How to choose battery passport software: criteria, questions for providers and red flags

You can tell good battery passport software not by how many features it lists but by how it meets the requirements of the Battery Regulation. Articles 77 and 78 call for open, machine-readable data that can be transferred without vendor lock-in, access rights by tier, assured integrity, and a passport that stays reachable even after your company is gone. There is no approval, certification or authority-kept list for battery passport software. Responsibility for the data stays with you, whoever you hire.

This page turns those requirements into criteria and questions for any provider, and compares four provider types: ERP module, specialised platform, consultancy project and in-house build. Whether building your own is worth it is covered in Build or buy; the basics are in the battery passport guide.

What does the Battery Regulation require of the software?

The Regulation regulates the passport, not the software, but what a system must do follows from it.

Add the contents of Annex XIII, the QR code under Article 13(6) and the battery management system data under Article 14. What that means for your category is on Data fields; who may see which tier is on Access tiers.

Is there an approval for battery passport software?

No. The Battery Regulation neither defines nor regulates “solution providers”. Whether you use one is your decision, and your relationship with it is governed only by your contract (Commission FAQ, question 10.3).

Three things are easily confused:

• The registry knows verified service providers. Implementing Regulation (EU) 2026/1778 provides for a list of verified digital product passport service providers in the registry (Article 3, point (f)). What is verified is identity, for example through a qualified electronic seal, not software. Even the registry's automatic checks at registration are expressly not proof that Union requirements are met (recital 16).
• The harmonised standards for digital product passports belong to the Ecodesign Regulation. Implementing Decision (EU) 2026/1736 lists six standards, covering identifiers, data carriers and interfaces among others. They give a presumption of conformity with Articles 10 and 11 of the Ecodesign for Sustainable Products Regulation, not with the Battery Regulation. At our check there was no harmonised standard covering Article 78 of the Battery Regulation.
• Rules for service providers exist only under the Ecodesign Regulation, and only later. The Commission may set requirements for digital product passport service providers there, possibly with a certification scheme (Article 11 of that Regulation). On 25 October 2026 no draft had been published.

Who stays responsible when a provider runs the passport for you?

You do. The economic operator placing the battery on the market ensures that the passport information is accurate, complete and up to date, and may authorise others in writing to act on its behalf (Art. 77(4)). The Commission makes clear that such an authorisation does not transfer legal responsibility (FAQ 2.1 and 2.4). The registry works the same way: a third party registering on an operator's behalf must be verified itself, and the operator remains fully responsible (Article 19(4) of Implementing Regulation (EU) 2026/1778).

In Germany, failing to ensure, contrary to Article 77(4), that passport information is accurate, complete and up to date is an administrative offence with a fine of up to EUR 10,000 (BattDG, section 60(2) no. 29 and 60(3)). It is aimed at the economic operator that Article 77(4) obliges, not at the software provider. So choose a system that keeps you in control: you need to see where every value came from, who approved it and what has been published.

Article 78(d) limits what a provider may do with your data: anyone storing or processing passport data on your behalf may not sell, re-use or process it, in whole or in part, beyond what the storage and processing service requires. Have this confirmed in the contract, explicitly covering benchmarking and the training of AI models as well.

Which criteria should you use?

For each criterion the table gives the question to ask and what a good answer looks like. An honest “not yet, and here is the plan” is worth more than a yes without evidence.

What provenance and four-eyes review look like day to day is described in Provenance and four-eyes review; supplier requests without accounts in Supplier data without supplier accounts.

How do the provider types compare?

We compare types, not products; the criteria above apply to every one of them.

Hybrids are common: a specialised platform for the passport and review, connected to the ERP through an interface built by your IT or a service provider. Then decide which system owns which value. What such a connection looks like is shown in our integration patterns and in Connecting the battery passport to SAP, Business Central and Odoo.

Which questions expose weak answers?

These questions have a right answer that you can check yourself.

• “Do you already register our passports with the EU?” The correct answer today: the registry launched on 20 July 2026 and companies can use a test environment, but its interface and the semantic repository for batteries are not yet complete (as of our check on 25 October 2026). To register, an economic operator must be verified, as a legal person with a qualified electronic seal or a qualified electronic attestation of attributes (Article 4(2) of the Implementing Regulation). Anyone claiming more should be able to show it.
• “Is your software approved by the EU?” The correct answer is: no, there is no such thing.
• “Which fields are mandatory from February 2027?” A good answer distinguishes by category and by legal status: carbon footprint, recycled content and due diligence information are not yet required at the start (FAQ 7.2, Commission guidance version 2.0). Software that flags every field as mandatory straight away is not checking carefully.
• “Who may see the restricted information?” Who counts as a person with a legitimate interest is for an implementing act under Article 77(9), not adopted at our check; a draft has been open for feedback since October 2026. A provider that calls this “solved” is getting ahead of the act.
• “What happens to our QR codes if we cancel?” A good answer is specific: a redirect for an agreed period, a move to your domain, an export of every passport.
• “Which data format do you export?” There is no binding data model for batteries yet; the registry's semantic repository is meant to supply it (FAQ 11.1). A good provider tells you how it will switch over.

How do you get out again?

Plan the exit before you sign. Article 77(5) requires passport data to be transferable through an interoperable network “without vendor lock-in”. In practice:

1. Full export. Not just the published passports but models, units, values with their history, evidence, approvals and the audit log. Ask for a sample file and check that your IT can read it.
2. Your own identifiers. The unique identifier is assigned by the economic operator placing the battery on the market (Art. 77(3)). It should not depend on the provider. GS1 Digital Link with your GTIN is one way; the Regulation names no particular scheme, only ISO/IEC 15459 or equivalent standards.
3. The address in the QR code. If it sits on the provider's domain, you need a contractual redirect after cancellation. If it sits on your own domain, you can move.
4. Continued operation. The Regulation sets no fixed period: the passport only ceases to exist once the battery has been recycled (Art. 77(8)). Until then, someone has to serve it.

What belongs in the offer and the contract?

Pricing models vary (per unit, per model, per organisation or per project), and none is better in itself. What matters is comparing costs over the life of your batteries. Ask about:

• The unit of charge: what is counted, published passports, units, models, users, API calls or storage?
• The installed base: what does a published passport cost in later years when no new units are added?
• The end of the contract: who keeps serving published passports, for how long and at what price?
• Export: is the full export included in the price?
• Legal changes: are new fields and acts included, or each a change request?
• Registration: is submission to the registry included once it becomes possible?
• Integration: who builds and maintains the connection to your ERP?
• Data processing: is there a contract under Article 28 GDPR with a list of sub-processors, and can they change only with your authorisation?

How do you test a provider in practice?

With your own data rather than a demo. Allow two to four weeks and cover the whole route:

1. Create a real model with its data sheet and declaration of conformity.
2. Import twenty real serial numbers from your ERP and read the validation report.
3. Send a request to a real supplier.
4. Have a second person approve a value.
5. Publish a passport and scan the QR code with an ordinary phone.
6. Check the public response to confirm that restricted fields are absent.
7. Export everything and have your IT open the file.

Where this stumbles tells you more than any feature list.

Where does BatteryPass stand?

BatteryPass is a specialised platform, so we are one of the providers you should test with these questions. No customer runs BatteryPass in production yet. Server-side access tiers, provenance of every value, four-eyes review, supplier requests without accounts, signed and versioned passports with GS1 Digital Link QR codes and the full export are in testing in testing. Access to the restricted tiers is limited until the act under Article 77(9) limited; managed ERP connections and submission to the EU registry are planned planned. Responsibility for the data stays with you. The full picture is on the product page and on Security.