Yes, it is possible to register a vehicle without a Certificate of Conformity (COC). The EC Certificate of Conformity is the manufacturer’s document confirming the vehicle’s approved type, but it is only one of several forms of evidence listed under Section 6(4) of the German Vehicle Registration Regulation (FZV) for first registration.
Issuing an individual vehicle approval under Section 13 EG-FGV or an operating permit under Section 21 StVZO costs €39.50 under fee item 223.1 of the official fee schedule. The technical inspection report required for the application is charged separately.
In some cases, you may not even have to provide the technical documentation yourself because the registration authority can retrieve the vehicle data electronically.
Can You Register a Car Without a COC Certificate?
Yes. The registration authority does not necessarily require one specific document. What it needs is sufficient evidence of the vehicle’s technical data and approval status.
One important distinction is often overlooked: the list in Section 6(4) FZV applies specifically to a vehicle’s first registration. If the vehicle has already been registered before, different rules may apply.
The key question is therefore not simply whether you have the COC document, but what type approval your vehicle has.
What Can Be Used Instead of a COC for Vehicle Registration?
Is a Certificate of Conformity required for vehicle registration? For a vehicle with EU type approval, the COC is the standard document, but even then there may be a route that does not require you to present the physical paper certificate.
If the COC certificate is not available, the registration authority may instead accept the German Registration Certificate Part II, a manufacturer’s data confirmation or a certificate of individual vehicle approval, depending on the vehicle’s approval status.
Section 6(4) of the Vehicle Registration Regulation defines four main categories, each subject to specific conditions.
Documents accepted for first registration under Section 6(4) FZV
| Document | Which vehicles does it apply to? | Legal basis |
|---|---|---|
| EC Certificate of Conformity (COC) | Vehicle with EU type approval | Section 6(4), no. 1 FZV |
| Registration Certificate Part II with type, variant and version codes, or data confirmation | Vehicle with national type approval | Section 6(4), no. 2 FZV; Section 20(3a) StVZO |
| Certificate of individual vehicle approval | Vehicle without type approval | Section 6(4), no. 3 FZV; Section 2, no. 6 FZV; Section 13 EG-FGV or Section 21 StVZO |
| COC, data confirmation or individual approval | Vehicle exempt from registration under Section 3(3) FZV | Section 6(4), no. 4 FZV |
In practice, the first three categories are the most relevant. They differ not only in the amount of work involved, but also in the conditions that must be met.
Manufacturer Data Confirmation: Only for National Type Approval
A data confirmation is intended for vehicles with national type approval. It is not a general replacement for a missing Certificate of Conformity.
Under Section 2, no. 8 of the Vehicle Registration Regulation, the document is issued by the holder of the national type approval and confirms that the vehicle complied with the approved type when it was manufactured.
Section 20(3a) StVZO requires the holder of the General Operating Permit to complete a data confirmation in accordance with template 2d for each vehicle subject to registration that complies with the approved type.
The document is unnecessary only if the Federal Motor Transport Authority has already made the type data available and the approval holder has entered the corresponding identification codes.
Individual Vehicle Approval or Operating Permit: What Is the Difference?
An inspection under Section 21 StVZO is only permitted if the vehicle does not belong to an approved type or if its operating permit has expired under Section 19(2) StVZO.
Section 21(1a) StVZO makes this distinction explicit. If the vehicle belongs to an approved type, or if an individual operating permit or an individual vehicle approval under Section 13 EG-FGV already exists, the procedure under Section 21 cannot be used.
Therefore, as long as your vehicle belongs to an approved type, a full inspection under Section 21 StVZO does not simply replace a missing COC certificate.
The Section 21 route primarily remains relevant for one-off vehicles, modified vehicles and imports from non-EU countries that do not correspond to a vehicle type approved within the European Union.
The two procedures cannot be distinguished simply by which authority issues them. Both the individual vehicle approval under Section 13 EG-FGV and the operating permit under Section 21 StVZO are issued by the authority responsible under the law of the relevant German federal state.
In both cases, the application is based on an expert report prepared by an officially recognised vehicle expert or a Technical Service. In practice, inspections are commonly carried out by organisations such as TÜV, DEKRA, GTÜ or KÜS.
When the Registration Authority Retrieves the COC Data Directly
There is one important situation in which you do not have to provide the technical document yourself.
Under Section 6(4), sentence 3 FZV, proof of the EC Certificate of Conformity is deemed to have been provided if the registration authority retrieves the relevant data electronically. The Vehicle Identification Number (VIN) is sufficient for this purpose.
The database is called the Central Database of Certificates of Conformity and is operated by Germany’s Federal Motor Transport Authority, the Kraftfahrt-Bundesamt (KBA).
According to the KBA, registration authorities have been able to access this database since 1 October 2019. If the vehicle data is not available there, the authority may be able to retrieve the information from the corresponding database of another EU Member State.
Before paying for a vehicle inspection, it is therefore worth asking your registration authority whether the necessary COC data is already available for your vehicle.
Which Document Does Your Vehicle Need?
The appropriate documentation depends largely on the origin and approval status of your vehicle. For a vehicle that has already been registered in another EU country, the foreign registration certificate will normally play a central role. For a vehicle imported from a non-EU country without an EU-approved vehicle type, an individual vehicle approval under Section 13 EG-FGV may be required.
Registration routes depending on vehicle origin
| Vehicle origin and status | Which documentation applies? |
|---|---|
| Used vehicle already registered in Germany | Proof is provided using the existing German vehicle registration documents. |
| Vehicle already registered in another EU Member State | This is not a first registration, so the list of documents in Section 6(4) FZV does not apply directly. If the authority is missing technical data, it may request an expert report under Section 6(8) FZV. |
| New vehicle from the EU, re-imported without a COC | First contact the seller. If the document is still unavailable, request the Certificate of Conformity from the manufacturer. If the vehicle has national type approval, a data confirmation may apply instead. |
| Vehicle imported from a non-EU country | If the vehicle does not correspond to a type approved in the EU, it must normally be inspected by an officially recognised expert, followed by individual vehicle approval under Section 13 EG-FGV. Proof of customs clearance must also be submitted under Section 6(7) FZV. |
| Vehicle without an approved type, such as a one-off vehicle | Individual vehicle approval under Section 13 EG-FGV based on an expert report; if the operating permit has expired following a modification, an operating permit under Section 21 StVZO may be required. |
How Much Do the Alternatives to a COC Officially Cost?
The administrative procedures have fixed official fees, starting at €39.50 for issuing the relevant approval. The amounts are defined in the fee schedule of the German Road Traffic Fee Regulations (GebOSt), most recently amended on 19 December 2025.
Fees according to the GebOSt fee schedule, net
| Service | Fee | Fee item |
|---|---|---|
| Issuing an operating permit under Section 21 StVZO or an individual approval under Section 13 EG-FGV | €39.50 | 223.1 |
| Allocation and issue of Registration Certificate Part II outside a registration procedure, including issue of the operating permit or individual approval | €49.70 | 223 |
| Full inspection under Section 21 StVZO or Section 13 EG-FGV, complete vehicle up to 3.5 tonnes | €97.90 | 413.4.1 |
| Time spent on inspections not specifically priced in the fee schedule, per started 15-minute period | €22.70 to €30.20 | 499 |
The inspection fee is charged in addition to the fee for issuing the approval, not instead of it, because the expert report is a prerequisite for the application.
If the authority cannot retrieve the data from the Federal Motor Transport Authority and the information is also unavailable in the local vehicle register, the fee under item 223 increases by €15.30.
VAT is charged on the expert’s fee as an expense under Section 2(1), no. 9 GebOSt. For official administrative acts, VAT applies only where those acts are themselves subject to it under Section 1(3) GebOSt.
When Is It Better to Request the COC Directly from the Manufacturer?
If your vehicle has EU type approval, the Certificate of Conformity is the intended evidence of that approval. In this situation, an inspection cannot simply replace the COC because an assessment under Section 21 StVZO is excluded for a vehicle that already belongs to an approved type.
You can request a replacement document from the manufacturer. Under Article 36(3) of EU Regulation 2018/858, manufacturers must issue a duplicate Certificate of Conformity during the ten years following the vehicle’s manufacturing date.
The manufacturer may charge for the duplicate, but the fee may not exceed the cost of issuing it.
If the vehicle has EU type approval and the COC is missing, requesting the Certificate of Conformity directly from the manufacturer will therefore often be simpler than pursuing an individual approval procedure.
