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HERE Technologies

HERE Technologies is the European champion of map-making, global leading provider of location data and services.

Lobbying Activity

Meeting with Magda Kopczynska (Director-General Mobility and Transport) and Airbus and

24 Mar 2025 · Exchange of views with EU aviation and land transport industry on key policy developments in Singapore and ASEAN

Meeting with Josianne Cutajar (Member of the European Parliament) and Bureau Européen des Unions de Consommateurs and

4 Apr 2024 · Connecting Europe Days 2024 - Data driven mobility and transport policy and the role of Artificial Intelligence (AI)

Response to Revision of the specifications for EU-wide real-time traffic information services (Delegated Regulation 2015/962)

9 Nov 2021

ITS Service Providers BE-MOBILE, HERE Technologies, INRIX and TomTom wish to jointly submit their feedback regarding the Revision of Delegated Regulation No. 2015/962 EU-wide Real-Time Traffic Information Services (RTTI). The aforementioned ITS Service Providers are all active in the RTTI domain and we are gravely concerned by the draft provisions and requirements laid out in the draft Delegated Regulation proposal. We strongly believe that they would have direct negative consequences on our product offering and ability to compete in the RTTI market. Please find attached our detailed position paper and our proposals for amendments.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

22 Apr 2021 · Presentation of the company, Data Governance Act

Response to Legislative framework for the governance of common European data spaces

8 Feb 2021

HERE Technologies appreciates the opportunity to provide feedback on the proposed Data Governance Act. Enhancing data availability, access and re-use are prerequisites to develop a fully-fledged EU Data Economy and pave the way for EU Digital Sovereignty, that both Member States and the European Commission are aiming for. As one of the few existing European B2B platforms, HERE strongly believes that any regulatory endeavor should aim at reaching these two aforementioned objectives, which the Data Governance Act, in its current form, utterly fails to address. An unclear scope and a lack of alignment with existing and successful B2B data sharing models will inevitably undermine the EU’s ambition to remain competitive in the digital economy. Regarding the introduction of new requirements for data sharing intermediaries, as specified in Chapter III, it is still very unclear which B2B activities would fall under the scope. If existing B2B marketplaces were included in the scope, they would be made subject to overly stringent and unproportionate obligations. In our view, the mandatory provisions under Article 11, and notably a legal and operational separation of activities, will inevitably lead to unnecessary and burdensome silos which might prevent EU B2B platforms operating their own products. Such a consequence would be extremely damaging and would turn out to be counterproductive for businesses operating in the EU. Beyond jeopardizing existing significant investments, this would remove any incentive for the private sector to innovate and develop new B2B platforms in a context of scarcity and at a time when the EU is aiming for Tech sovereignty, focusing on industrial data. We need to understand that in order to unleash the full potential of data in today’s digital world and to reach a critical mass, B2B platforms need more integration, certainly not less. In that regard, the current proposal falls short in capturing the reality of the platform business. In our view, the EU should support the diversity of emerging trustful business models and secure B2B platforms are able to operate with a certain level of flexibility, in order to meet customer’s expectations in the best possible manner. In addition, such requirements would be contradictory to key EU Competition Law principles, which only apply drastic approaches where essential facilities are concerned, such as when the infrastructure in question is unique and cannot be duplicated. If the European Commission considered that unbundling is not appropriate for the biggest and most powerful B2C platforms, we have a hard time understanding how this could be seen as legitimate and be applied as the default setting for smaller EU B2B players. Some of the requirements laid out in Article 11, and notably under § 5 and § 7 appear to be unrealistic in the context of fast-paced machine-to-machine communications, and in particular in the context of connected and/or autonomous vehicles. In a B2B context, huge volumes of IoT-generated data have to be processed and aggregated. Real-time monitoring of every single data flow is a practical impossibility. From our perspective, such a measure would immediately impact the quality and the continuity of many advanced services. Moreover, these principles would only apply if the platform operator is responsible for the whole end-to-end process, which is in reality, not the case. HERE welcomes the overall idea of enhancing interoperability; however, this should, by no means, be required as a one-size-fits-all solution. Interoperability only makes sense in a similar environment where the formats are aligned (e.g in the case of vehicle sensor data in the SENSORIS format). It would not necessarily make sense in a cross-sectorial platform approach. On the contrary, this could greatly decrease the value of the data, and not contribute anything than extra unjustified costs, thereby disincentivizing data sharing.
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Meeting with Margrethe Vestager (Executive Vice-President)

18 Mar 2020 · Key priorities for Europe on digital platforms

Meeting with Henrik Hololei (Director-General Mobility and Transport)

12 Feb 2020 · Urban mobility