Out-Law News 3 min. read

UK mobility-as-a-service code targets improved data sharing


Plans to give transport operators and local authorities greater guidance on how they can lawfully share data with digital platforms that aggregate information to aid journey planning have been outlined by the UK government.

Responses to the consultation may help to shape any future changes that may be required to enable MaaS offerings to flourish in the UK

MaaS is a catch-all term used to describe a range of different and emerging business models built around the concept of enabling consumers to plan, book and pay for trips across different modes of transport provided by different transport operators through one digital platform.

The Department for Transport (DfT) is seeking views on what content the new MaaS code should cover. Data sharing is one of the areas that it has proposed the code address.

“MaaS platform providers need to be able to access journey and payment data to increase the functionality of their applications by providing users with tailored information about their journey, such as service availability, timetable data, payment methods, reservation details and disruption data,” the DfT said. “Data sharing between transport operators and MaaS platform providers will allow MaaS to fully integrate with public transport, payment processers and local authorities.”

“At present there are a number of barriers to data sharing including incomplete and inconsistent data, such as the lack of available real-time data to help consumers plan their journeys more effectively. There may also be commercial and competition impacts for MaaS platform providers that need to be taken into consideration,” it said.

The DfT said that, as part of its plans to facilitate data sharing, it wants users of MaaS platforms to be presented with “carbon data for each route offered” to help consumers to choose “lower carbon journeys”.

The DfT is also planning to promote greater data standardisation in the MaaS code, highlighting “inconsistencies” over the way data is currently provided across different transport modes.

“Improving data standardisation and discoverability could increase the pace of new innovations such as MaaS by improving data quality and data collection,” the department said. “Data standardisation is also a valuable tool in understanding the shift towards more sustainable modes of transport. Passenger numbers and the uptake of new modes of transport can help us to understand if users are switching from private car use to more sustainable modes of travel such as public transport and active travel, from one sustainable mode to another, or creating entirely new journeys.”

The DfT has also outlined plans for the new code to address “multimodal ticketing”. It has invited views on how to break down existing barriers that mean users of MaaS platforms are often unable to pay seamlessly for journeys across different modes of transport supported by different transport operators.

It said: “MaaS can offer the ability for customers to purchase a ticket for their journey through the MaaS application, using either pay-as-you-go or subscription models. This can save the customer time, allow them to compare different options more easily and could be more convenient than having to make multiple transactions. Increasing convenience for customers can encourage greater use of public transport for end-to-end trips. For this to work, however, passengers need to be able to receive their tickets in a convenient, digital format, and MaaS providers need to be able to integrate with operator retailing systems.”

“While digital ticketing is increasingly available on some modes, for example with the roll out of barcode e-tickets on rail, different modes and operators can adopt different standards for both ticketing and retailing systems, meaning that MaaS providers would potentially need to integrate with a multitude of standards. In some cases, standard interfaces do not exist, or onerous accreditation standards apply, requiring significant development work for new players like MaaS providers. We would like to understand how the code of practice can help MaaS platform providers, local authorities and transport operators overcome the challenges to offering ticketing and integrating with multiple modes,” it said.

According to the DfT consultation, the code could also cover issues such as how to avoid the risk of algorithmic bias, provide for accessible and inclusive journeys, and help businesses navigate consumer protection law and competition issues.

The deadline for responding to the consultation is 3 May 2022.

Ben Gardner, who specialises in mobility services and autonomous vehicles regulation at Pinsent Masons, said: “MaaS is rapidly evolving and will have a profound impact on the future of transportation in the UK and beyond. However, as with many emerging technologies, they are moving quicker than regulatory frameworks are able to. This creates legal grey areas and potential obstacles which could undermine investment, with organisations opting to test and develop their technologies in more favourable regulatory environments.”

“The code is designed to provide clarity and guidance for those operating in the MaaS ecosystem.  It will help to navigate data protection, competition and consumer laws but, as with other codes of practice, it will not be legally binding. Therefore, responses to the consultation may help to shape any future changes that may be required to enable MaaS offerings to flourish in the UK,” he said.

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