Mandate Math: Why the UK’s 28% EV Target is More Complicated Than It Looks

On paper, the UK’s ZEV mandate seems straightforward: carmakers must ensure 28% of their sales are electric vehicles this year. However, the real-world “mandate math” is far more complicated, thanks to a system of credits and flexibilities that obscure the true target and soften the regulation’s impact.
The recent record in EV sales has pushed the year-to-date market share to 22.1%. While this is a significant step forward, it still appears to leave a substantial 5.9% gap to the 28% target. But this simple subtraction doesn’t tell the whole story. The mandate allows carmakers to use various “flexibilities” to achieve compliance.
These mechanisms, made more generous by the government in April, allow manufacturers to earn credits for things other than selling pure EVs. For example, they can gain credits for the emissions performance of their remaining petrol and diesel fleet. This means they can meet their legal obligations while selling fewer electric cars than the headline target suggests.
This complexity has led thinktanks like New Automotive to calculate a “true” effective target. Their analysis suggests that once all the loopholes are factored in, the actual requirement for battery EV sales is below 22%. This implies that the industry may not be trailing its ambition, but rather that the ambition itself has been quietly lowered.
This complicated mandate math matters. It means that while the government can publicly champion a high target, the actual regulatory pressure on the industry is less severe. It creates a situation where impressive-looking sales figures, like those seen in September, can mask a less aggressive and potentially less effective push towards full decarbonization.