A Digital Battery Passport depends on data collected from across the organisation and, in many cases, from partners throughout the battery value chain. Engineering teams may own technical specifications, sustainability teams may manage environmental information, supply chain teams may coordinate supplier data, while IT teams manage the systems through which that information is collected and exchanged.
Without clear ownership, however, even a well-designed Battery Passport can become difficult to maintain.
From 18 February 2027, every electric vehicle (EV) battery, light means of transport (LMT) battery and industrial battery above 2 kWh placed on the EU market or put into service will require a Battery Passport under Regulation (EU) 2023/1542. The regulation requires the economic operator placing the battery on the market to ensure that the information in the Passport is accurate, complete and up to date.
This makes data governance a practical implementation issue. Organisations need to establish who is responsible for each type of information, who can approve it, who can change it and who remains accountable for its accuracy.
Why Data Governance Matters for the Battery Passport
Battery Passport information does not come from a single source.
A manufacturer may hold production and technical data in its ERP, MES or PLM systems. Sustainability teams may manage carbon footprint and recycled content information. Engineering teams may be responsible for performance and durability data, while supply chain teams coordinate information received from suppliers.
The Battery Passport itself also covers different levels of access. Under Article 77, information can be accessible to the general public, restricted to notified bodies, market surveillance authorities and the Commission, or made available to parties with a legitimate interest for specific purposes such as repair, repurposing and recycling.
A governance framework therefore needs to address two questions at the same time:
Who is responsible for the data, and who is allowed to access or change it?
Define Ownership at the Data-Field Level
Assigning ownership to an entire department is rarely enough.
Instead, organisations should identify the responsible owner for important Battery Passport data categories or individual attributes. The owner should understand what the information means, where it comes from and when it needs to be updated.
For example, responsibility could be structured around functions such as:
- Engineering: technical specifications, battery chemistry, design characteristics, performance and durability information.
- Sustainability: carbon footprint, recycled content, environmental and circularity information.
- Supply Chain: supplier information, material provenance and upstream documentation.
- Compliance: regulatory requirements, conformity information, validation and approval.
- IT and Data Teams: data architecture, integrations, access controls, security and system availability.
The precise allocation will vary between organisations. What matters is that responsibility is explicit rather than assumed.
Ownership and Approval are Not the Same
One of the most important distinctions in Battery Passport governance is between data ownership and data approval.
The person who creates or maintains a data field does not necessarily need to be the person who approves it for publication.
For example, an engineering team may provide a battery's technical specifications, while a compliance function verifies that the information meets the applicable regulatory requirements before it becomes part of the published Battery Passport.
This separation can create a useful control mechanism, particularly for information with regulatory or commercial significance.
A simple governance model could therefore define three roles:
- Data Owner: accountable for the accuracy and lifecycle of the information.
- Data Steward: responsible for maintaining, validating or coordinating the information.
- Data Approver: authorised to approve information for publication or a defined regulatory use.
Not every field needs three separate people. In smaller organisations, one person may perform multiple roles. The important point is that the responsibilities and approval rules are documented.
Build a Single Source of Truth
Battery Passport implementation can become complicated when the same information exists in several systems.
A battery's technical specification might appear in an engineering database, a product catalogue, an ERP system and a spreadsheet maintained by the compliance team. If those records are updated independently, inconsistencies can quickly emerge.
Organisations should therefore determine which system is the authoritative source for each important data category.
The Battery Passport platform can then retrieve or synchronise information from those sources rather than creating another isolated repository.
This approach also supports the regulation's requirement for Battery Passport information to be interoperable, structured and transferable through an open interoperable data exchange network without vendor lock-in.
Create Rules for Data Changes
Battery Passport data should be managed as a lifecycle rather than a one-time submission.
Some information may remain relatively stable, while other data can change as a battery is used, repaired, repurposed or remanufactured. Article 77 also allows responsibility for maintaining the Passport to transfer to another economic operator in certain lifecycle scenarios.
Organisations should therefore establish rules for:
- When data must be reviewed
- Who can modify each data category
- What requires approval
- How previous versions are retained
- How corrections are documented
- How changes are communicated to connected systems or stakeholders
This is where audit trails and evidence management become particularly important. A strong governance process should make it possible to understand what changed, when it changed and who authorised the change.
Protect Sensitive Information
Battery Passport governance also needs to account for confidentiality.
Not all Battery Passport information is intended for unrestricted public access. The regulation establishes different access rights and requires commercially sensitive information to be protected while still making necessary information available to authorised stakeholders.
This means organisations should define access at the data level rather than treating the Passport as either entirely public or entirely restricted.
Role-based access, authentication and appropriate permissions can help ensure that employees, suppliers, customers, authorities and other stakeholders receive only the information relevant to their role.
The technical design of the Battery Passport must also ensure data authentication, reliability, integrity, security and privacy.
Bring IT And Business Teams Together
Data governance should not sit entirely with IT.
IT teams provide the technical infrastructure, integrations and security controls, but business functions understand the meaning and use of the information. Engineering knows the product. Sustainability understands environmental indicators. Supply chain understands suppliers and upstream data. Compliance understands regulatory obligations.
A cross-functional Battery Passport governance team can bring these perspectives together.
A practical governance process might begin with a Battery Passport data catalogue that records each attribute, its source system, owner, steward, approval requirements, access level and update frequency.
This creates a common reference point for both business and technical teams.
Start With the Current Data Requirements
The European Commission's latest guidance for the Digital Battery Passport brings together 71 data points relevant to EV, LMT and industrial batteries, identifying their legal sources and applicability for February 2027. The Commission notes that the guidance is intended to help economic operators identify the information they may need to collect, assess and make available.
Organisations can use this as a starting point for their governance exercise.
For each applicable data point, ask:
Where does this information come from? Who owns it? Who maintains it? Who approves it? Who can access it? What evidence supports it?
The answers will expose gaps in both data management and organisational responsibility.
BASE's Battery Passport Data Attribute Longlist v1.3 can also support this exercise by helping teams structure their understanding of Battery Passport information.
How BASE Can Help
The BASE project is developing and validating a trusted and interoperable Digital Battery Passport framework and platform, with a focus on traceability, secure data exchange and lifecycle information across the battery value chain.
Data governance is closely connected to this work. A Battery Passport needs clearly structured information that can move between systems and organisations while maintaining appropriate access controls, reliability and traceability.
BASE's work on Article 77 and Battery Passport data modelling highlights the importance of creating a structured data architecture capable of supporting manufacturing, operation, maintenance, repurposing, reuse and recycling.
The project's resources on DIN DKE SPEC 99100, JTC 24 standards and Battery Passport data attributes can further help organisations understand how regulatory information requirements connect with technical data structures and interoperability.
For manufacturers and OEMs, this provides a practical foundation for deciding not only what information needs to be collected, but who should be responsible for keeping that information reliable throughout its lifecycle.
Building a Clear Battery Passport Governance Model
A successful Digital Battery Passport requires more than a data collection exercise. It requires an organisational model that gives every important piece of information a clear owner and a defined path from creation to approval and publication.
For battery manufacturers and OEMs, the starting point is straightforward:
Know your data. Assign ownership. Define approval. Control access. Track changes.
With these responsibilities established early, organisations can reduce duplication, improve data quality and create a stronger foundation for meeting the Battery Passport requirements from 2027 onwards.
The BASE project has received funding from the Horizon Europe Framework Programme (HORIZON) Research and Innovation Actions under grant agreement No. 101157200.
References & Resources
European Union - Regulation (EU) 2023/1542: https://eur-lex.europa.eu/eli/reg/2023/1542/2025-07-31/eng
European Commission - Digital Product Passport For Batteries: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en
European Commission - Guidance To Support Preparations For The Digital Batteries Passport: https://single-market-economy.ec.europa.eu/news/guidance-support-preparations-digital-batteries-passport-2026-08-21_en
BASE - Article 77 Explained: Building A Compliant Digital Battery Passport Data Model: https://base-batterypassport.com/blog/regulations-4/article-77-explained-building-a-compliant-digital-battery-passport-data-model-111