Discover the differences between open and closed charging networks and their advantages.

Being an eMobility leader in various projects across multiple startups, Piotr was responsible for OCPI and OCPP integration as well as EMP and CPO platforms development. With extensive expertise in the open standards field and eMobility tech solutions, he is leading teams of experienced developers and contributing with invaluable knowledge and experience.

Piotr Majcher

The world of electric vehicles is ever changing with the introduction of new models and advancements in technology. One thing that hasn't changed however, is how you charge your vehicle once it's out of juice. Charging infrastructure has been and is one of the biggest challenges of the entire industry. Range anxiety in many instances is the main reason as to why people fear purchasing an electric car or deploying a fleet.

Being a very complex undertaking, charging networks and their utilization possibilities are shaped by many different factors. One of them would be the type of networks.

There are two types of charging stations: open and closed. Many would find it difficult to grasp the hold of the differences between them and yet, there is a fairly simple analogy that perfectly describes what it is all about. Namely, in order to fully understand the contrast between them, we can think about Android and iOS systems.

Open charging networks allow for standard communications to be used, so it is easy and efficient. This means that charging station owners can connect to more than one open network without needing any upgrades or changes in hardware since they are all compatible with the same standards-based networking providers. Open networks make it easier for drivers who prefer using their own programs or pay directly at any time without having an account on one specific network. It's much like using a phone with an Android system - you do not have to search for specific chargers or apps as there is a wide standardization allowing users to use various different types as they are all unified.

With the closed network, e-mobility service providers do not have to comply with open standards and can instead set up their stations using proprietary technology. This means that they are able to limit which networks customers can connect to as well as where a car will be allowed to stop for a charge. Within this system it is a bit easier for e-mobility service providers to control their costs, which can be a difficult task with open networks. Easy-to-understand analogy of what closed charging networks really are would be to compare them to the Apple company. iPhone producers heavily focus on making sure their devices are only compatible with their other products. Which means that with a closed charging network all electric cars have to use a specific charging connector - regardless of its manufacturer or battery size, resulting in limited flexibility for customers.

Why are there two types of charging networks?

The e-mobility industry is a very competitive space with many different companies fighting for the customer's business. One of the ways to succeed in this process and create an advantage over other competitors is by providing services that are tailored to their specific needs.

One would think that since range anxiety is one of the biggest issues within the e-mobility industry, open charging networks would work best to help mass EV adoption. So why do some tend to choose the closed ones?

Again, the aforementioned analogy to Apple vs Android might come in handy here. Since e-mobility service providers are all competing for the same customer base, they offer closed networks in order to limit which network their customers can access. This gives them a competitive edge over others by not having as many competitors available and it also allows e-mobility service providers to control costs.

EV charging station owners have a variety of options for how to monetize their products and services. The most popular option is through property owners as they pay both upfront costs for the stations and potentially recurring charges such as maintenance, network access or other small fees each time someone plugs in at your location. Drivers might also be able to purchase subscriptions which grant them use of specific networks on their own terms. Utilities companies are also interested in purchasing driver data from EV charger providers so that usage can help inform decisions about infrastructure needs going forward while car manufacturers may utilize these same provider's technology with some modification.

An e-mobility service provider might prefer using the closed charging network to make sure that they are not competing with other networks. Furthermore, it is easier for e-mobility providers to control their costs as opposed to open networks where drivers can connect and charge without having an account on a specific e-mobility service provider's network.

Surely both types of charging network have their pros and cons and it's a much more complicated issue than just money. Let's look at some of them.

One of the best parts about open standards-based charging networks is that drivers get to choose from a number of different hardware and network providers.. This allows e-mobility service providers to be rewarded with more customers who want their specific type of charging network.

The other advantage is that those e-mobility service providers are not limited in the amount of drivers they can have subscribed on any one network. Meaning there's an increased flexibility as for how many cars are available at any one given e-mobility service provider's charging stations.

In the e-mobility industry, open standards are preferred by drivers as they don't need to register or pay on an e-mobility network for them in order to be able to use it. Furthermore, e-mobility service providers need to comply with open standards which means that they can't limit where cars will be allowed to stop.

Proprietary networks allow them an opportunity to capitalize off of charging stations and give customers access with subscriptions that grant priority usage rights or provide rewards for driving electric vehicles over others; these closed networks also help prevent any other companies from using their services which might take away some of their customers.

Some people think that closed networks might mean higher quality services because no one else will be able to steal their customer base or tamper with security measures since it is isolated from other systems.

Not quite. As bizarre as it may sound there is more to charging than just... charging. Namely, at the second end of the cable there are also the energy suppliers.

The electric car market has been growing rapidly in recent years with no sign of slowing down but as it grows we have a responsibility to make sure the charge points don't overburden our current electricity grid system. To ensure e-mobility doesn't overextend, there are several steps that may be taken before things get out of hand: managing demand by monitoring usage; providing remote authorization through standard protocols like Open Charge Point protocol – OCPP; ensuring all chargers work together. For example, OCPP 2.0 can restrict power delivery to ensure the charging points match the power generation capacity of the grid.

So in fact, open charging networks, as much as not so appealing to some operators, may be the only option to ensure sustainable energy distribution once electric vehicles take over the automotive market.

Open vs closed charging networks - summary

Coming back to our previously mentioned analogy, much like with the situation of iOS vs Android, both networks will certainly find their sympathizers. It mostly depends on what is the main focus behind setting up charging stations. Those who wish to reach an audience as broad as possible, should definitely consider an open standards based network. Those who want to focus on securing an “independent” brand position and be in a full charge of costs will choose a closed network.

It seems, however, as though within the e-mobility industry experts, open standards are the ultimate way to go. Apart from increased flexibility in terms of charging equipment, open protocols ensure of staying up-to-date with newest technologies and solutions, they are also responsible for a seamless communication within the channel driver - charging point - grid.

An open, interconnected electric vehicle charging infrastructure would allow for a more dynamic and robust grid. The network of EV chargers could sync up with the pricing signals from utility companies to integrate renewable energy sources into power grids across America. This information sharing will help drivers quickly find available stations when they need them most while also streamlining payments via apps on their smartphones.

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Ebook - The Growing concept of e-Mobility

Open Charge Point Protocol migration from 1.6 to 2.0.1

Keeping IT systems up-to-date, even with basic tasks like dependencies or newly coming company-wide best practices is challenging. Even if all components are maintained in-house, it’s time-consuming to keep all areas updated. This applies also to keeping up-to-date external protocols our system uses. Whether we are integrated with Stripe over HTTP API, or with thousands of charging stations over OCPP, it’s good to know what the latest API version introduces. All this in order to examine if there are new opportunities upfront our business that can be supported by the newest version of the protocol we use. Or maybe our market requires covering long-waited, flow enabling updates. Let’s dive deeper into the new features introduced in OCPP 2.0.1 to see if it’s worth spending time upgrading your CPO platform.

OCPP 2.0.1 introduced business-oriented features but also technical improvements like device management or security. Those aspects are likewise very important, but this article gathers the latest OCPP updates focusing on the business angle.

More sophisticated support for smart charging is OCA’s (Open Charge Alliance) answer for a growing interest in this area. Energy cost fluctuates during the day. Also, the amount of energy available on different levels (charging station, building/parking, grid) changes according to the current consumption, production, and network capabilities.

Having that fact in mind we can use it to plan the charging process, buy cheaper energy for the end-user, and not overload the network. We need to know when energy is cheaper or the network load is too high. It’s out of the scope of OCPP, but once we have such information, we should inform the charging station how to apply it to finally reduce the cost of charging and limit network load.

OCPP 1.6 already supports smart charging. What is new, OCPP 2.0.1 is being open for new types of input having an impact on the charging process. Let’s start from a quick overview of OCPP 1.6’s support for smart charging and then move to things that are new in version 2.0.1.

Whole smart charging is based on charging profiles. A single profile describes time intervals with power/current limits, for instance, a profile can define that between 0:00 and 10:00 we can charge using 5kW, and between 10:00 and 0:00 maximum energy is limited to 2kW.

Profiles can be stacked and merged in order to build complex profiles. There are three types of charging profiles:

ChargePointMaxProfile - profile of whole charge point

TxDefaultProfile - default profile for a transaction (can be for whole charge point or for specific connector)

TxProfile - profile for a single transaction, deleted once a transaction is finished.

The second essential concept is a type of smart charging. There are three types of smart charging setup supported in version 1.6:

From a technical perspective, everything is covered by three OCPP API operations:

As it was mentioned earlier, 2.0.1 is open to new sources of information driving smart charging. Since now we can consume information from:

electric vehicles connected to charge point (through the ISO 15118)

Imagine a situation where there are some external indicators saying the energy our charge points transfer to EVs has to be limited. We can handle that on the CPO side, consuming the information and preparing an adequate charging profile being sent to the charging station over OCPP. But the 2.0.1 version supports direct integration between charge points and EMS. An extreme example of such integration can be a hospital with a lot of critical health-related systems consuming energy and with parking having charge points. It’s obvious that charging cars is less important than keeping the core hospital’s infrastructure running. This is an example in case of a bigger load, the energy management system should limit energy flowing to the charging stations. It can be done directly between the EMS and charging stations outside the OCPP. But such an approach introduces a problem. The CPO platform can be lost because the charging station behaves not the way it was requested by the system. OCPP 2.0.1 solves this problem by introducing a notification mechanism that informs CSMS (Charging Station Management System) about some external limitations. There are many cases that can be solved by support for direct smart charging inputs from an energy management system:

integration with Building Energy Management System

integration with Home Energy Management System

From a technical perspective, a new charging profile type (ChargingStationExternal) has been introduced. External signals changing the charging profiles should be stored as a charging profile of this type. Once an external charging profile has been added, the charging station has to notify CSMS and it does it using the new message - NotifyChargingLimitRequest.

The issue of support for ISO 15118 will be covered in the next paragraph, now let’s focus on the parts of ISO 15118 related to smart charging. Smart charging is nothing more than gathering information about the state of the network (including prices, load, etc.), processing the data, and steering the charging process. Standard ISO 15118 introduces another one source of information that can be processed in order to plan charging processes effectively. The source of information is an EV. One of the most important pieces of information when planning a charging process is the amount of energy the car wants to consume. There are many options to provide such information to the CSMS:

user can enter requested energy using a mobile app (delivered by the eMSP) and through the backend-to-backend integration send it to the CPO’s CSMS,

the charging station may send this data directly to the CSMS using a custom API

We could even use a new measurand introduced in OCPP 1.6 called SoC (State of charge of charging the vehicle in percentage). All those approaches have significant drawbacks. They assume the user's manual action, using a custom API or doing some approximations (when translating percent of battery already charged to the energy to be consumed without knowing the capacity of the battery). None of those solutions is good enough to become a standard. But ISO 15118 together with OCPP 2.0.1 covers this part of smart charging. ISO 15118 as a standard describing communication between an electric vehicle and a charging station specifies what type of information can be exchanged between those two parties. EV sends:

energy request (target, minimum and maximum)

charging parameters (current, power, and voltage)

discharging parameters (current and power)

Once the data is sent to the EVSE, it can be translated to the OCPP message and sent to CSMS which can use this input to prepare the charging schedule and send it back to the charging station (taking into account other inputs like price info, network load from DSO, etc.).

OCPP 2.0.1 introduces the message NotifyEVChargingNeedsRequest to share ISO 15118 based information with CSMS. It has four parameters describing charging details sent by EV:

Once CSMS prepares a charging profile for the current transaction, it sends it using SetChargingProfileRequest OCPP message. EVSE is proxying the information to the EV and as a last step, EVSE can notify CSMS about the charging schedule calculated by the EV using the NotifyEVChargingScheduleRequest OCPP message.

What is also worth mentioning OCPP 2.0.1 introduced ISO 15118 based renegotiation of the charging schedule. Renegotiation can be triggered by both sides - EV and CSMS. It’s useful in order to quickly react to the latest changes in the grid, no matter if it’s to reduce costs or unstress the network.

Very often the eMobility world is compared to the petrol industry. One of the most frequently compared areas is the transfer of energy from the station to the car. It’s said that we still have to wait years to bring the same user experience for the eMobility users as gasoline-based car users have today because of the time needed to charge the car. There is one improvement that has never been available for classic cars, but some charging stations and electric cars already have it. It’s Plug & Charge. In short, it’s a technology that allows users to start charging sessions without manual authorization. A user just needs to plug in the cable and without scanning the RFID token or using a mobile application car starts to drain energy from the station. Once charging is done, users can be automatically billed, also without entering payment details anywhere. Everything thanks to the PKI based solution introduced in the ISO 15118 and also covered by the OCPP 2.0.1.

Plug & Charge is built on a trust that is guaranteed by the Public Key Infrastructure. The most interesting part of it is how it replaces the need for human intervention when doing the authorization. The EV has the contract certificate stored (X.509 certificate). The certificate associates the end-user with the public key. Because the certificate is issued by a trusted Certificate Authority, the charging station is able to check it, and if it’s valid, the charging station believes that the user presented in the certificate is not fake. User is identified by the ID called E-Mobility Account Identifier (eMAID) stored in the contract certificate. eMAID is also known to the eMSP for billing purposes. Thanks to that, eMSP knows which user has to be charged for the transaction started automatically just by plugging the cable.

Two main parts of OCPP cooperating with ISO 15118 in order to provide Plug & Charge are:

Whole ISO 15118 is built upon Public Key Infrastructure. That’s why the separate component managing certificates has been introduced in order to open OCPP for integration with EVSE supporting ISO 15118. There is a set of OCPP messages including:

that are designed to manage certificates related to ISO 15118.

The second part of OCPP allowing to implement Plug & Charge is Authorization flow. AuthorizeRequest message contains (among other fields) information about the token used for authorization. This is a message used to send RFID token or a Central token in a remote transaction. There are multiple types of tokens supported in OCPP version 2.0.1 (more about it in the next paragraph), but one of them is called eMAID. eMAID is sent together with the data allowing to verify contract certificate (certificate and iso15118CertificateHashData).

OCPP 1.6 and previous versions were designed to support RFID-based authorization. Version 2.0.1 introduced a set of new authorization mechanisms, among them:

Central - used in for example in remote transactions

KeyCode - for authorization using PIN-code

It opens new possibilities for the development of user-friendly interfaces that may make charging easier and more accessible for the end-users.

OCPP 2.0.1 introduces significant changes that bring new opportunities for the whole eMobility world. In order to develop an efficient smart charging system or introduce Plug & Charge, we have to involve many parties, to mention only well-known ones like CPOs, eMSPs, and OEMs. The connection between the charging station and the backend system (CSMS) is a piece of a puzzle - linked with an upgrade of OCPP to the latest version. The decision has to be made wisely because it has many consequences, however, the features OCPP 2.0.1 provides can give CPO business a notable boost.

OCPP 2.0.1 introduced business-oriented features but also technical improvements.

OCPP migration

Open standards can be a game changer for both eMSP's and CPO's. Here is why.

The initial stages of technologies lead to various types of solutions addressing the same problem. Each company develops a different approach. At the beginning of the XXth century, when commercial electricity had come to the mainstream, multiple energy producers offered power supply with miscellaneous frequencies and voltages. As time passed, governments began to impose certain standards on suppliers. This standard-setting led to the joint effort to create the first power grid.

From the first power plant to the moment when all energy providers linked to the same network, decades passed. This was only possible because they took a mutual direction.

 - literally and figuratively. With global warming, exhaustion of solid fuel resources, and lifestyle changes, companies face the challenge of how to provide accessible new charging forms of green power.

Now, as the e-mobility era is here, we are on the same page, like we were at the very beginning of the XXth century. We already have plenty of providers: eMobility Service Providers (eMSP) and Charge Point Operators (CPO) - two substantial sides of the e-Mobility world. One of the main challenges ahead of this market is to deliver the best user experience, at possible minimum resources use. As usual, user experience is a matter of well-designed apps, customer support, and simplicity itself. But there is an additional fact. End-users need to be able to charge cars at any charging station without being concerned about accessibility. The issue is - having the contract signed with the Charge Point Operators recharging point service. How to achieve this? Partners must take the same course, and this is where the standards start to play a major role. There are two possibilities: Open Charge Point Interfaces or Open Intercharge Protocols. What are the benefits?

The main goal of the Open Charge Point Interface (OCPI) is to allow electric vehicle drivers to charge their cars at any station. OCPI defines a set of modules that cover most cases the driver may need. There are two technical modules that are used to establish connectivity between two platforms using OCPI: Credentials module and Versions module. Other modules are strongly related to real-life use cases. These would be:

Locations - module responsible for sharing information about the Charge Points, like address, geolocation, real-time data about the current status, electrical parameters.

Sessions & Commands - module allows the end-user to start the charging session and be informed about the current status of the charging session.

OCPI is an open standard, and what may be very important for the adopters - it’s very flexible. For instance, CPOs (Charge Point Operators) may implement only the Locations module (apart from two technical mandatory modules) when only sharing Point Of Interest data. With no necessary exposing the eRoaming functionality. But the ultimate goal for many CPOs is to allow end-users to charge their car. In that case, many more modules need to be implemented (Sessions, Commands, CDRs). Some others are optional, even for the eRoaming (Tokens, Tariffs), and that depends on the agreement between certain allies. It’s in terms of how financial flow and security is modeled.

The biggest advantage of having OCPI implemented is that it’s almost a one-time investment. The initial effort is significant, as it might be challenging to transfer internal models and processes to the OCPI. But once it’s done for a partner, it opens the company for quick and cost-effective integration with a lot of other associates.

A bit different concept is proposed by the Berlin-based innovative company - Hubject. Hubject developed its own API (OICP) covering almost the same cases as OCPI. There is one extra. Hubject also acts as a hub. It connects CPOs and eMSPs. Once a company is connected to the Hubject platform, it becomes open for integration with any other comrade being already assigned. That’s a huge advantage because the integration is done once, with one platform, and of course it becomes profitable when it comes to an alliance with multiple partners.

Yet another advantage of the Open Intercharge Protocol is that it’s quite easy to implement. Like with most protocols, the main challenge is to synchronize our internal models with the standard one. What is comforting with OICP - there is not too much to implement. It depends on the level of integration we want to achieve, but it’s enough to implement about 5 HTTP calls to expose eRoaming through the Hubject platform.

Having in mind multiple historical examples, it may be difficult to be a part of a developed market without following widely adopted standards. Initially, it may need some additional effort. But when the standard is implemented, our platform becomes open for the whole market 

. Without it, we would need to spend weeks or months doing the integration with each partner separately.

OICP and OCPI protocols - open standards for CPOs and eMSPs

Legal frameworks behind the e-Mobility market discussed by the industry experts.

Experienced content writer with over 4 years of experience in the energy sector and many industry-related publications released.

Gabriela Stawiarska

On June 16th we were lucky enough to have led a webinar in which our guests discussed some of the legal aspects of charging network expansion and business approach towards state legislatures and incentives while entering e-Mobility markets.

Below, you will find a video recording as well as a full transcript of the discussion.

What is the European status of e-mobility, now reaching mid-2021?

Yeah, well, it is an interesting question because it is always hard to really get the latest figures. But I think in general, in the electric mobility part, for this kind of overview, you need to split it into two things. One is how well the electric vehicle car sales are doing. And of course, you can split that also between busses, trucks, passenger cars in general, and the other part is the charging infrastructure. And in general, you can say that currently in the electric vehicle sales, new sales are going very well, I think better than expected. That's also one of the challenges that we face from your side, because, on the charging infrastructure side, everyone is doing their best, but it is hard to catch up with the number of vehicles coming in. So also a lot of new models. That's very good. We didn't see or we don't see any more concrete effects of COVID. We saw that last year. We could also register that amount of charging stations because at a certain moment everyone stayed at work from home. So we should withdraw directly, which was actually quite large, I think 20, 30 percent of the energy usage, the same for the old-fashioned fuel vehicles. I mean, no one needed fuel anymore because everyone worked from home. So there was definitely an effect. But currently, we see in the most recent statistics which show the amount of energy use is getting a bit back to normal. So in general, the progress is good. You still see a lot of differences in different countries. And I think that's one of the European concerns that we have both on electric vehicle sales sites, but also on the charging infrastructure side.

Have you noticed any particular countries that noted a boost when it comes to the growth of the e-Mobility market within this year?

We see that. Most of the time, there are almost the most obvious countries. I mean, Norway, of course, is one of the leading countries, especially in electric vehicles. When it comes to the electric vehicles infrastructure, you see that the Netherlands is leading. But we definitely see that countries like Iceland, Sweden, Finland, Denmark, are really doing great. Also, Germany and France are doing very well. On the lower side, we see that the numbers are not great when we look at countries like Greece, Czech Republic. But also, to be honest, Poland is not yet really on the move. So there are definitely countries that could take advantage of their current situation and what happened before the COVID period. But the good thing is, I think that I see from the European Union, the European Commission, that now they will really focus on the countries that are lagging behind a bit. So from that point of view, it's definitely positive that the movement is going on.


When it comes to you, EU directives, what updates can be expected during the next few months or next year?

OK, so we should start with the Green New Deal, which was issued on May 27th. Recent year.. It is a long-term recovery strategy because everyone, especially in Europe, but also in the whole world, was harmed and touched by the crisis caused by the COVID outbreak. So, the Commission prepared and issued this green new deal. First of all, the biggest today’s goal for Europe is to become a climate-neutral continent by the end of 2050. European Commission and European Parliament are performing many activities to achieve this target. European Commission will announce new legislative proposals in the coming year. And many of them will, of course, target e-mobility with special concern. That includes the benefits for the EV users, Charge Point Operators, and more restrictions, which can and will lead to automotive concerns and developers.

It can also be seen in the current legislation in both European and member states legislation. When it comes to regulations, we must say that in the field of electromobility and related sectors, there are plenty of examples of new, recent, and upcoming legislation. The most important one, that's happening now, is so-called the Clean Energy Package, which includes a set of updated and ongoing regulations, especially a review of the European Union taxonomy system and the Performance of Buildings Directive, which especially touches developers, renewable energy directive and the market design directive and regulation on energy efficiency. Maybe I will provide you with some more detailed information about those directives and regulations so everyone will have a little bit more knowledge about what's going on and what changes in the near future will occur. First of all, the European Union taxonomies climate is changing and it's a classification system that consists and establishes a list of environmentally sustainable economic activities. It’s a very important system because it's enabled to scale up sustainable investments and help to implement this European green deal. And a new and recent classification consists of some provisions which open and enable operators to provide financing for the companies, to entities which really, really need this financing to make some sustainable investments.

Another very important directive, which is currently changing and shaping is the Energy Efficiency Directive. It's an old directive because; it dates back to 2009, when the main reason to appoint was to reduce CO2 emission from new vehicles. The last version was passed by the parliament in 2013, and these regulations required lowering CO2 emission from new cars in 2013 to be lower by 37,5%. For 2021 protection will also be high - 41%. So in the nearest, eight, nine years this reduction will take like one-third of the emission, which is now. In June 2021, the European Commission will present a proposal to revise these targets and raise them, but they will need the support of the European Parliament because the European Parliament, as you know, is now very much in favor of ambitious climate targets. In the current term because it was said that up to 2015, we will have no emissions system in the European Union. And it's very interesting how the member states today react to this directive, because some of the member states are very clear in the favor of the rapid decarbonization of road transport, especially in Norway, but not only. There was a filed, joint open letter to the European Commission, which demands ban of the registration of combustion vehicles up to 2030. And this letter was prepared by a group of nine member states: Austria, Belgium and Denmark and Greece, Netherlands, Malta, Ireland, Lithuania and Luxembourg. So we may assume that the states declare that. Nevertheless, even if the European Commission wants to ban this registration of combustion engines, they will probably do that and perform some measures and activities to ban this registration.

Even if in this group there is no Germany but the experience so far shows that Germany will also play a key role in the European Council because they are very cautious about raising the bar for vehicle facturers., We may see a direct course from a Volkswagen Group - a largest car manufacturer in Europe, and it may mean the Germany will finally stop acting as a brake and will support a more ambitious policy to reduce the emission.

There is also a Renewable Energy Directive. And today, it must be stated that a majority of European Union member countries have not incentivized the use of electricity as, for instance, bio fuels, even despite that, obviously, electricity is the cleanest alternative to oil and it's even cleaner than biofuels.

This directive was refreshed and offers a chance to move away from the biofuels and to cleaner fuels. This creation of this credit system would, and I believe will help in increasing the rise of renewable fuels, since this electricity requires a separate infrastructure to be introduced to the market and everyone needs financing to implement that. It is important that the deadline for transposition of this directive in the member countries expires in June 2021. So this is happening now.

There is also energy performance of the buildings directive, which obligates new buildings and the buildings undergoing major renovations to either install charging stations or assure the installation of ducting infrastructure in parking spaces. So it also helps the growth of electric mobility.

Last but not least - in December 2010, 20 European Union proposed the revision of the directive to set the highest standards in the world for the  acquisitions of raw materials from which batteries come and the recycling of batteries, especially car ones. And it will help us have the whole Europe to be self-sufficient too, because right now we have a little problem with getting and exporting, importing lithium, cobalt Netco, which are required for battery production. And by 2014,, battery production will be mainly obtained from the recycled European batteries. So it's a huge boost finally to end this topic, referring to the legislation which committed to European Union climate neutrality by 2050. The European Commission proposed to increase the 2030 greenhouse gas reduction target to 55%. These kind of activities are very crucial for the growth of electro mobility, and I believe that will help us to have a cleaner planet.

In my opinion, there are two important things like Pawel said. All you have to do is legislation in which you are definitely focused on stimulation and support of electric mobility, like similar legislation regarding buildings, parking. Those requirements will definitely show several issues and ensure that you have the right, i.e. to get a charging infrastructure, a parking garages, etc. for buildings that it should be. On the other side, we see influence, which will come from the revised Alternative Fuel Directive. That will come in 2023 and actually the whole market is busy with that. The good thing is from one point of view, that it will be more strict in a way that the first alternative fuel directive, they gave too much room for the different implementations. This will be more strict. The kinds of sites that I see is that if the changes are too big, it will also not support all the new infrastructure which is needed. I mean, currently we talk about approximately 150 000 new charging points that need to be installed every year to meet targets. So we talk about 3000 chargers per week at least to meet the targets. So I hope the whole market, especially with its alternative fuel directive, contains a lot of different aspects like Pawel said, this is this very wide subject legislation. But I hope that it will be more strict that we are also part of that fight for your own foundation, but also in all kinds of ways that it will indeed help the market. But it's definitely one of the things to keep an eye on, the developments which are going on there.

When it comes to network fees and network development, can we witness something that could be called the road to unification?

We have a lot of different networks across Europe and then there is indeed a challenge. One of them is indeed based on the fees because you have different ways you make use of roaming hooks, you can do with peer to peer. You need to connect an operator with service providers to ensure that the service providers get access to the networks and finally, to the EV drivers. There are all kinds of arrangements there, to be honest, I don't expect many regulations on the fees. And I do hope and do currently already see that because of the competition, the fees will not be raised extremely. But it is a complicated market. From that point of view, unification will be done. But I don't expect it directly on the fees because finally, that is also up to the market. As an EV driver, you have the choice to choose your own insurance provider, a service provider, you have the choice to choose the different operators. But of course, it's a big market with a lot of money involved where companies make choices. So I do see that the next networks connect to each other. But in the concrete fees that you need to pay, for example, to roaming or to a service provider or the service provider to an operator, I don't expect there will be much of a registration from the EU site.

It would be good and that's maybe an interesting view that if the consumer authorities would keep an eye on it. There are in all countries and also by the EU, there are authorities to look at to assure honest competition. And I think that's an important role. But in my opinion, that role is not yet taken or not yet managed. I think it would be good to have those types of organizations more proactive in this, because there are definitely threats. I mean, if we look at the current developments via the car industry, like I'm using the 15118 ISO protocol, which is a possibility that via your car, you can directly connect to networks. In itself, it's not a bad development. But if it would exclude certain service providers or other parts of the market, then you get an issue. And I know that from their point of view, I don't think that the fees need to be regulated, but I hope that the authorities will keep an eye on it and assure that an open, valid or equal competition landscape will be there. And that's actually what could help in this

From the point of view of operators and the Union, what regulations can soon arise?

Yeah, well, I think regarding the operator, some mean the biggest regulations that also Pawel mentioned earlier, tax regulations are definitely a hot topic which will influence them, which was actually also rare for a long time. We were not really involved in this. I think at this moment, countries unite there and talk more or less with one vote or work together on that. The alternative fuel directive, which we have, which will have impact. We work together with a lot of companies and the Sustainable Transport Forum, where the EU is thinking about the legislation, about short term data formats, those kinds of things. So there are things which will definitely have an impact on the operator and which might also influence the way that they work. I mean, if I currently see, for example, that you need to offer outlook charging. So that means the ability to charge without subscription cards, those kinds of activities or activities will have an influence. There is another movement where you see that companies, or rather countries, will demand certain displays or certain information that need to be shared with EV drivers. Well, that's quite often it's either shared directly or via the service providers.

So there are a lot of things which are coming to the operators which will influence their work. We all need to catch up with the legislation, but also with improved and updated protocols and connections. So, yeah, I expect a lot of developments there. And I'm not sure if everything will directly be an improvement, because also to be able to say for a long time we as markets did not have maybe the right the right focus. And then you see that the EU, for example, takes the lead and says, well, we need to share data via national exit points. It simply requires that all operators need to open their network and share all the public SMI public infrastructure information towards our national exit point. And so you see these kinds of movements going on and that will have impacts on the way operators work.

It's another wide problem and wide question. I think I will come out with one very important regulation, which I believe will soon arise. First of all, it must be stated that the regulations which regard EV charging infrastructure and mobility, must respond to the real problems which are faced currently by EV owners and CPO’s and eMSP’s and among other areas of law. I believe that especially crucial and urgent for the development of the European single market for EV charging infrastructure may be considered to the VAT directive, particularly when it comes to cross-border transactions to e-roaming. And the industry is currently confronted with very uncertainties regarding the correct interpretation of European Union, especially VAT directive and national VAT laws. Furthermore, the existing VAT regime has turned out to be a major obstacle to the development of this integrated European trudging infrastructure market, because currently there is a big issue that EV charging can be seen either as a supplier of the goods, especially electricity, or as a supplier of service in terms of VAT. This distinction is very important because the VAT directive and after that national VAT rules for six different rules for supplies of goods and supplies of services when it comes to the determination of the place where the transaction is taxable.

Of course, there are some guidelines which were issued by the European Commission in 2019 on the subject that were issued on the request of Italy and France. However, they are not transported to directive or a national law. Now, according to these guidelines, CPO should be regarded (when it comes to e-roaming) as a supplier of electricity in the meaning of this VAT directive. From the point of view of European Union Commission e-roaming (CPO) is making a supply of electricity to the eMSP, who in turn makes the supply of the same electricity to the EV driver. However, it's only the view of European Commission. It's not a hard law. Some member states don't comply with the statement. And we are having issues where it is. It is regarded as supply of services, performing services, and it's a big problem for the unification of the market. And I believe that VAT committee, which is making a new VAT directive, it should be and now is scheduled to reconvene the opinion of the commission and today will decide in this directive, either commission's guidelines are right and they will be transferred into the directive and then all the member states will and must comply with this directive. However, now there are no binding guidelines, no binding regulations, and we are having big trouble with this. This problem regarding that and its complexity led to a situation where most industry members are reluctant to offer charging services to other member states. It's a big issue and I believe it will be changed in the coming years.


When it comes to open network across Europe, what is an optimistic and realistic scenario of forming this one bit in European Union?

I'm actually quite optimistic. I mean, I want to be optimistic. But I think we are not there yet. Let me be clear about that. We are working very hard and that means the whole market: the whole ecosystem, the companies but also the governments. We are all working very hard to achieve and to support an open, better network with the right information to EV drivers, but also possibility for competition, possibility to earn money, connectivity. So that’s the combination actually that we talk about here. There are things that need to improve and that we need to solve but we are working on that. If I look at where we are now and the fact that in the past I needed eight or more different cards and tokens to charge my vehicle across Europe - now, I can do it with two.So it is definitely improving. Networks are more connected to each other. They talk to each other in different standardization bodies. Also regarding the legislation, they definitely work together more and more. By the way, and I also think that's an important actor, which was quite often forgotten, but now we work together with those organizations, which are the communities of EV drivers. Finally, that's the group we do it for. We see that we really work together there. So I'm positive that in the next year or so, together with the EU, I mean, we all talk to each other. I think that's a big achievement - we don't talk about each other, but with each other. And that's a different level. So, the only thing I hope for and it’s a bit of a concern is that not only the main countries, so not only Netherlands, France or Germany, but also the other countries. I mean, it would be great if countries like Poland, like Czech Republic, etc. could also catch up and join and participate. And I know that from the EU also with their self funding mechanisms, they focus now on those countries to support the network. So they really look at the gaps where infrastructure is not yet good enough or where more needs are to be added. That way we can really ensure that it will be a real covering network and not only from a few countries. But again, I mean, we have huge targets. We have huge challenges. The biggest challenge might be the ability to install enough charging infrastructure. I mean, don't underestimate it. If you need to install a few thousand chargers per week in countries, it's going to be a real challenge. But we’ll get there. The next step for us is looking at busses, trucks or vans that are definitely the next important things, which will also have a huge impact on the charging infrastructure.

I totally agree. I believe that we are at a great point. We are after the biggest outbreaks of pandemic. We did it. We managed to survive. We are growing. There are more and more EV users on the European streets. So I believe the worst part is behind us. I believe everything is in our hands. I also believe that the goals we have are very demanding. They demand appointing a set of regulations and targets of member states, companies, consumers in the right direction. But I believe the commission, especially European Parliament is doing a great job in adopting common standards. The standards ensure the interoperability and coordination and support for the member states and the deployment and development of electrical charging infrastructure and while this targeting infrastructure grows. Also, the number of EVs on the European streets will also grow. So I believe we did a very good job and we are on the right pathway to reach these goals. Moreover, in the near future, we may expect some new solutions and regulations which will open this electromobility market, in a world of tokens and cryptocurrencies. And I'm glad to announce that at this point Nexity, together with a partner from our Capital Group - Columbus Energy, we are introducing to the market a solution which enables the tokenization of electricity from renewable energy sources; photovoltaic. It enables its balancing and also its further resell, not only to the neighbors, but also to every interested entity, as well as the purchase of the services of companies from our capital group. So, ladies and gentlemen, I believe the future is now and we are on the right path for this.

Where to look for legal guidance when deciding to enter a new market?

 I can tell you about it in my own example, because we are expanding to other markets. And first of all, we are searching contacts with associations, which conduct and care for electromobility in other countries. We are reaching out to them, contacting them and talking with them. Very often such associations provide us with different bulletins, guidelines for starting, growing and expanding in the foreign market. So I think and I believe that's a good way to go.

Now, I agree that definitely industry bodies or organizations or branch organizations are a good starting point. I also have to admit that this is definitely one of the challenges because it is hard to find single places where you can find all the information, all regulations and legislation. Partially, it is EU regulation. Also, a lot of things like the tech issues are not even solved yet, but we got a lot of questions about it. But there are a lot of discussions going on and you can't wait to start until everything is solved and there is national legislation and regulations. And then you also have the non-directed or the non-legislation parts which are simply the agreements between parties. So what Pawel is saying is definitely good to start with organizations like EV Roaming Foundation or other organizations. Finally, if you go to a certain country and try to get in touch with those countries and do good research on it. Also legislation and these kinds of things change on a regular basis. I mean, especially if we look at all kinds of incentives, it is very hard to keep track of all that. So, you need to do it also on a national level and investigate the possibilities. Unfortunately, I can't say there is one website where you can find all the information. There are good websites. I mean, look at the European Alternative Fuel Observatory, which can definitely be a good starting point. Still you need to look on national level and also maybe on the EU level to find the lost situation.


When creating a pan-European MSP offer, do companies need to create legal structures into every country that they offer access to the charging station in order to manage VAT requirements?

Oh, it's a little bit of a hard question to answer from the top of my head, and I believe we could provide a proper answer after checking and reading some interpretations in this regard. But I believe that the proper answer is that it depends mainly on the place of the taxation. And then I believe you don't need to meet any additional entities in the foreign country to provide your services. However, it is difficult to answer because of this VAT problem, which I mentioned earlier. And in every country, it must be checked if the roaming and roaming services are considered, services or are they considered goods. And I believe in the near future we may check the legislation in the different countries and provide you with some information on our blog.

There was the advice from a group of countries which was also something as guidance adopted by the U.S. on regulations, so to look at it as selling energy as a good but recently, Italy sent a big report with the question to reconsider it and to consider selling electricity for charging stations as a service. That can depend a lot on how you deal with that. The same as Pawel was saying, where do you deliver the energy? That's also a discussion. I mean, an operator in Poland active in Germany, where does he deliver the energy? So that's another discussion. In general what I normally advise, is that at the moment you get considerable volume, reasonable volume. The question is then what's reasonable? Having your own or legal company in a certain country can never harm when the volume is still small. It's probably too much effort, but it is a delicate discussion as Pawel was saying. Your options are waiting until the EU agrees, but then you can't do business for the next two years.

Are any directives being made that you are aware of, that will regulate the exception right for roaming partners throughout the EU? Small EMSPs are getting less chances to roam with large operators, which slows the development down.

It's a bit of an open market and I know where the question comes from because I also hear those issues and I see it. But it is a bit of a challenge. Do you also want it to be EU regulated? It's a bit of what I mentioned. I think that we have the authorities in the different countries who should definitely keep a good eye on honest and open competition and the possibilities for that. But if a certain operator is asking a large high fee to an EMSP and it can indeed be that bit maybe blocking or may be making it more difficult to enter the market for that EMSP. But there can be good reasons. I mean, if volumes are low, then it is not really strange to ask for a higher fee but these are difficult discussions. Almost on a daily or weekly basis I get those questions: can you do something about it? It is hard to do, and I think, do you want to get the EU to say “well, now we put a certain cap on it”. I mean, what's reasonable? You always get those kinds of discussions. Maybe Pawel will know something about it from a legal perspective. But we do stimulate the companies to be reasonable to each other and I think maybe branch organizations can play a role that the companies that are members of those organizations assure a kind of equal playing field. So that if you are a member, then you need to comply or apply to do all those business. I know where the question comes from, but it is hard, it's the market…

Do most member states consider electricity as a good or as a service? Are there any visible trends?

The only thing I can say, if companies are interested there is from the EU committee open information available. And that's the only thing I can say and you will see that as Pawel was saying, they also don't agree yet, but that information is available and can be shared.

To summarize, there are those guidelines from the European Commission from 2018, according to which the supply of electricity supply is regarded as supply of goods. However, there are a few member states where it is considered a service. But I believe mostly it is considered to supply imports. But it's only a trend. Now we need to have VAT directive changes, which I believe will come out in the next few years.

Learn about the legal aspects of charging network expansion and business approach towards state legislatures and incentives while entering e-Mobility markets.

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