For vehicle manufacturers, homologation teams and production operations in Europe and the United Kingdom.
A NAP outage needs a controlled recovery process: preserve the released file, distinguish unsent records from uncertain submissions, and use an alternative route only after its access and operating conditions have been confirmed. After service resumes, reconcile the receiver’s results before closing the incident.
This article proposes a manufacturer continuity plan. It covers the operational gap between a vehicle record being ready and the receiving service being available. It does not assume that a manufacturer can guarantee authority availability, route around every downstream dependency or replace a required electronic exchange with a PDF.
The EReg IVI NAP Q&A discusses applying to two NAP operators as a continuity measure. It also explains that delivery, international distribution and registration involve different parties. An alternative NAP therefore needs advance preparation and may not resolve a failure affecting a shared downstream service.
| Observed condition | Initial investigation | Operational response to prepare |
|---|---|---|
| Manufacturer cannot dispatch | Local application, connection, credentials and signing availability | Hold released records and assign an internal recovery owner. |
| Selected NAP unavailable | Operator notice and the last successful exchange | Evaluate the already authorised alternative route. |
| Requests time out | Whether the receiver processed any request | Reconcile uncertain attempts before retrying. |
| Receiver accepts but retrieval fails | Onward availability and the retrieval service | Escalate with acceptance evidence; avoid uncontrolled new versions. |
| UK service unavailable | VCA service instructions and support | Use the UK recovery procedure; an EU NAP is not a substitute. |
A single ‘failed’ status hides the decision that matters most: did the receiver process the record? Use separate operational groups for released-but-unsent files, attempts with a known rejection, and attempts with an unknown outcome. These groups are suggested internal controls, not universal NAP status codes.
Freeze the signed release candidate while investigating. Keep its digest, approval context and business version. If vehicle data genuinely needs correction during the outage, handle that through a separately reviewed release decision; do not silently replace the file waiting in the dispatch queue.
The EUCARIS implementation guidance describes the manufacturer’s choice of NAP. That choice should become a practical onboarding checklist: confirm the manufacturer identity, accounts, certificate arrangements, supported profile, test route and production permission with the operator. A URL that responds is not evidence of completed onboarding.
Do not promise an automatic switch unless that behaviour has been agreed, implemented and demonstrated for both routes. A controlled manual decision can be appropriate where volumes are low or receiver reconciliation requires human review. The decision should be visible to the people releasing vehicles and handling registration enquiries.
Define an internal target for recognising the outage, a target for deciding how to handle queued records, and a target for reconciling outcomes after recovery. Base them on production schedules, dispatch volumes and registration dependencies. Keep these internal targets distinct from an operator’s published service commitments.
For each target, identify the clock start, responsible person and escalation channel. ‘Resolve immediately’ is not an actionable rule. ‘Operations checks the operator notice and opens a case after the agreed trigger’ can be tested. Neither an internal target nor a software dashboard establishes a legally guaranteed registration time.
Illustrative exercise: twelve records have not been dispatched, three requests timed out and two files have explicit validation rejections. On service recovery, do not place all seventeen into a common resend batch. Send the twelve through the agreed normal or alternative route; reconcile the three unknown outcomes; assign the two rejections to their data owners.
Then compare the recovered results with the queue and the retained file versions. The exercise passes when each vehicle has an explained outcome and no record was lost or issued again merely because its status was unclear. Use fictitious vehicles in an authorised test environment for rehearsals.
VCA operates a separate UK portal and API rather than an EUCARIS NAP. A manufacturer supplying both markets should document two receiving routes and their support responsibilities. Do not assume that sending a UK record to an EU point fulfils a UK submission obligation.
In the UK plan, retain the account owner, environment, submitted file, receiver response and current support route. Include the same uncertain-outcome scenario in testing. Keep local process documentation current as the receiving service evolves.
Discuss this plan alongside your NAP delivery preparation and portal or API operating model. Electronic COC can be evaluated against the manufacturer-side visibility and review steps you need; operator access and interface behaviour require their own verification. Arrange a workflow review with a representative outage scenario.
EReg’s manufacturer Q&A discusses two NAP operators as a continuity measure. Confirm onboarding, authorisation, supported files and operating procedures with each operator before relying on an alternative in production.
A timeout can leave the processing outcome unknown. Follow the receiver’s documented reconciliation and repeat-attempt procedure. Keep the original request reference and released file so that recovery does not create conflicting records.
Do not invent an alternative filing method. Follow the authority or receiving operator’s current contingency instructions for the vehicle and destination, and retain any written direction received.
An alternative entry point may still depend on the same receiving country or downstream service. Diagnose the failed boundary and confirm the alternative’s reach before activating it.
Reviewed on 16 October 2026. Authority statements below are distinguished from our suggested operating controls. Receiving-system instructions and the applicable approval scheme govern the actual submission.
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