ChargeUp Europe input into the revision of EU rules on the security of network and information systems
ChargeUp Europe welcomes the European Commission’s initiative to review the EU rules on the security of network and information systems.
The security of network and information systems represents one of the key foundational values of ChargeUp Europe and the revision of the NIS Directive comes at a critical time in Europe’s transformation into a smart and sustainable economy.
The uptake of EVs is developing at a very fast pace. EV drivers need to be guaranteed access to reliable and secure charging infrastructure and it is imperative that their user data is secured. Ensuring more consumer-friendly experience for EV drivers, to boost e-mobility uptake, must go hand in hand with ensuring higher privacy and security standards.
There are numerous steps in the EV charging process which involve communication between networked elements and thus the EV charging value chain should be clearly and coherently covered by the scope of the NIS Directive across Member States.
The priority must be on ensuring that EV drivers feel safe and secure wherever they travel in Europe.
In this respect, EV charging infrastructure should be considered as critical infrastructure and the relevant operators should fall under the category of “operator of essential services” as laid down in Article 5(2) and illustrated in Annex II of the Directive.
In our view, the European Commission’s Impact Assessment should look at:
1.How to ensure a coherent definition of critical infrastructure in Member States. In this sense the European Commission could make recommendations on a list of what is considered as critical infrastructure.
2.How to guarantee multiple certificate issuers and multiple standards, ensure an open market, and combat potential pitfalls of monopolistic behaviors. Market operators should be able to freely choose between different encryption certificates.
3.How to ensure compliance costs will not hurt consumers, both in terms of ease of use and in terms of implementation costs. In the specific case of EV charging infrastructure, drivers will need to be guaranteed a smooth experience with new systems, without waiting for updates or system waiting times when charging their vehicles, and without paying considerable extra costs.
4..The potential benefits of a system of regulatory oversight at EU level to deal with repercussions for value chain players who do not comply with the standards.
See our input here