Session data belongs to the driver, not just the back office

Not the same obligation. AFIR requires ad hoc price transparency and easy payment at the point of charging — what a driver sees before and during a session. The Data Act is a separate, ongoing right to access and export the session data a charger generates after the fact, and to direct it to a third party such as a fleet platform or billing-reconciliation service. A compliant charge point operator needs both: transparent pricing at the plug, and a durable access API behind it.

It depends on who the Data Act treats as the user for that vehicle — typically whoever has the contractual relationship establishing use of the charging service, which in a fleet context is often the fleet operator, with the driver's personal data inside those sessions still protected under GDPR. Model both relationships explicitly: a fleet-level entitlement to operational session data, and driver-level protection for anything personally identifying within it.

The algorithm itself, generally yes, through the Act's structured trade-secret process — proposing proportionate confidentiality measures and documenting the decision. The session-level output of that algorithm, meaning the price actually charged for a specific session, is a different matter: it's a normal part of the session record a driver is entitled to see, not the pricing logic that produced it.

Roaming means a driver can charge at a station operated by one company through a contract with another (an e-mobility service provider), which creates two candidate data holders for the same session. Resolve this in the roaming agreement: decide up front which party owns the pre-contract disclosure and the access-request handling for sessions initiated through roaming, rather than leaving a driver's request to bounce between two operators.

Yes, where the charger or the vehicle generates it as product or related-service data. Bidirectional energy flow, timing and volume during a V2G session are operational data the driver or fleet operator can reasonably request, on the same terms as one-directional charging-session data — this is a growing area as V2G deployments increase, so build the catalog to accommodate it rather than assuming charging is always one-directional.

Where that's the readily available data relevant to the request, yes — a fleet operator reconciling a month of charging costs across dozens of vehicles has a legitimate access-on-request claim to that full period, not just the most recent session. Build export with date-range and multi-vehicle filtering in mind from the start rather than a single-session-at-a-time API that a fleet customer immediately outgrows.