Interoperability is Not Neutral: Why Battery Swapping Needs Design, Not Just Data Rules
Effective battery swapping policy depends less on identity mandates and more on infrastructure readiness, technical standards, and clear liability frameworks
A background note can be accessed here: Guidelines for Battery Pack Aadhaar
Rahul Raj: Co-Founder, Inverted
SDG 7: Affordable and Clean Energy | SDG 9: Industry, Innovation and Infrastructure
Ministry of Power | Ministry of Heavy Industries
The guidelines mandate Aadhaar-linked authentication and remote locking of battery packs to curb theft and misuse. What design trade-offs arise from this approach, and how might mandatory authentication affect small or informal swap operators with limited digital infrastructure?
Aadhaar-linked authentication introduces an identity layer to battery swapping, but it should not be confused with effective theft prevention. In practice, authentication does little once a battery pack is physically stolen: a determined actor can dismantle the enclosure and extract valuable materials irrespective of identity controls. Consequently, most operators rely on GPS-based immobilisation that disables a pack when misuse or theft is detected.
However, immobilisation depends heavily on reliable network connectivity. In many operating geographies, intermittent cellular coverage makes real-time locking unreliable, undermining the intended security benefits. Mandating Aadhaar-based authentication without addressing these infrastructure constraints risks creating a false sense of security.
From a system perspective, mandatory authentication also increases transaction friction and complexity at the Battery Management System (BMS) and pack level. This raises costs and operational burdens for small or informal swap operators who lack robust digital infrastructure or continuous connectivity.
A more resilient design would combine physical tamper detection, offline event logging, delayed or conditional immobilisation, and periodic authentication synchronisation. Policy should explicitly recognise authentication as an enabling control rather than a standalone safeguard, and align security mandates with infrastructure readiness to avoid excluding smaller operators from the swapping ecosystem.
The framework envisages a shared Battery Swap Trust Architecture to enable cross-brand interoperability. What technical and governance safeguards are necessary to prevent vendor lock-in and ensure a genuinely interoperable swapping market?
A genuinely interoperable battery swapping market requires safeguards beyond a shared data architecture. Interoperability must begin with minimum design and component standards. Battery suppliers should be required to use certified cells, BMS, contactors, connectors, and protection devices validated by approved agencies. Without internal standardisation, packs may look compatible externally while posing safety or reliability risks.
To prevent interoperability from becoming a cost-cutting race, policy should set clear minimum compliance requirements–potentially linked to certified bill-of-materials (BOM) norms – so competition does not erode safety. Standardisation should include a government-defined reference design envelope covering outer dimensions, mounting interfaces, connector types, and safety clearances, while still allowing innovation inside the pack.
On the software side, communication protocols should be standardised and restricted to read-only access for shared parameters such as state of health and safety events. This enables cross-brand operation without forcing disclosure of proprietary algorithms.
Finally, governance must be neutral. Certification, protocol evolution, and dispute resolution should be managed by independent, multi-stakeholder institutions. Without these technical and institutional safeguards, interoperability risks remaining nominal rather than functional.
Battery swapping unbundles battery ownership from vehicle ownership and links usage to personal identity. How should policy allocate liability to protect consumers while sustaining incentives for private investment and competition?
Battery swapping fundamentally reshapes liability by separating battery ownership from vehicle ownership and linking usage to personal identity. It also introduces significant cybersecurity and systemic risk. If immobilisation or remote-control systems are compromised, a malicious actor could disable large numbers of vehicles at once, triggering accidents, congestion, or network-wide failures. These systems must therefore be treated as critical mobility infrastructure, with strong access controls, audit trails, and fail-safe mechanisms.
Consumer protection should rest on data-driven accountability rather than discretionary operator decisions. State-of-health models must be calibrated against experimental data and real-world usage patterns, enabling objective identification of misuse or abnormal degradation. Commercial consequences – such as penalties or differentiated pricing – should follow measurable deviations from expected behaviour.
Pricing design is equally important. Users should be charged based on actual energy delivered (kWh extracted), not flat swap fees. This ensures fairness as batteries age and aligns payment with value received.
At the same time, financiers and private investors need access to standardised, anonymised health and usage metrics. Privacy-preserving, dynamic data improves risk assessment, supports capital deployment, and sustains competition without weakening consumer protections.
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