The passport needs tiered access. Annex XIII point 1 is public. Under Article 77(2), notified bodies, market surveillance authorities, and the Commission can access the model information in points 2 and 3. Persons with a legitimate interest can access the point 2 model information and point 4 individual-battery information only for the statutory purposes and within the access rules set by the Article 77(9) implementing act.
The passport must be accessible through the QR code referred to in Article 13(6). That QR code links to a unique identifier attributed by the economic operator placing the battery on the market. Article 78 adds technical controls: free access based on access rights, open and interoperable formats, restricted update rights, data integrity, security, privacy, and continued availability.
Article 77(9) requires the Commission to specify by 18 August 2026 who qualifies as a person with a legitimate interest, which point 2 and point 4 information each person may access, and the extent of download, sharing, publication, and re-use rights. A passport design should keep those permissions configurable instead of treating all repair, second-life, energy-market, or recycling users alike.