of electromobility; enhance energy system resilience; facilitate renewable energy integration; reduce costs for both fleet operators and the electricity system.

Recommendation:

• Without delaying implementation, the Regulation should explicitly encourage the deployment of smart and bidirectional charging solutions alongside fleet electrification.

We regret the absence of any binding commitments for heavy-duty vehicles, as large fleets (except bus fleets, for which the Clean Vehicles Directive applies) have not been regulated at EU level. While the challenges differ from light-duty segments, HDV fleets also represent a major decarbonisation opportunity.

Recommendation:

• The Regulation should at least establish a clear roadmap or review clause to progressively integrate HDVs (other than buses) into the clean corporate vehicle framework.

Specific support should be provided to the second-hand market through National implementation plans, including measures such as:

• Removing registration and circulation taxes;
• Offering favourable depreciation and vat treatment;
• Providing incentives and premia for high-mileage and second-life vehicles to support vulnerable communities;
• Reduce residual value risk for professional fleets via guarantees, risk-sharing, or resale support schemes

While the Regulation’s scope allows for the inclusion of taxis, ride-hailing services, and other professional or shared mobility fleets when operated by large undertakings, in practice many of these operators will not meet the thresholds set out in the proposed regulation. These vehicles are intensively used, predominantly urban, and can have a significant positive impact on air quality and emissions.

Rather than reopening the core fleet definition, the Platform considers it more effective to address these segments through Member States’ compliance and implementation plans. This would allow national authorities to design targeted measures for high-impact professional fleets, improve visibility on national actions, and partially address the absence of a strong EU-level compliance mechanism.

Recommendation:

• Encourage Member States to explicitly include taxis, ride-hailing services, and other professional and shared mobility fleets in national implementation and compliance plans, with tailored measures reflecting their high utilization and environmental impact.

A credible and transparent compliance framework is essential to ensure the Clean Corporate Vehicles Regulation delivers real-world emissions reductions. To maintain market confidence, the Regulation must focus on Member State accountability while allowing for national flexibility in policy design.

Recommendations:

• The Regulation should establish EU-wide monitoring and proportionate consequences for missed national targets. Enforcement revenues should be reinvested into electrification, charging infrastructure, and clean mobility.
• In line with Article 6, MS should report annually on the effectiveness of their chosen policy mix (e.g., fiscal incentives or mandates).

The Platform supports the use of size thresholds to focus binding obligations on large undertakings and avoid disproportionate burdens on SMEs and one-person companies. While not in the scope, smaller and more fragile actors will be directly affected by market shifts driven by large fleets and must be supported to ensure a fair and effective transition. Targeted incentives, access to charging infrastructure, and adapted financing solutions will be essential to enable SMEs and individual operators to absorb the costs of electrification and fully benefit from the increased availability of electric vehicles.

Recommendation:

• Retain size thresholds for binding obligations while ensuring that SMEs and one-person companies are supported through dedicated incentives and enabling measures at national level.