The Battery Passport framework is becoming more concrete as companies move closer to the February 2027 implementation deadline.
In August 2026, BatteryPass-Ready published version 2.0 of its Data Attribute Longlist, replacing version 1.3 released in March 2026.
The update reflects several important developments across the regulatory and technical landscape, including the final CEN/CENELEC JTC 24 standards, the EU DPP Registry implementing act, the European Commission's updated guidance on Battery Passport data points and draft rules on access to restricted data. BatteryPass-Ready also published a corresponding version 2.0 Data Model to support technical implementation.
For companies already working on Battery Passport implementation, the update provides useful clarification. While the overall list is shorter, version 2.0 provides more detail about which attributes apply to different batteries and under which conditions.
In other words, the question is becoming less about simply working through a long list of data fields and more about understanding which data actually applies to a specific battery.
A shorter and more precise list
Based on Minespider's comparison of the two published versions, the complete BatteryPass-Ready Longlist has been reduced from 100 attributes in version 1.3 to 92 in version 2.0. Three attributes were added, while eleven were removed, merged or consolidated.
The number of applicable data attributes has also changed depending on the battery category or applicability profile:
Note: The industrial battery profile without a BMS is an applicability profile introduced in v2.0; it is not a new legal battery category.
At first glance, fewer attributes may look like a simplification. But the update should not be understood as a straightforward reduction in Battery Passport responsibilities.
In several cases, attributes have been merged, consolidated or reformatted. Others have been placed into categories where their applicability depends on the battery type, its technical configuration or whether the underlying regulatory obligation is already in force.
That distinction matters in practice. A company should not simply compare the number of fields in an old template with the number of fields in the new version and assume that fewer fields mean less work.
The more important question is whether the right fields are being applied to the right battery.
Mandatory does not always mean applicable
One of the most relevant changes in version 2.0 is the clearer distinction between mandatory, conditional and voluntary attributes.
For example, the 87 attributes applicable to EV batteries in version 2.0 consist of:
- 69 mandatory attributes;
- six conditional attributes; and
- 12 voluntary attributes.
For stationary batteries above 2 kWh, the 88 applicable attributes include:
- 69 mandatory attributes;
- nine conditional attributes; and
- ten voluntary attributes.
This distinction is particularly important when companies assess their Battery Passport readiness.
A lower number of mandatory attributes should not automatically be understood as a reduction in implementation responsibilities. Some requirements have instead moved into the conditional category because their applicability depends on the battery category, its design or use, or whether the related regulatory obligation is already in force. This means that implementation increasingly requires context.
A data point may apply to one battery category but not another. It may depend on a particular technical configuration or it may only become relevant once a related obligation enters into force. Where a stated condition doesn’t apply, the field can normally be left empty or marked as not applicable.
Attributes described as "where possible" add another layer of interpretation. These should be provided where the information can reasonably and technically be generated. If the information cannot be provided, it's good practice for the responsible company to retain an explanation of the limitation.
This is one of the reasons why Battery Passport implementation is not simply a data collection exercise. Companies also need a clear understanding of why particular information is available, unavailable or not applicable.
How this connects with the latest Commission guidance
The update is consistent with the latest European Commission's Guidance Document: Digital Batteries Passport - data points by category Version 2.0 from 15 August 2026
The Commission's guidance groups Battery Passport requirements into 71 numbered data points for EV, LMT and industrial batteries over 2 kWh. Some data points cover multiple individual pieces of information, while the guidance shows whether each is mandatory, optional, conditional, or not required as of February 2027.
The guidance reinforces the importance of reviewing Battery Passport requirements by battery category. While core information such as the unique identifier, manufacturer, battery category, manufacturing date, capacity and chemistry is required across categories, other data points depend on the battery type or specific conditions.
It also distinguishes between requirements that apply from February 2027 and those that become relevant later, while highlighting dynamic information such as capacity fade, state of health, power and internal resistance that can change throughout the battery's lifecycle.
What does this mean in practice?
Companies that have already mapped their data against version 1.3 should review their templates instead of simply removing the attributes that are no longer listed as mandatory.
In practice, the review should confirm:
- which attributes apply to the relevant battery category and technical configuration;
- whether the conditions mentioned for the conditional attributes are triggered;
- whether previously used attributes have been merged, renamed or reformatted;
- whether access rights or identifier formats have changed; and
- which future obligations are not yet applicable but will need to be added later.
For many companies, this is also a useful opportunity to review how flexible their existing data structure is. A data point that is not currently applicable may become relevant later as additional regulatory obligations take effect. Building a structure that can accommodate those changes is likely to be more practical than repeatedly rebuilding templates as the framework develops.
The same applies to supplier and operational data. Companies may already have some of the information they need, but that information may sit across different systems, departments or supply chain partners. Understanding where the data comes from and how it will be maintained can be just as important as identifying the correct attribute.
The Longlist is an important resource, but it’s not the law itself
The BatteryPass-Ready Longlist is an important implementation resource, but it’s not itself a legal act. Companies should use it together with the EU Battery Regulation, the applicable delegated and implementing acts, European Commission guidance and the relevant technical standards.
This distinction is important as the Battery Passport framework continues to develop.
The Longlist helps translate a complex combination of regulatory and technical requirements into a structured implementation resource. But companies should not treat it as a substitute for understanding the underlying obligations that apply to their batteries.
BatteryPass-Ready has also confirmed that the Longlist and Data Model may be updated again as the framework develops. For companies, the main takeaway from version 2.0 is therefore not simply that the total number of attributes has decreased.
The framework is becoming more specific about which data applies, when it applies and under which conditions. That makes accurate applicability mapping increasingly important.
Preparing for implementation
Battery Passport readiness is not only about collecting a list of data points.
Companies need to understand where their data comes from, who is responsible for maintaining it and whether each attribute actually applies to the battery being placed on the market.
As February 2027 approaches, updates such as the BatteryPass-Ready v2.0 Longlist provide a clearer basis for reviewing existing implementation plans. They also highlight that flexibility will remain important. The framework is becoming more detailed, but it is still developing.
For companies already preparing, version 2.0 is a good reason to review existing data templates, assumptions and processes now rather than waiting until implementation is further advanced.
Minespider is a supporting partner of the BatteryPass- Ready project and continues to follow regulatory and technical developments closely. Our live Battery Passport solution is already aligned with the latest v2.0 data attributes, supporting companies as they prepare for implementation.
Disclaimer:
This article is based on Minespider’s analysis of the BatteryPass-Ready Data Attribute Longlist v1.3 and v2.0. The v2.0 Longlist is made available by the BatteryPass-Ready Consortium under the Creative Commons Attribution 4.0 International (CC BY 4.0) Licence.
Source: BatteryPass-Ready Consortium (2026). Battery Passport Data Attribute Longlist v2.0.
