Urban Mobility Data Lock-In  

1. Meaning of Urban Mobility Data Lock-In

Urban mobility data lock-in describes a situation in which a transport platform, mobility-as-a-service (MaaS) provider, mapping service, ticketing system, connected-car ecosystem, or transport operator gains control over important mobility data and makes it difficult for users, transport operators, or competing platforms to move that data or use it with rival services.

Relevant data can include:

• real-time vehicle locations and arrival information;
• routes, timetables and service availability;
• ticketing and payment information;
• journey and trip histories;
• traffic and congestion information;
• shared-bike, scooter, taxi or ride-service availability;
• charging-station information;
• user preferences and mobility profiles;
• demand and passenger-flow information; and
• APIs and technical information required for interoperability.

The competition concern is not simply that one company possesses a large amount of data. The central question is whether control over the data, together with contractual or technical restrictions, raises switching costs or makes effective competition substantially more difficult.

EU guidance on MaaS has specifically recognised that vertically integrated mobility ecosystems can produce high entry barriers, customer vendor lock-in and potentially dominant positions, while standardised APIs can lower entry barriers.

2. How Data Lock-In Develops

Suppose a city has a popular mobility application combining buses, metro services, taxis, bicycles, parking and journey planning. As more people use the platform, it accumulates increasingly valuable information about routes, demand patterns and passenger behaviour.

A reinforcing cycle may arise:

More users → more mobility data → better service → more transport partners → greater platform attractiveness → still more users and data.

A new competitor may consequently face a problem. It cannot provide a comparable service without sufficient mobility data, but it cannot obtain enough users to generate that data unless its service is already competitive.

This is particularly important where network effects and data advantages reinforce each other. EU competition guidance recognises network effects and switching costs as factors capable of making market entry or expansion more difficult.

3. Main Forms of Urban Mobility Data Lock-In

A. Data Portability Restrictions

A mobility platform might prevent customers from transferring journey histories, stored preferences, subscriptions or other usable information to another provider.

Users technically remain free to leave, but abandoning accumulated information makes switching expensive or inconvenient.

B. Closed APIs

A dominant mobility ecosystem may provide only limited API access to competing journey planners or MaaS platforms.

For example, competitors may receive scheduled information but not real-time information, while the platform's own service receives complete data.

C. Interoperability Restrictions

One provider may design ticketing, authentication, payment or vehicle-management systems so that third-party services cannot connect effectively.

Interoperability has become particularly important in EU digital regulation. The Commission describes interoperability requirements as a means of allowing third parties to compete effectively rather than leaving important technical functionality exclusively available to the ecosystem operator.

D. Exclusive Data Agreements

Transport operators might agree to supply important real-time data exclusively to one mobility platform.

If enough significant operators enter such arrangements, competing platforms may struggle to construct comprehensive mobility services.

E. Technical Data Formats

Lock-in does not always require an express prohibition.

A provider might use proprietary formats, interfaces or authentication protocols that make migration technically difficult or costly.

F. Historical Data Advantages

Years of information about passenger demand, congestion, journey preferences and transport patterns can potentially create an advantage that a new entrant cannot reproduce immediately.

However, possession of historical data by itself does not establish an antitrust infringement.

4. Competition-Law Analysis

Urban mobility data lock-in can potentially be examined under several competition-law theories.

Abuse of Dominance

Under Article 102 TFEU, the starting questions would normally include:

1. What is the relevant market?
2. Is the undertaking dominant?
3. What data or interoperability functionality does it control?
4. How important is that input to competitors?
5. Does the challenged conduct make competition more difficult?
6. Is there an objective justification?
7. Is the restriction proportionate?

The Commission's current Article 102 guidance expressly recognises that an input involved in access restrictions can include data, networks, infrastructure, intellectual property and interoperability information.

Exclusive Dealing

Exclusive arrangements between mobility platforms and transport providers could create foreclosure concerns where they cover an important share of transport services or strategically important data.

Tying and Bundling

A company could connect access to mobility information with another product—for example, requiring transport providers to adopt its complete technology stack before obtaining access to an important platform.

Merger Control

A transaction involving a mobility platform and a major data provider can also raise questions about whether the combined undertaking could restrict rivals' access to strategically important information or interoperability.

5. Relevant Case Laws

There is not yet a large body of judgments specifically labelled “urban mobility data lock-in.” The legal principles therefore come primarily from cases concerning interoperability, platforms, switching costs, essential inputs and digital ecosystems.

1. Microsoft Corp. v Commission — Case T-201/04

Court: General Court
Judgment: 17 September 2007

This is one of the most important interoperability cases.

Microsoft held a very strong position in PC operating systems. The Commission concluded that Microsoft's refusal to provide certain interoperability information prevented competing work-group server operating systems from interoperating sufficiently with Windows.

The General Court largely upheld the Commission's findings.

Importance for urban mobility

Imagine a dominant MaaS platform controlling the protocols necessary for:

• ticket validation;
• real-time scheduling;
• payment integration;
• transport-account authentication; or
• communication between transport applications.

If competitors cannot realistically interoperate without information controlled by the dominant platform, Microsoft provides an important analytical precedent.

The case is also significant because EU competition analysis recognises that creating accessible interoperability information can sometimes require the dominant undertaking to prepare information that was not previously supplied in that form.

2. Google Android — Cases T-604/18 and C-738/22 P

Google's Android practices involved restrictions connected with mobile operating systems, search services, browsers and device manufacturers.

The General Court largely upheld the Commission's findings in 2022. The litigation subsequently reached the Court of Justice; its July 2026 judgment provides further guidance concerning interconnected conduct, network effects and restrictions affecting user choice.

Relevance to mobility data

The case demonstrates how competition authorities can examine an ecosystem rather than looking at each contractual restriction in isolation.

An urban mobility ecosystem might similarly combine:

mapping + navigation + ticketing + payment + transport data + connected vehicles + user accounts.

A combination of defaults, technical restrictions and data advantages could potentially reinforce lock-in even when each element viewed separately appears less significant.

3. Google Shopping — Cases T-612/17 and C-48/22 P

The Google Shopping litigation concerned Google's treatment of its own comparison-shopping service relative to competing comparison-shopping services.

The Court of Justice delivered its judgment in September 2024.

The case is important for understanding circumstances in which a dominant digital platform's treatment of its own service and competing services can constitute abusive conduct. Current Commission guidance also relies on Google Shopping when discussing barriers, network effects and exclusionary effects.

Urban mobility application

Suppose a dominant journey-planning platform operates its own:

• taxi service;
• bike-sharing service; or
• charging network.

If the platform uses its control over mobility information or ranking mechanisms to advantage its own downstream service, authorities could examine whether the arrangement improperly disadvantages competing mobility providers.

4. Slovak Telekom v Commission — Case C-165/19 P

The Slovak Telekom litigation concerned access to telecommunications infrastructure and practices affecting competitors seeking to use that infrastructure.

It is important because it helps distinguish situations involving an outright refusal to provide access from cases where access exists but the conditions themselves may be exclusionary.

Mobility relevance

The same distinction matters for mobility platforms.

A platform might argue:

“Competitors already have access to our API.”

That would not necessarily end the analysis.

Authorities could examine whether access is:

• timely;
• technically usable;
• sufficiently complete;
• non-discriminatory; and
• commercially realistic.

An API that technically exists but delivers substantially inferior information could potentially create competitive concerns depending on the surrounding circumstances.

5. Clearstream Banking AG v Commission — Case T-301/04

Clearstream concerned access to clearing and settlement services.

The General Court upheld findings concerning discriminatory treatment and delays affecting access.

The case demonstrates that competitive harm can arise not only from a permanent refusal but also from the conditions and timing of access.

Current Commission guidance cites Clearstream when explaining that providing an input may sometimes require modifications to computer systems, preparations and testing.

Mobility relevance

Suppose a transport platform gives its own mobility service immediate access to real-time data but requires independent MaaS providers to undergo prolonged technical procedures.

The relevant inquiry would therefore extend beyond:

“Was access eventually provided?”

It could include:

“Was access provided on conditions that allowed effective competition?”

6. Bronner — Case C-7/97

Oscar Bronner GmbH & Co KG v Mediaprint

Bronner is the classic EU judgment concerning compulsory access to infrastructure controlled by a dominant undertaking.

The Court established demanding conditions for treating a refusal to provide access to an existing facility as abusive, particularly where the claimant argues that access is indispensable.

Mobility relevance

Suppose one company controls a unique mobility-data infrastructure.

A competitor cannot simply argue:

“Their dataset would make our service better.”

Where the strict refusal-to-supply doctrine applies, questions can include whether the input is genuinely indispensable and whether realistic alternatives exist.

This prevents competition law from automatically converting every valuable private dataset into a resource that competitors must receive.

7. IMS Health — Case C-418/01

IMS Health concerned access to a copyrighted structure used for pharmaceutical sales information.

The Court examined exceptional circumstances in which refusal to license intellectual property by a dominant undertaking could amount to abuse.

Mobility relevance

Urban mobility information can involve proprietary databases, database rights, software architecture and intellectual property.

IMS Health therefore illustrates the need to balance:

protection of intellectual property

against

competition where access to a protected structure or input becomes exceptionally important.

The existence of intellectual-property rights does not automatically resolve the competition-law inquiry.

8. Servizio Elettrico Nazionale — Case C-377/20

The Court of Justice's 2022 judgment concerned the use of advantages associated with a former legally protected electricity-market position when competition was introduced.

The Court examined circumstances in which resources inherited from a protected position could be used in ways capable of excluding competitors.

Current Commission guidance cites the judgment when discussing exclusionary conduct and competitive advantages that cannot simply be attributed to competition on the merits.

Mobility relevance

This principle may matter particularly where historically regulated public-transport operations are opened to digital competition.

A former monopoly could possess:

• historical passenger databases;
• established customer accounts;
• transport-card information;
• ticketing infrastructure; and
• extensive demand information.

Competition authorities could examine how such legacy advantages are used when adjacent mobility markets become competitive.

6. Network Effects and the Lock-In Cycle

Mobility platforms can exhibit both direct and indirect network effects.

Consider:

Passengers → Mobility Platform → Transport Providers

More passengers make the platform attractive to operators.

More operators make it attractive to passengers.

Additional transactions create additional data.

Additional data may improve routing, demand forecasting and service recommendations.

This can produce:

Users → Data → Better Service → Operators → More Users

Network effects themselves are not unlawful. They become relevant when assessing whether particular conduct—such as exclusivity, interoperability restrictions or discriminatory access—can foreclose competitors. EU competition guidance expressly recognises network effects as potentially relevant to exclusionary analysis.

7. Switching Costs

Switching costs are central to data lock-in.

A passenger moving from Platform A to Platform B might lose:

• saved routes;
• travel history;
• loyalty benefits;
• integrated tickets;
• payment preferences;
• accessibility settings; and
• personalised recommendations.

A transport operator switching platforms might lose:

• analytics;
• customer relationships;
• demand information;
• technical integrations; and
• accumulated operational data.

Consequently, switching can be difficult even where contracts formally permit it.

The European Commission has previously identified high switching costs as an important obstacle to entrants in digital markets.

8. Data Portability as a Response to Lock-In

Data portability can reduce these switching costs.

An effective system may allow users to transfer relevant information from one ecosystem to another in a technically usable format.

The EU's DMA illustrates the broader regulatory approach. Article 6(9) imposes data-portability obligations on designated gatekeepers, while Article 6(7) addresses interoperability with operating-system functionality. The Commission describes portability as particularly important where users would otherwise face difficulty switching because substantial information is stored within an ecosystem.

These DMA obligations are not themselves an urban-mobility-specific antitrust rule, but they demonstrate how modern regulation addresses ecosystem lock-in.

9. Interoperability and Open APIs

Another important solution is interoperability.

For mobility markets this can include standardised interfaces for:

Transport operator → API → MaaS platforms → passengers

Possible interoperable information includes:

• routes;
• schedules;
• disruptions;
• prices;
• vehicle availability;
• ticketing functionality; and
• real-time positions.

European mobility policy material has specifically noted that technology standardisation and APIs can reduce entry barriers in MaaS ecosystems.

10. When Data Lock-In Is Not Anticompetitive

A major distinction must be maintained:

Lock-in does not automatically equal illegal conduct.

A mobility platform may legitimately develop proprietary technology, collect data and build an attractive ecosystem.

Restrictions might also have legitimate explanations involving:

• cybersecurity;
• passenger privacy;
• data protection;
• system reliability;
• safety;
• intellectual property; or
• protection of commercially sensitive information.

The competition question is therefore whether particular restrictions go beyond what is reasonably necessary and produce exclusionary effects in the relevant legal and economic context.

11. Practical Competition Test

A useful framework for analysing an Urban Mobility Data Lock-In problem is:

Market power → Important mobility data → Switching costs/network effects → Restricted portability or interoperability → Rival disadvantage → Foreclosure effects → Objective justification → Proportionality/remedy.

For example:

A dominant MaaS platform controls real-time bus, rail and shared-mobility information. It gives complete data to its own journey planner but gives independent journey planners delayed or incomplete information.

An authority would investigate whether the company is dominant, whether equivalent information can realistically be obtained elsewhere, whether the difference in access materially harms rivals, whether users become locked into the ecosystem, and whether technical, privacy or security reasons genuinely justify the restriction.

Conclusion

Urban Mobility Data Lock-In is primarily an ecosystem competition problem involving control of mobility information, interoperability, switching costs, network effects and data portability.

The strongest legal analogies come from Microsoft v Commission, Google Android, Google Shopping, Slovak Telekom, Clearstream, Bronner, IMS Health and Servizio Elettrico Nazionale. These cases do not establish a special rule requiring every urban-mobility dataset to be shared. Instead, they provide different legal frameworks for determining when control over data, infrastructure or interoperability can cross from legitimate competitive advantage into exclusionary conduct.

In urban mobility markets, the decisive issue is therefore usually not how much data a company possesses, but whether its market power combined with restrictions on access, portability, interoperability or switching materially prevents rivals from competing on the merits.