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Move EU

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<p>Multimodal Digital Mobility Services (MDMS)</p>

Multimodal Digital Mobility Services (MDMS)

Position Paper on Multimodal Digital Mobility Services (MDMS)

Key Messages

  1. Clarify the roles of actors in the mobility network and define their attributions

  2. Recognise the specificities of ride-hailing platforms in an urban mobility context

  3. Preserve the ability of actors to freely enter into integration or aggregation agreements

  4. Enable private mobility service providers to propose a holistic and diverse mobility offer, including public transport ticketing

  5. Clarify the contexts, uses, purposes, conditions of data sharing




The European Commission recognised ride-hailing as a “game-changer” in urban mobility in its recent new EU Urban Mobility Framework, as well as in the Guidance Notice for taxi and private hire vehicles (PHVs). In line with its vision to tap into the potential of digital technologies to make transport more sustainable, the European Commission is also currently working on a framework for Multimodal Digital Mobility Services (MDMS). Move EU welcomes the efforts of the European Commission in designing such a framework to help European citizens get closer to moving away from private car ownership. As a member of the Multimodal Passenger Mobility Forum (MPMF), Move EU would like to provide preliminary views on a series of aspects that have been raised during the recent workshops and working groups and bring in the view of the ride-hailing sector.



The role of the ride-hailing sector in the MaaS ecosystem


Mobility-as-a-Service (MaaS) in many cities in Europe is being developed using Internet-based technology to improve urban movement. Ride-hailing services offering mobility-on-demand have grown independently and bottom-up in recent years. The presence of ride-hailing in the urban ecosystems has become permanent, but it naturally evolved, not without hurdles, as an agile alternative to traditional taxi operations through the use of technology. Ride-hailing and similar on-demand services, such as e-bikes and e-scooters or shared cars (often integrated within ride-hailing platforms), are an integral part of urban space and are increasingly combined with public transport.


European city residents’ mobility needs are diverse and have evolved, also driven by the interest to save time, money and more recently, to be more mindful of their environmental footprint. A tool like MaaS allows citizens to combine different means of transport and mobility options, thus moving further away from private cars, plan, book and pay trips, both long and short distances, provided by both private and public operators. Ride-hailing mobile apps have progressively turned into such MaaS platforms where, next to ride-hailing, different public and active mobility options are available, which provides benefits to local communities and cities, such as accessibility, choice and a contribution to a better environmental footprint.



Characteristics of ride-hailing platforms in an urban mobility context


Urban mobility services are typically provided for shorter distances and time periods to fulfill immediate needs of citizens to move around cities and suburbs. Such services include urban public transport (e.g., light rail, metro, bus), ride-hailing and car-sharing, micromobility, bike services and walking. In this context, the characteristics of services like ride-hailing are different from those for long-distance travel, such as railway or aviation:

  • Operational: Ride-hailing companies do not operate with their own car fleets, nor do they employ the drivers. They match independent local taxi or PHV drivers with requests of customers. The drivers are often connected to several platforms. A distinguishing feature is also the absence (or small amount) of infrastructure taxi and PHV services need compared to air or rail transport.

  • Dispatch logic: Customers using ride-hailing services are matched with the closest possible driver to reduce the waiting time as much as possible and to increase efficiency. The same applies to other modes of transport: the closest available vehicles are indicated in the app to the consumer who can freely choose the e-scooter / shared car, bike or public transport option.

  • Planning: While long-distance travels are usually planned much longer in advance, short-distance trips in urban areas are frequently planned or booked spontaneously and are very limited in time.

  • Partnerships based on licensing agreements: Third parties that are integrated into a multimodal ride-hailing platform reciprocally agree on terms and conditions including price setting of their services (e.g. e-scooter or e-bike operators/car sharing etc.). Operators remain in control of the operation of their services. Some of the offered urban mobility services have regulated fares (e.g., taxi/PTO).

  • Liability: Liability conditions of third party services integrated on a ride-hailing platform are commonly agreed, set out in contractual agreements and visible to consumers. However, this topic plays a minor role in urban mobility as a missed ride (e.g. metro, bus, shared car, etc.) does not impact the price paid by users as it is frequently the case in long-distance travel. Furthermore, a user can rarely miss a taxi, an e-scooter or a shared car, as these services are booked according to their immediate availability (or can be pre-booked, but a majority of bookings are spontaneous).



What should MDMS set out from a ride-hailing perspective


Clear definitions and roles of mobility actors

The mobility ecosystem is incredibly diverse, with actors and business models having different specificities that come to interact to provide a service to consumers. Given the complexity of MaaS, it is crucial for the upcoming MDMS initiative to define roles and responsibilities of all active stakeholders, both public and private, in the field of urban mobility, in accordance with those specificities. Definitions should also be precise and clear, as they are the foundation on which obligations will be set out and assigned. This will help minimise legal uncertainty, reduce administrative burden to entrepreneurs and prevent a fragmented interpretation.


Level playing field

Move EU agrees that EU-level action is needed to address challenges resulting from market imbalances and regulatory fragmentation in the spirit of free and fair market access and competition principles. The various mobility options and transport modes are rather complementing each other to incentivise citizens to move away from private car ownership and are gravitating around public transport as the core of the transportation network.


Move EU therefore advocates for the need to ensure a level playing field for all MDMS players. In a business-to-business context, entering into a commercial agreement should remain voluntary and should define clear responsibilities and access rights, leading to reciprocal benefits that ultimately strengthen MDMS and MaaS platforms.


As mentioned above, ride-hailing platforms intermediate transport operators and do not own vehicles. For this reason, ride-hailing platforms cannot be required to integrate the taxi and PHV services they intermediate into other MaaS platforms. This is always the free choice of the taxi or PHV company owners or of the independent drivers. The same applies to the reverse case: ride-hailing and other MaaS platforms should not be required to integrate every possible service into their platforms. This should remain the free choice of the companies in question, given the significant amount of resources that are needed to pursue such an integration partnership.


Many new mobility services are very young companies that strive to offer top quality services, based on the direct interaction with their clients. We believe that the European Commission should preserve the ability of MDMS players to freely choose whether to engage or not in agreements with other parties and should not be obliged to integrate into multimodal platforms. Any potential integration or aggregation of services must guarantee the quality of service towards consumers, their privacy, security and safety for which substantial investments have been made.

Position Paper on Multimodal Digital Mobility Services (MDMS)


Integration of public transport operators & distribution channels

The MPMP working group has discussed how cooperation between MaaS platforms and public transport operators (PTOs) and public transport authorities (PTAs) can be improved.


Contrary to private MSPs in the urban space, public transport is designed to serve usually vast areas and a large number of people travelling together on predetermined and non-flexible routes on a strict schedule. Most PTOs are owned by public authorities (governments, regions or municipalities) or through legal entities that are created for that purpose. Some European cities have even developed their own MaaS platforms that are operated by PTOs. We welcome to see the MaaS ecosystem thriving as this brings multiple benefits to consumers and gets us closer to moving away from private car ownership through reliable alternatives. Move EU supports fair competition in the sector that would also give PTOs the chance to attract more consumers to their offer. We truly believe that MDMS provides an opportunity to connect private MSPs like ride-hailing with PTOs and develop the cooperation where it already exists to also propose public transport ticketing and serve consumers’ demand and interests.


We welcome working with both PTOs and PTAs to further achieve the complementarity between private mobility offers (e.g., ride-hailing, car sharing, micro-mobility) and public transport. However, the current discussion only focuses on the integration of PTOs into MaaS systems that leaves out the concrete problem: for consumers, it is particularly the ticketing aspect that is the most important one for seamless mobility. Hence, to use a public transport service, a consumer needs a valid ticket and no seat reservation as it is the common case for railway or air transport services. For the time being, most PTOs do not allow the selling of their tickets on other mobility platforms. Another aspect is that not all PTOs have fully digitised their complete offer yet, including monthly tickets. We believe PTOs and PTAs should be therefore encouraged and supported to digitise their systems and purchase mechanisms to enable ticketing to private mobility service providers (MSPs) and give convenience and choice to consumers and ensure a seamless user experience. As already mentioned above, PTOs and MaaS platforms jointly agree the terms and conditions of their offered service in reciprocal licensing agreements. The same logic would accordingly apply to public transport tickets.


Agreement on standardization and clarity on costs

During MPMF discussions, the term ‘interface’ has been used in different ways giving rise to different interpretations. While ‘interface’ can refer to an Application Programming Interface (API) standard, it can also describe the “display”.


A joint European standard for booking and ticketing is essential to achieve more cooperation between private and public mobility operators across the EU and offer seamless mobility solutions to consumers. To define an EU-wide standard, all existing successful market solutions should be taken into account to not reinvent the wheel.


By contrast, standardization of the display of different MaaS platforms would cause a violation of the principles of competition and the freedom to conduct business. It would also contribute to losing consumers' confidence in the brands they know and trust. Move EU sincerely hopes this is not the intended purpose of the EU Commission.


Clarity on data sharing

Discussions within MPMF have revealed different views and approaches towards data sharing in the context of mobility and MDMS. Move EU acknowledges the importance of tackling the question of data and welcomes further clarity in this regard from the European Commission. In light of the Data Act setting out conditions to enable Business-to-Government (B2G) data sharing which are currently under negotiation as well as other initiatives such as the Data Governance Act (DGA), it is important for the upcoming MDMS regulation to clarify:

  • the scope of data sharing;
  • the actors that are required or expected to share data;
  • the purposes, contexts and acceptable use cases for which data needs to be shared

and subsequently used.


We believe that a precise data sharing architecture within MDMS should help all actors determine the appropriate and necessary volume of data. Additionally, data should be shared based on a concrete use case with a clear purpose and in line with applicable General Data Protection Regulation (GDPR) provisions and principles.


Ride-hailing platforms make significant investments in designing the operational procedures and building the infrastructure needed to collect, evaluate and analyze data correctly, all of which are not generated without a cost. Processed data become a company's intellectual property, which should be adequately protected to incentivise continuous investments and innovation. In this light, the MDMS should recognise this reality and build in, to the extent possible, incentives for the private sector to engage in data sharing.





Move EU welcomes the European Commission’s ambition to boost the multimodality of the EU’s mobility system, powered by digital solutions. Due to the diverse landscape of actors, services and applications, we advocate for taking the specificities of the different stakeholders into account, to deliver an impactful legislative proposal, without hampering innovation.


The ride-hailing sector is inherently different from long-distance travel, such as air and rail transport, in many aspects. In addition, Move EU members do not own vehicles and instead, local and independent taxi and PHV drivers and companies are offering their services via our platforms. It is of utmost importance to encourage voluntary integration for both transport operators and MDMS services, to create mutual benefits and preserve the free choice of integration for both. A forced integration may result in disproportionate cost and burden for all involved parties, which would deliver limited added-value to EU citizens and hamper innovation in the still young on-demand urban transport mobility field. A competition between several MaaS platforms is beneficial for consumers and transport operators alike.

In the urban mobility context, cooperation between PTOs and ride-hailing platforms can be a game-changer to provide a seamless, holistic and diverse mobility offer to consumers. This is a matter of the distribution of PTO ticketing through channels provided by MSPs like ride-hailing, rather than a deep integration with these players. The procedure of cooperation with the PTO would be the same as with any other third party: via reciprocally agreed terms & conditions.


Move EU is looking forward to continuing engaging with policy-makers and other stakeholders to contribute to making Multimodal Digital Mobility Services a success story in the EU.



About us


Move EU brings together the leading actors in the field of ride-hailing. Speaking with one voice, our members aim to foster sustainable deployment of on-demand mobility and new mobility services in the European Union. Move EU members connect passengers with licenced on-demand taxi and private hire vehicle (PHV) drivers, for the purpose of carrying passengers in return for payment.


Contact: [email protected]

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