Directive (EU) 2019/520, the European Electronic Toll Service (EETS): verification of the interoperability of electronic road toll systems in the European Union

Directive 2019/520 replaces and repeals the previous Directive 2004/52/EC and the related Decision 2009/750/EC. The purpose of the Directive is to achieve the interoperability of all electronic road toll systems in the European Union in order to harmonise electronic payment systems and to enable a correct and effective exchange of information between EU countries to ensure the payment of tolls by all users.
The directive, therefore, provides for the establishment of the European Electronic Toll Service (EETS), which extends to all road networks and (infra)toll facilities in the Union and defines the technological solutions allowed for electronic toll payment operations. The technologies allowed by the Directive to fulfil its purposes are the following: 5.8 GHz microwave technology (DSRC - Dedicated Short Range Communications system) in the European and Italian systems, satellite localisation associated with mobile communication systems (GNSS - global navigation satellite system), ANPR - Automatic Number Plate Recognition based on the use of cameras and OCR - optical character recognition - software systems for the recognition of vehicle number plates.


EETS allows road users to easily pay the tolls due on any road or (infra)facility in the Union by concluding a single subscription contract with an EETS Provider (Service Provider) using a single on-board equipment or other systems provided by the new technologies introduced. Each EETS Provider is required to achieve full coverage of the EETS domains within a transition period of 24 months after registering as an operator.
The essential interoperability requirements adopted in the new Directive have been designed in such a way as not to hinder technological progress in the solutions implemented for these purposes. Following the new references of the European legislative framework, the so-called "delegated regulations" were introduced, i.e. explanatory parts adopted by the legislator to define the requirements in detail and allow them to be updated over time without altering the main structure of the Directive.


In Delegated Regulation (EU) 2020/203 of 28 November 2019, the Commission included the classification of vehicles, the obligations of users of the European electronic toll service, the requirements for interoperability constituents and the minimum eligibility criteria for notified bodies.
Delegated Regulation (EU) 2020/204 of 28 November 2019 relates to the specific obligations of the providers of the European electronic toll service, defines the minimum content of the declaration of the European electronic toll service sectors, the electronic interfaces and the requirements for interoperability constituents in order to assess their conformity to specifications and their suitability for use; this Regulation repeals Decision 2009/750/EC.


Support provided by IMQ in its capacity as a notified body for the EETS directive

Testing and certification of on-board and infrastructure devices developed with European or Italian DSRC technology - Verification of compliance with EETS specifications

  • Layer 1 (physical layer): tests and functional checks at IMQ laboratories
  • Layer 2 (data link layer): application of the test cases envisaged by the standard, support for the creation of the test suite
  • Layer 7 (application layer): project customisation on the basis of the specifications prepared by the manufacturer, application of the test cases envisaged by the standard, support for implementation of the test suite
  • Certification: issue of Statements of Conformity to Specification certifying product conformity to Layers 1, 2 and 7

Verification of system interoperability

  • Issuance of interoperability certificate against agreed verification protocols between service providers (service providers) and motorway concessionaires (toll chargers).

Conformity with the RED directive

  • Conformity testing at IMQ laboratories: electromagnetic compatibility (EMC), safety, RF exposure and effective use of the radio spectrum, as established by the requirements of Directive 2014/53/EU (RED).

Verifications of compliance with specific standards or test specifications

  • Reliability tests are carried out on components with specific environmental tests, mechanical tests, climatic tests, IP protection of enclosures, corrosion resistance, solarisation, up to ATEX type tests (see specific service).
  • Conformity tests are carried out to test specifications based on validation criteria provided by international standards applied to EFC (Electronic Fee Collection) devices, with track tests, the use of different types of vehicles and a DSRC communication portal dedicated to the technologies adopted by the Italian motorway system.
  • Specific test specifications are prepared for ITS (Intelligent Transport Systems) type solutions used in vehicle and infrastructure contexts.

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