Access rights and roles: who may see what in a battery passport, and why

Access rights in a battery passport decide who may see restricted detail, for which battery, and for what purpose. Annex XIII defines the audiences: the general public, persons with a legitimate interest, notified bodies, market surveillance authorities and the Commission. Roles translate those audiences into working permissions: public reader, repairer, recycler, remanufacturer, assessor, notified body, authority, operator administrator. A role is not a person. A person holds a role for a purpose and a period, and the role can change while the person stays the same.

Access control that grants rights to named individuals without roles, purposes and review dates cannot be audited, and cannot be revoked cleanly when a purpose ends.

How are roles defined?

Roles are defined by the detail needed and the purpose served. A public reader needs point 1 only, with no authentication. A repairer needs point 2 dismantling and safety detail for the model being repaired, plus point 4 history for the unit being repaired. A recycler needs detailed composition, dismantling detail and waste information for the battery being treated. A remanufacturer or repurposer needs the same detail plus performance history to support assessment. A notified body needs point 3 test results for the models within its notification scope, plus the model detail needed to assess conformity. A market surveillance authority needs point 3 and the detail needed for enforcement. An operator administrator needs the ability to maintain the record, but administration is not a right to read restricted detail for an unrelated purpose. Each role should be defined in writing, with the points, the battery scope and the purpose stated, before any grant is made.

What does the role matrix look like?

How is a grant made and recorded?

A grant is made by an authorised grantor, recorded with the person, the role, the battery or model scope, the purpose, the start date and the review or end date. The grant record is retained with the access log, so that a later review can reconstruct who had access to what, when, and why. A grant made informally, by sharing a password or a link, leaves no record and cannot be revoked without changing the shared secret for everyone. A grant that has no end date or review date drifts into permanence, and permanence is the most common access failure in record systems. Grants should default to the shortest period that serves the purpose, with renewal requiring a fresh purpose statement. Renewal without review is not a control. It is a habit that defeats the control.

How is access reviewed and revoked?

Access is reviewed at intervals set by the operator, on a change of role or employment, on completion of the purpose, and after any security incident. Review checks each live grant against current purpose and scope, checks access logs for use consistent with purpose, and revokes grants that no longer serve a purpose. Revocation must be effective immediately in the system, not merely noted in a file. A revoked reader who can still log in through a cached session or a shared link has not been revoked. Review also checks for dormant grants: access that was granted but never used, or used once and never again, should be revoked or renewed with a fresh purpose. Dormant access is a risk without a benefit, because it widens the set of people who could access detail without any current need.

What happens when access is misused?

Misuse includes accessing detail outside the granted purpose, sharing detail with a person who has no grant, copying detail into a public document, and using detail to gain a commercial advantage unrelated to the battery purpose. Misuse is handled by revocation, by investigation of the access log, by notification to affected operators where the system rules require it, and by a record of the incident and the remedy. The incident record should state the facts in neutral terms, without speculation about motive, and should state what was accessed and what was done with it where that can be established. Misuse by one reader must not lead to withdrawal of access for all legitimate readers, because the passport system depends on legitimate access to detail. The response should be targeted: revoke the grant, fix the control that allowed the misuse, and preserve access for readers who use it properly.

What does the draft implementing act change, and what does it not change?

A draft implementing act under Article 77(9) of Regulation (EU) 2023/1542, circulated as Ref. Ares(2026)9814179 on 19 October 2026, would name the persons with a legitimate interest in Annex XIII points 2 and 4, and would set the purposes for which they may use that detail. This draft is not law. The draft itself states that it has not been adopted or endorsed by the Commission, and its contents are the preliminary views of the Commission services. Feedback on the draft was reported as open until 16 November 2026. Until an act is adopted and published in the Official Journal, the access tiers in Annex XIII and the role matrix above remain the position stated in the Regulation, and no reader should treat a draft allocation below as a granted right.

The draft would allocate detail by point, not by a single general right. For point 2(a) and point 2(c), it names repairers, remanufacturers, persons carrying out repurposing, waste management operators carrying out treatment, recyclers, and vocational training centres for battery repair, repurposing or remanufacturing. For point 2(b), it names repairers, remanufacturers, persons carrying out repurposing, and the purchaser of the battery. For point 2(d), on safety measures, it names those same persons, plus establishments permitted to carry out treatment operations on end-of-life vehicles and treatment facilities for waste electrical and electronic equipment. For point 4, on the individual battery, it names the purchaser and any third party acting on the purchaser’s behalf.

Use under the draft would be purpose limited. The persons named for points 2(a) to 2(c) and point 4 could access that detail only to evaluate the status and residual value of the battery and its capability for further use, or to repair, prepare for re-use, prepare for repurposing, repurpose, remanufacture or recycle the battery, or to choose between those operations. Purchasers and parties acting on their behalf could also use point 4 detail to make the battery available to independent aggregators or market participants. Downloaded detail could be kept only for as long as necessary for those purposes.

Sharing and publication under the draft would remain restricted, with listed exceptions. The persons named could not share or publish points 2(a) to 2(c) or point 4 detail, except where the draft allows it: sharing with emergency services and, for point 2(a), with poison centres; sharing of point 4 detail by purchasers and their representatives with prospective purchasers, market surveillance authorities and the competent authorities for Chapter VIII obligations; sharing with customs authorities; and sharing or publication authorised by the economic operator placing the battery on the market. Safety information under point 2(d) is treated differently in the draft: the persons named for that point could use, download, share, publish and re-use it without restriction.

What the draft does not change matters as much as what it would add. It does not change the 18 February 2027 date from which the passport applies to the batteries in scope, and it does not give legitimate-interest readers access to point 3 test results, which remain in the notified body, market surveillance authority and Commission tier. The draft, if adopted, would enter into force on the twentieth day after its publication in the Official Journal, so the adoption and publication dates, not the feedback date, would set the start of any new access rule. This guide will be updated again when the act is adopted, or when the draft changes in a way that changes a named person, a point or a permitted purpose.

What limits apply to role claims?

A role claim states what a reader may see for a stated purpose. It does not state that the reader is competent to act on the detail, that the reader is authorised to repair or recycle a battery, or that the reader has any other regulatory authorisation. Competence and authorisation are separate questions, governed by separate rules. This guide gives general educational information only and does not give legal advice for a particular reader, role or access decision.