ZEV mandate: carmakers need 265,000 more EV sales by year end

Carmakers need roughly 265,000 battery electric car registrations in October, November and December to hit the ZEV mandate’s 33% target for 2026, according to the SMMT. By our calculation that is close to six in every ten new cars expected in the quarter, more than double the share achieved in a record September. For anyone buying an electric car before Christmas, it means the pressure behind today’s EV discounts is not going away.

The gap remains despite the best month ever for electric car sales. In September, 99,199 battery electric cars were registered, up 36.3%, a 28.3% share of a market that grew 12.1% to around 350,500 cars, its best September since 2017 (electrive). We cover the full figures in our September sales report. Across the first nine months, though, 454,945 battery electric cars took a 26.2% share, well short of 33%.

How big is the gap to the 33% target?

The SMMT’s sums use its latest outlook of a 2.183 million car market for 2026. A 33% share of that is about 720,000 battery electric cars, so after 454,945 so far, about 265,000 more are needed before 31 December.

Measure	Figure
2026 ZEV mandate target for cars	33%
2025 target	28%
SMMT full-year BEV forecast, January 2026	28.5%
BEV share, September 2026	28.3% (99,199 cars)
BEV share, January to September 2026	26.2% (454,945 cars)
SMMT 2026 market outlook	2.183 million cars
Extra BEVs needed in Q4 to reach 33%	about 265,000

The January forecast comes from SMMT’s first market update of 2026, which already expected the year to fall short.

By our calculation, a 26.2% share implies about 1.74 million cars registered so far this year, leaving about 447,000 for the final quarter if the SMMT outlook holds. Reaching 33% would therefore need about 59% of all Q4 registrations to be battery electric. The table below shows what different outcomes would mean for the full year.

If Q4 brings…	Q4 BEV share	Q4 BEVs (approx)	Full-year 2026 BEV share
A repeat of September’s record share	28.3%	126,000	26.6%
Enough to match the 2025 target	35%	156,000	28.0%
Enough to match SMMT’s January forecast	37%	167,000	28.5%
Enough to hit the 2026 target	59%	265,000	33.0%

EV Compared calculations based on SMMT’s 2.183 million outlook and year-to-date figures, rounded.

The first row is the uncomfortable one for the industry. Even if every month of the quarter matched September’s record share, 2026 would end at about 26.6%, below last year’s 28% target, let alone this year’s 33%.

Will carmakers reach 33%, and does it matter if they miss?

On sales alone, they will not. A jump from 28.3% in the best month on record to 59% across a whole quarter is not realistic. But the target applies to each manufacturer rather than to the market as a whole, and the mandate’s flexibilities, widened in 2025, lower the effective requirement. Brands can borrow credits against future years, earn credits by cutting CO2 emissions from their petrol and hybrid cars, and buy credits from rivals that are ahead of target. Our guide to how the ZEV mandate works covers those rules in detail.

So the headline 33% overstates how many EVs each brand must actually sell this year. It does not remove the pressure. Borrowed credits have to be paid back in later years, and credits bought from a rival cost money. Every extra EV registered before 31 December reduces both. The SMMT has argued that the mandate’s targets are running ahead of consumer demand.

Plug-in hybrids do not close the gap. They rose 55.7% to a record 59,563 in September, a 17% share, but they do not count towards the zero emission target, though they can help a brand indirectly by cutting the average CO2 of its non-electric cars.

Why the gap points to bigger EV discounts

The SMMT credited September’s record to greater model choice, manufacturer incentives, the Electric Car Grant and high fuel prices. Choice is not the problem: Transport + Energy counts 178 battery electric models on sale. Price is the lever carmakers can pull fastest.

They have already been pulling it. Trade title AM Online described the plate-change surge as discount-led and said it was testing dealer margins, with the average new car discount reaching 10.5% of list price against 9.8% a year earlier. Lender Marsh Finance also put September discounts at 10.5%.

Finance offers already run to mid-December

Vauxhall’s 0% APR offers apply to orders placed between 1 October and 15 December 2026. A closing date that leaves time to register cars before the year ends is what you would expect from a brand watching its 2026 numbers.

Brands outside the grant are funding their own

The Electric Car Grant takes £3,750 or £1,500 off eligible EVs with a list price of £37,000 or less, but its scoring of manufacturing emissions rules out China-built cars. Several of those brands now fund their own discounts instead: Leapmotor applies a £1,500 “Leap-Grant” and MG a £1,500 saving on the China-built MG4 Urban, while BYD offers five years’ servicing on the Dolphin Surf, Dolphin and Atto 3 (Fleet News).

Less reason to push petrol

Because each brand is judged on its own sales mix, every petrol or hybrid car it registers raises the number of EVs it needs to sell. Brands short of their target have good reason to put their marketing money behind electric models until Christmas.

Could the ZEV mandate review take the pressure off?

The government’s review of the ZEV mandate opened on 14 August 2026 and closes at 11:59pm on 23 October 2026. It sets out options to lower the 2030 car target, and some of its pathways would lower targets from 2027.

2030 car target	Status
80%	Current law
70%	Review option
60%	Review option, also proposed by dealer body the NFDA on 25 September
50%	Review option

We explain the options in our report on the 2030 target consultation. For buyers, the logic is simple: mandate-driven discounts exist because targets run ahead of demand, so if the review lowers targets from 2027, brands have less reason to subsidise EVs heavily next year.

What this means for you

Our take: if you plan to buy or lease an electric car in the next few months, the final quarter of 2026 looks like a strong time to do it, as long as the car can be registered before 31 December.

• Stock beats factory orders. A car delivered in January counts towards a brand’s 2027 figures, not 2026. Ask which cars can be registered before Christmas, and push hardest on those.
• Keep the grant and the discount separate. Ask the dealer to show the Electric Car Grant and any dealer or manufacturer discount as separate lines, so you know the discount is on top of the grant rather than instead of it.
• Compare finance, not just price. A 0% APR deal can be worth more than a cash discount over a few years. Our guide to leasing, PCP or buying shows how to compare them.
• Watch the deadlines. Vauxhall’s 0% offers end on 15 December, and the Electric Car Grant can close early if its funding runs out. We look at how long the funding might last in our grant funding report.
• Shop around. Not every brand is under the same pressure. Those already ahead of target have less reason to cut prices, so a rival’s offer is your best bargaining tool.

Should you wait until 2027 instead? We would not bank on it. If the review softens targets from next year, the main force behind mandate-driven discounts weakens, and the grant can close early if its funding runs out. If you are ready to buy, a well-negotiated deal registered before 31 December is the safer bet.