From 1 April 2027, EPO mandatory electronic filing and notification will apply in European, PCT and Unitary Patent proceedings: documents must be filed electronically, and anything sent by post will have to be refiled electronically within two months of an invitation, or a European application will be refused. EPO communications will be notified electronically as the rule. It matters most to applicants and local agents in Latin America and Africa who still use paper.
Update (October 2026): the EPO published on 30 September 2026 the President’s implementing decisions and a notice dated 8 September 2026. They confirm that Online Filing 2.0 will be the standard tool, that the two-month refiling period cannot be extended, that a PCT application not refiled in time is considered withdrawn, that postal filings pay the paper filing fee and that, without a MyEPO Mailbox, the EPO will generally notify by public notice. OJ EPO 2026, A43; EPO news, 1 October 2026.
Key takeaways
- The legal basis is decision CA/D 2/26 of the Administrative Council of 19 March 2026, which amends Rules 2, 114, 125, 129 and 134 EPC, among others, with effect from 1 April 2027.
- Paper filing remains possible to secure a date, but documents must be refiled electronically within two months of the EPO’s invitation.
- If a European application is not refiled in time, it is refused; later documents not refiled are deemed not received.
- Notification will be electronic; if it cannot be made for reasons within the addressee’s sphere, the EPO will notify by public notice.
- Third-party observations will only be accepted electronically.
What exactly changes on 1 April 2027?
The Administrative Council’s decision CA/D 2/26, published in the Official Journal in April 2026, rewrites the rules on filing and notification. The EPO summarised the change in its news of 23 July 2026, noting that over 99% of new applications are already filed electronically and over 80% of notifications are digital.
| Rule (EPC) | From 1 April 2027 | Applies to |
|---|---|---|
| Rule 2 | Documents filed electronically; postal filings must be refiled electronically within two months of an invitation, otherwise refusal of the application or documents deemed not received | Documents received on or after 1 April 2027 |
| Rule 114 | Third-party observations filed only electronically; others deemed not filed | Observations received on or after 1 April 2027 |
| Rule 125 | Notification electronic; postal notification only in special circumstances; delivery by hand removed | Documents dated 1 April 2027 or later |
| Rule 129 | Public notification where electronic notification fails for reasons within the addressee’s responsibility | Documents dated 1 April 2027 or later |
| Rule 134 | Periods extended if a permitted electronic means is unavailable at the EPO | Periods expiring on or after 1 April 2027 |
Rules 126 to 128, which govern notification by post and by hand, are deleted from the same date. Certified paper copies, physical objects and submissions by people who are not parties to the proceedings are exempt from the refiling obligation.
Why does EPO mandatory electronic filing matter for non-European applicants?
Under Article 133(2) EPC, applicants without residence or a place of business in an EPC state must act through a European professional representative in all proceedings except filing the application. Three situations follow:
- An applicant or local agent in Latin America or Africa who files a European application directly on paper to secure a date will then face a two-month refiling period, with refusal as the consequence of missing it.
- Electronic notification goes to whoever represents the applicant. If that representative cannot receive it, the risk under Rule 129 is a public notice the applicant never sees.
- The July 2026 news confirms that mandatory electronic filing also covers PCT procedures before the EPO, which acts as International Searching Authority for many applicants from the region.
Readiness checklist
- List every channel through which your organisation or local agents send documents to the EPO, including PCT filings and payments.
- Confirm that your European representative uses the EPO’s online filing tools and MyEPO Mailbox for all your files.
- Stop planning paper filings as a fallback for deadlines falling on or after 1 April 2027, or diarise the two-month refiling period for each one.
- Check that the applicant name, address and representative details in the European Patent Register are current, so notifications reach the right person.
- Review your docketing: notifications will arrive electronically, and periods run from the date the document bears, subject to Rule 125.
What this means for your business
For most companies the change is administrative, but for portfolios managed through several local agents it is an opportunity to consolidate: one representative, one electronic channel, one docket. If your European and PCT filings are currently split between firms, our patent team coordinating EPO and PCT filings can map the files and propose a single channel before April 2027.
Where applicants could get caught out
- Assuming paper still works. It secures a date, but the two-month refiling obligation follows.
- Losing track of who receives notifications. If no one can receive them electronically, a public notice can start a period without anyone noticing.
- Leaving the refiling to the last day. Two months pass quickly when the electronic version has to be checked against the paper original.
- Forgetting third-party observations. Paper observations will be deemed not filed.
Frequently asked questions
Can I still file a European patent application on paper after 1 April 2027?
Yes, postal filing remains possible, for example to obtain a filing date. But under amended Rule 2 EPC the documents must be refiled electronically within two months of an invitation from the EPO. If a European application is not refiled in time it is refused, and subsequently filed documents are deemed not to have been received.
How will the EPO notify decisions and communications?
Electronically, as the rule, under amended Rule 125 EPC. Postal notification is kept only for special circumstances, such as addressees who are not parties to the proceedings. If electronic notification cannot be made for reasons within the addressee’s responsibility, Rule 129 provides for notification by public notice.
Does the change affect PCT applications?
Yes. The EPO has said that electronic filing becomes mandatory for both European and PCT procedures from 1 April 2027. This matters to applicants who use the EPO as receiving Office, International Searching Authority or International Preliminary Examining Authority.
Can IP Global Guard manage our EPO filings electronically?
Yes. We coordinate European and PCT filings with European patent attorneys who file and receive notifications electronically, and we centralise the docket so that deadlines and communications reach you through a single point of contact, whether your company is in Europe, Latin America or Africa.
Get ready for April 2027 with one point of contact
A digital EPO rewards portfolios with a single, well-organised channel. IP Global Guard, the IP services line of META Channel Corporation Limited, coordinates patent filings across more than 25 jurisdictions in Europe, Latin America and Africa with one strategy and one billing relationship; see our coverage map.
Send us the list of your European and PCT files and who currently handles each one. We will check how they will be notified after 1 April 2027 and propose how to consolidate them. Get in touch with our patent team.
This article is general information, not legal advice, and reflects the rules as adopted on its publication date.
Sources
- EPO, OJ EPO 2026, A27: Decision of the Administrative Council of 19 March 2026 (CA/D 2/26)
- EPO, Patent granting process fully digital as of 1 April 2027 (23 July 2026)
- EPO, European Patent Convention, Article 133
- EPO, OJ EPO 2026, A43: Notice dated 8 September 2026 on mandatory electronic filing and notification (published 30 September 2026)
- EPO, First implementing measures for the fully digital patent granting process (1 October 2026)
