Relics of the Past: Paper Processes

01 December 2021 by Jens Cram

The change is coming slowly, and the signs of change might still easily be overlooked. But if one looks closely, it is hard to deny that an era is coming to an end for vehicle homologation and registration. This era was the era of paper processes, where ownership of a vehicle was bound to the possession of paper certificates, where the correctness of data was secured by signatures and copy-proof paper, and where official documents were part of a vehicle manufacturer's corporate design. It was also the era of Word and Excel. But the old paper processes are giving way for the young generation of the digital age.

What are the signs?

Firstly, e-government processes in vehicle registration have already been introduced by many countries within the EU. Here in Germany, for instance, you can register your vehicle online (even though you will still receive a paper registration document via post afterwards).

Secondly, the paper Certificate of Conformity (COC) is being replaced by its electronic successor. Already, many governments in the EU have started introducing the electronic COC.1 Looking again at the German example, manufacturers of any type approved vehicle are by law required to transmit the electronic COC since 2019,2 making registration data available for the German government in one central source. Thus, for market surveillance or police control, physically looking into the official COC paper or the official registration document would not even be required anymore.

In 2026, electronic COCs will become mandatory throughout the EU for manufacturers of cars, trucks and trailers.3 Other vehicle categories are bound to follow. The paper COC, which is currently still mandatory, will, in exchange, become completely optional. It is not hard to imagine that paper registration documents will, sooner or later, disappear completely.

Thirdly, interdisciplinary teams have already formed, thinking about the optimal format for a digital type approval documentation. When this step will follow is, to our knowledge, still open, but already the path is being laid out. It would mark the final step in the conversion to the new era of e-government in Homologation.

Turbulences ahead

As with every change, while it is good and necessary, the end of this era will cause its minor or major turbulences. Moving away from paper processes is a major change, not only for governments, but also for the manufacturers. And while large enterprises will have the capital and the lobby to easily navigate through those turbulences, the smaller and mid-size competition is at risk of being heavily shaken by what lies ahead of them.

The old paper documents bring along some "advantages" which easily allow for manual and semi-manual processes:

The documents are strictly intended for human readability. That means on the one side, that a human can easily read, understand and maintain the document, which is why Word and Excel solutions are still well established at a large number of manufacturer's. On the other side, human readability allows for flexibility. Instead of formally listing specific data, you can just as well reference to some attachments or drawings, where the information is provided implicitly, knowing that the human who will read the document, will understand. Neither the data nor their presentation are formally strictly binding. In the result, short-cuts and workarounds are implemented everywhere in the manual and semi-manual processes.

This is where Excel and Word will not be of much help anymore. As a consequence, manufacturers will have to invest in IT, some of them without having the budget to do that.

A promise of a bright future

To be clear: The change is worth the investment. If you once start mentally disconnecting from the old ideas of paper government, a lot of "problems" companies are now solving just dissolve into thin air.

Having to deal with paper documents put a high emphasis on document layout. Conditions like getting all the information on two A4 pages, avoiding nasty line and page breaks, and having a format in accordance with the company's corporate design, where equally crucial as the formal correctness of the data on the documents. In the end, this was a huge driver for manual processes based on Word templates, because Word allows you the individual handling of format adjustments. IT solutions on the other hand always struggle here, having to find compromises to achieve the goal of more automation. For digital formats, all of this is irrelevant, so automation actually becomes much easier.

Document layout was not only important for the eye, it became to some degree the formal proof of validity of the documents. An example COC had to be attached to every type approval application. A COC in a different layout consequently lost its validity. This meant, that with a change in the corporate design, the type approval would have to be refreshed. Or, something we frequently encounter, when introducing a standard solution like VCX, additional customization of the COC layout has to be invested in because the "standard layout" provided by default would not be accepted as a valid COC. Now, just to say that very explicitly: the format of a document should have no connection at all to the validity of its contents. Going away from paper documents will just make the whole discussion go away.

“When Digital Transformation is done right, it is like a caterpillar turning into a butterfly”

George Westerman Scientist at the MIT Center for Digital Business

Having to provide an "original" and "official" paper document also comes with having to provide tools and processes to protect against forgery. It is strictly mandatory that only one original document is generated and that original is to be designed in a way to be copy-proof. Manufacturers are investing in special paper or even special printers to achieve that condition. In addition, manufacturers have to provide for processes to supply duplicates in case the original is lost. Being the sole owner of the data and the format, only the manufacturer could do that. Manufacturers are also formally required to be able to provide a duplicate of the COC up to 10 years after the original was provided, and informally even well beyond that. If, in the future, the data of the vehicles are centrally available at the registration authorities, and no paper documents are distributed anymore, such a process is completely superfluous.

These are only examples, and the list could go on for quite some time. But it should make clear that paper government comes with its specific burdens, which are in the end highly unnecessary and a major blocker for any attempt to automate processes. The digital transformation to e-government processes promises a much brighter future.

A bright future for everyone

All of this shows, that paper government really is just a relic of the past, still living, but without a long history ahead of it anymore. And that is good. The digital future really promises to be much better for all participants.

In the end, all boils down to only one open question: How can we make sure that no manufacturer is lost on the way? As noted, the requirements for the digital transformation bring the risk to have quite heavy investments into IT coming, and not every company will have the resources to stem those investments alone.

From our point of view, there is only one solution: Standard IT solutions, ready for every manufacturer to use, out of the box. That is why we introduced VCX. By providing a standard cloud solution for type approvals and vehicle registration, the IT investment is evenly distributed across many manufacturers, making the transformation effortless and affordable. This way, every manufacturer, no matter how big or small, can equally participate in the advantages of the new era of e-government processes.

The digital transformation is good. Let's make sure that it is good for everyone.


For an overview over the status of implementation in Europe, see this Link, and this link especially
"Vierte Verordnung zur Änderung der Fahrzeugzulassungsverordnung und anderer straßenverkersrechtlicher Vorschriften", §45a
Regulation (EU) 2018/858,Article 37

If you've enjoyed our article, look to the right to find a selection of related content and services.