EU Battery Passport Rules Put Midnight’s Privacy Technology to the Test

The European Commission published a draft implementing regulation on October 19, 2026, defining who may access restricted information in digital battery passports and under what conditions.

The proposal comes ahead of February 18, 2027, when digital passports become mandatory for electric vehicle batteries, light means of transport batteries, and industrial batteries exceeding 2 kWh.

Among the projects developing technology for this requirement is NightPass, an application built by ODATANO using Midnight. Its privacy-focused architecture offers a practical example of how blockchain verification and controlled data disclosure could support European battery compliance.

EU Proposal Defines Access to Sensitive Battery Information

Under Regulation (EU) 2023/1542, battery passports will contain information covering product identification, technical characteristics, sustainability, performance, and lifecycle management.

Some information must remain publicly accessible. Other records, including detailed battery composition, dismantling instructions, and certain operational data, require restricted access.

The Commission's new proposal further identifies which participants may access specific categories of information and the purposes for which those records can be used.

Repairers, remanufacturers, repurposers, and recyclers may require technical information to perform their activities. Battery purchasers and authorized representatives have different rights involving individual battery information.

These distinctions create a practical challenge for digital passport providers. A system must determine not only whether a user has permission to view data, but also which information that permission covers.

The draft remains open for public feedback until November 16, 2026. Its provisions may change before adoption.

Midnight’s NightPass Demonstrates Privacy-Preserving Verification

ODATANO's NightPass is designed to provide different views of the same battery passport to consumers, recyclers, and regulatory authorities.

Rather than publishing sensitive battery information directly on a blockchain, the application keeps confidential records encrypted outside the network. Midnight stores cryptographic commitments and verification records that can be checked without exposing the underlying dataset.

Access permissions are managed through the application layer, while blockchain transactions can record authorization changes associated with individual passports.

NightPass also supports zero-knowledge proofs, allowing selected information to be verified without revealing its original value.

For example, a manufacturer could demonstrate that a battery's carbon footprint falls below a specified threshold without publishing the exact measurement.

The project operates a public demonstration on Midnight's Preprod network. Users can create sample battery passports, anchor their records, and verify cryptographic claims through an explorer.

Its documentation also describes versioned battery records and ownership transfers, allowing a passport's history to remain verifiable as the battery moves through different stages of its lifecycle.

These capabilities have been demonstrated in a development environment, rather than confirmed through commercial deployment with battery manufacturers.

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New EU Rules Create a More Specific Test for NightPass

The Commission's proposal introduces distinctions that go beyond NightPass's currently documented consumer, recycler, and authority access categories.

A production system would need to support more granular permissions, including differences between repairers, recyclers, purchasers, and third parties acting on their behalf.

Identity verification presents another requirement. A blockchain authorization record can establish that permission was granted, but it does not independently prove that its holder is a legally authorized repairer or the rightful purchaser of a particular battery.

NightPass would therefore need an appropriate mechanism for connecting verified real-world identities and legal roles with its digital access controls.

The European Commission has not selected Midnight, Cardano, or any blockchain network as an official battery passport infrastructure. Blockchain and zero-knowledge proofs are not mandatory technologies under the EU framework.

ODATANO documents interoperability testing and integration capabilities for NightPass, but these do not constitute an official EU certification or confirmation of full regulatory compliance.

The next regulatory milestone is November 16, 2026, when public consultation closes. The battery passport obligation is scheduled to begin on February 18, 2027.

For NightPass, the specific implementation challenge is to translate the final EU access categories into verifiable permissions while preserving the separation between confidential battery information and the cryptographic records maintained on Midnight.