AdC electric mobility recommendations

Following a public consultation held in the first quarter of 2024—which saw record participation—the Portuguese Competition Authority (Autoridade da Concorrência, or “AdC”) presented 9 recommendations aimed at promoting an efficient and competitive coverage of electric vehicle charging infrastructure. (See press release dated October 14, 2024, which can be consulted here.)

These recommendations come in response to the obstacles identified in the AdC’s “Competition and electric mobility in Portugal” study and the public consultation, and include the following:

• Barriers for new operators setting up and operating motorway charging points
• Complications for electric vehicle users in paying, comparing prices, and predicting final charging costs
• Complex electric mobility organizational structure, involving charging point operators (Operador de Pontos de Carregamento, or “OPCs”), eMobility service providers (Comercializadores de Eletricidade para a Mobilidade Elétrica, or “CEMEs”), and eMobility network management entities (Entidade Gestora da Rede de Mobilidade Elétrica, or “EGMEs”)
• Entry barriers for new players in the electricity sector
• Geographical disparities in network coverage, particularly in interior areas

AdC’s recommendations

For the government

1. Simplify payment methods at public charging points.
2. Simplify the organizational model by integrating the roles of OPCs and CEMEs.
3. Assess the costs and benefits of selecting EGMEs through a competitive, open, transparent, and non-discriminatory process.
4. Make it compulsory for EGMEs to be independent from CEMEs.
5. Revoke the requirement for CEMEs to be OPCs.
6. Revoke the option to extend, without a public tender, (sub)concession contracts of service areas or fuel stations to install and operate charging points.
7. Promote competitive, open, transparent, and non-discriminatory processes for granting rights to install and operate motorway charging points.
8. Allow CEMEs or OPCs—depending on the organizational model for electric mobility—to contract electricity from any economic agent selling it.

For municipalities

1. Promote the regional development of the electric mobility network in a timely manner to reduce regional disparities.

At a time when legislative changes to the electric mobility legal regime and the MOBI.E model are being prepared to align them with the Alternative Fuels Infrastructure Regulation, these AdC recommendations are particularly important and, if implemented, could result in a structural change to Portugal’s electric mobility legal regime.