Don't Pull the Plug on Battery Data: Possible Amendment of Article 20a(3) of the Renewable Energy Directive – in the context of the Post-2030 Renewable Energy Framework Consultation
In the context of the consultation on the renewable energy framework beyond 2030, ongoing debates on the Automotive Omnibus and the possible revision of the Renewable Energy Directive, we would like to stress the importance of maintaining EV battery data sharing obligations included in Article 20a(3) of the RED on access to battery-related data.
The post‑2030 framework should strengthen and implement the core principles of Article 20a(3), i.e. real‑time, non-discriminatory and free-of-charge access to essential EV battery data for owners/users and authorized third parties acting on their behalf, with appropriate safeguards (consent, data protection and cybersecurity). It should also reinforce the fact that maintaining a non-discriminatory access to data that supports fair competition is key, but isn't enforced in today's market where OEMS have full and opaque control of the battery data.
First, these provisions are essential for the development of diverse business models. Charge Point Operators (CPOs) and other market actors rely on real-time battery data (state of charge, state of health, capacity, power set points) to operate efficiently, offer smart charging services and participate in flexibility markets. Without reliable access to this data, many of these services would not be economically viable. Article 20a(3) targets a defined set of data points (SoC, SoH, battery capacity, power set point and, where appropriate, location), which are necessary to deliver safe and reliable smart charging and flexibility services.
Second, the current rules are important for consumer transparency. They ensure that users, or third parties acting on their behalf with consent, can access meaningful information about their batteries at no cost. This allows consumers to make informed choices and engage in new energy services. Weakening these provisions would risk creating information imbalances. This access should ensure users retain control while enabling trusted third‑party services.
Third, data access is a key enabler of system integration. The increasing share of renewable electricity requires better use of flexible assets such as electric vehicles and battery storage. In particular, access to accurate, real-time battery data is essential for the development of Vehicle-to-Everything (V2X) services, including vehicle-to-grid and vehicle-to-home applications. These services depend on precise information on battery status and availability to safely and efficiently feed electricity back to the grid or buildings. Standardized and accessible data therefore underpins both grid optimization and the scaling of V2X solutions.
Fourth, Article 20a(3) provides legal certainty. A clear and harmonized EU framework avoids fragmentation between Member States and supports investment decisions. This is particularly important for actors operating across borders. The Commission has already highlighted the importance of a uniform approach to implementation to avoid divergent national interpretations (Here).
Finally, maintaining non-discriminatory access to data supports fair competition. It prevents situations where access to essential information is restricted, which could otherwise limit innovation and reduce consumer choice.
We also recognize the importance of ensuring that battery data sharing obligations are appropriately reflected within type-approval legislation; however, this should not be interpreted as a justification for weakening or removing these corresponding obligations under the Renewable Energy Directive. We recognize the need for coherence with type‑approval rules, but coherence must mean “alignment without dilution”: whether these obligations sit in energy law, type‑approval or a complementary instrument, the post‑2030 framework should preserve the same substantive rights (real‑time, free‑of‑charge, non‑discriminatory access for owners/users and authorized third parties).
For these reasons, we encourage the Commission to maintain the core principles of Article 20a(3) (EV battery data sharing obligations) in any future revision of the Directive.