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TomTom International bv

TomTom

TomTom is the leading independent location technology specialist, shaping mobility with highly accurate maps, navigation software, real-time traffic information and services.

Lobbying Activity

Meeting with Wouter Beke (Member of the European Parliament)

8 Dec 2025 · EU defence

Meeting with Petras Auštrevičius (Member of the European Parliament)

6 Nov 2025 · Mobility

Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

18 Jul 2024

TomTom welcomes the opportunity to provide feedback on the Commissions draft implementing act specifying the technical and methodological requirements of cybersecurity risk management measures and specifying when an incident is considered significant under the NIS2 directive. Please see our feedback in the attachment.
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Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur) and Association des Constructeurs Européens d'Automobiles and

9 Mar 2023 · ITS Directive Revision

Response to Cyber Resilience Act

23 Jan 2023

TomTom wishes to provide feedback regarding the public consultation for the proposal for a regulation on horizontal cybersecurity requirements for products with digital elements (amending Regulation (EU) 2019/1020) published on the 15th of September 2022, the Cyber Resilience Act. As Europes leading location technology specialist, TomTom appreciates the Commissions endeavor to bolster cybersecurity rules to ensure more secure hardware and software products to be placed on the market. However, we would like to use this public consultation to emphasize the importance of ensuring a coherent cybersecurity framework that respects and references existing and broadly acknowledged industry standards. This will facilitate compliance with the CRA for hardware and software producers, guaranteeing that the intended policy goals are reached and enabling industry to place innovative products and services on the market in a cost-efficient way. Our position paper is attached, outlining more details.
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Response to Adapting liability rules to the digital age, the circular economy and global value chains - the new Product Liability Directive

9 Dec 2022

TomTom wishes to submit feedback on the Product Liability Directive together with fellow location technology provider HERE Technologies. Our position paper gives feedback on both the Product Liability Directive and the AI Liability Directive. Please refer to our position paper for full details.
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Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

28 Nov 2022

Considering the parallel cross-sectorial legislative proposal on liability (the revision of the product liability directive from 1985) and the potential overlap between these two pieces of legislation, TomTom would like to submit detailed comments on both files simultaneously during the PLD consultation (closing on 9th December 2022). However, as a high-level remark we believe there should be greater alignment between the Artificial Intelligence Act and Artificial Intelligence Liability Act. Notably, the AI Act grants an exemption for the automotive sector due to the prevalence of sectorial legislative frameworks that already exist and better suited to regulate the use of AI (EU type approval and annexed regulations under the UNECE 1958 Agreement). For the same reason, and given that liability regimes go hand in hand with product requirements, we believe that the AI Liability Directive must also foresee an exemption for the automotive sector so liability regimes related to the use of AI can also be addressed in existing sectorial legislative frameworks.
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Response to Type approval of motor vehicles regarding access to in-vehicle generated data

1 Aug 2022

As Europe’s leading independent location technology specialist, TomTom appreciates the opportunity to provide feedback to this call for evidence for an impact assessment on access to in-vehicle data. TomTom welcomes additional sector-specific legislation regulating access to in-vehicle data, as the Data Act is too general to sufficiently cover the complexity of a product such as a connected car. Transparency on available data and rules for fair and equal access to vehicle data are crucial elements of a complementing sector specific regulation. Please find attached a detailed response to the call for evidence for an impact assessment.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

13 May 2022

As Europe’s leading independent location technology specialist, TomTom appreciates the opportunity to provide feedback on the Commission’s proposal for the Data Act. Overall, TomTom supports many of the components of the Data Act. However, we would like to seek clarification on some issues and propose some changes to improve the implementation of the proposed regulatory framework. Please find attached a detailed response to the public consultation.
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Response to Revision of the Intelligent Transport Systems Directive

20 Mar 2022

HERE and TomTom wish to provide feedback to the proposal of the European Commission to amend Directive 2010/40/EU on the framework for the deployment of Intelligent Transport Systems in the field of road transport and for interfaces with other modes of transport. We acknowledge the Commission’s endeavor to increase the deployment and operational use of ITS services across the EU. We support efforts to tackle the shortcomings of the current regulatory framework for ITS technologies and the need to include emerging ITS solutions: such as C-ITS, CCAM and MaaS. The strategic objectives of increasing interoperability, better coordination among all ITS stakeholders and improved availability, accessibility, and quality standards for data, should indeed be the aim and interest of all stakeholders to enable a better functioning of the mobility system. However, we believe there are some issues that need further clarification and attention: 1. Scope of Commission’s Mandate Clarity on Commission’s mandate and involvement of industry stakeholders Especially the additions below refer to a broad and unclear Commission’s mandate: • Article 1 Subject matter and Scope in Par. 2 (a): “This Directive provides for the availability of data and deployment of ITS services within the priority areas referred to in Article 2 with a specific geographical coverage as specified in Annexes III and IV.” • Article 7 on Delegated Acts: “The Commission is empowered to adopt delegated acts in accordance with Article 12 to amend the list of data types in Annex III & IV, including the date of implementation and the geographical coverage for each data type & ITS Service” • Article 7 on Interim Measures: “In the event of an emergency situation having a severe direct impact…., the Commission may adopt immediately applicable implementing acts” - It should be clarified that delegated regulations (e.g., specifying data lists for the Priority Actions) must be in line with the requirements and specifications of existing delegated acts e.g SRTI, RTTI in order to avoid any legal unclarity and hurdles at implementation - It should be guaranteed that industry stakeholders are duly consulted and involved in the drafting process of Delegated Acts (we propose the approach followed for the ISA Delegated Regulation with the active involvement of the Motor Vehicle Working Group) - The terms “severe direct impact” and “emergency situations” should be clearly defined 2. Availability & Accessibility of “data” Sharing of data by national authorities We welcome a broader sharing of data generated by the Member States via the National Access Points. However, to ensure fair competition and added value for end users: - Data points/interfaces must be authoritative, technically robust and machine readable - Data must be of good quality otherwise it is useless (different quality levels required depending on the use cases and its corresponding value) What constitutes “data” We want to re-iterate that the definition of “data” in this context should be unequivocal: - “Raw or source data” and “service-level data” must be differentiated. Service-level data has IP & Copyright, raw data or source data does not - Service providers incur costs while collecting, producing, and creating “service-level data”. As such, data is part of a commercial business model and therefore engender costs regardless of whether it contributes towards public policy goals (making traffic safer/more efficient/greener etc.) 3. Risk of over-regulation & legal unclarity We welcome the revision of new priority areas to reflect emerging technologies and the revised specifications in Annex I. However, any vehicle software related regulation, i.e., related to Human Machine Interface should not be dealt with within the framework of the ITS Directive, but should rather fall under the DG GROW umbrella, responsible for vehicle regulations.
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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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Response to Review of the general product safety directive

4 Oct 2021

TomTom welcomes the fact that Type-approval for motor vehicles and the General Safety Regulation (GSR) are both listed as “Union harmonization legislation” covering the automotive sector​. Obligations on economic operators and their placing on the market of products defined in the GPSD proposal only apply when obligations are not yet covered by Union harmonisation legislation.​ When products are subject to specific safety requirements imposed by Union legislation, this Regulation shall only apply to the aspects and risks or categories of risks not covered by those requirements. ​ This significantly reduces the risk of duplicating regulatory requirements in the automotive sector.
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Response to Technical requirements and test procedure for approval of intelligent speed assistance (ISA)

28 Apr 2021

HERE and TomTom would like herewith to submit joint comments to the public consultation on the draft Delegated Regulation for ISA. In line with the General Safety Regulation 2019/2144, we support the objective of improved road safety by limiting speeding with the use of ISA systems. In order to support the implementation of robust ISA systems, which can deliver substantial road safety benefits, we would like to bring to the attention of the European Commission the elements mentioned in the attachment.
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Meeting with Margrethe Vestager (Executive Vice-President)

18 May 2020 · To present TomTom’s vision for a competitive digital economy in Europe

Meeting with Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager)

7 Apr 2020 · To present TomTom’s vision for a competitive digital economy in Europe

Response to European Partnership for Safe and Automated Road Transport

27 Aug 2019

TomTom welcomes the prospect of a new European Partnership for safe and automated road transport via the Horizon Europe programme. It is essential that the development of the Partnership's work programme is conducted in a fair and transparent manner giving industry the possibility to shape research topics along with governmental bodies. The new EU CCAM Platform should be a key instrument to drive this activity.
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Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

7 Feb 2019

TomTom along with fellow ITS Service Providers BE-MOBILE, HERE and INRIX wish to jointly submit feedback on the Commission draft Delegated Regulation regarding the deployment and operational use of Cooperative Intelligent Transport Systems via the document attached. We greatly support the Commissions endeavor to improve road safety and traffic efficiency in the European Union by facilitating the deployment of C-ITS with this specification. Overall, we as leading ITS Service Providers support this draft Delegated Regulation, but we believe there are some important changes and follow-up actions required in 5 key thematic areas as identified in the attachment document which are essential for the operation of C-ITS services, the competitiveness of Service Providers and the clarity & usability of the document.
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