The Fuel Card Is a Tax Document That Happens to Buy Diesel

A buyer who ranks price third is not buying fuel

Dataforce’s 2025 study of German fleets found that 78% of companies now use fuel cards for their company vehicles, a share that has crept up year after year. The growth is not coming from large fleets: among operators with 20 or more vehicles, penetration is already above 90%. It is coming from the smallest operators, fleets of up to 19 vehicles, buying their first card.

The same study asked those buyers what they weigh when they choose an issuer. Acceptance network came first. Transparent billing and usable online analytics came second. The price of the fuel itself ranked third.

That ordering is the whole business. A fleet manager who ranks price third is not buying fuel. He is buying a settlement process — an invoice that can be posted without a reconciliation exercise, a per-transaction record that survives an audit, and drivers who do not keep receipts in a glovebox.

The share is moving away from the companies that own the fuel

DKV is the clear leader in German fleet penetration, with Aral second and UTA third. EuroShell, which used to sit in the top three, has fallen to fourth. The trend underneath the ranking is the interesting part: brand-independent issuers are gaining share and the oil-major brands are losing it.

The reason is structural rather than commercial. A card issued by a fuel company can only be neutral about that company’s price. A card that accepts every brand can be indifferent — and indifference is exactly what a procurement department is buying when it has to defend a fuel line to a finance director.

What the card actually manufactures

Consider what a fleet has to produce to recover value-added tax on fuel bought in another member state. Under Directive 2008/9/EC the claim is an electronic refund return filed by 30 September of the year following the purchases, supported by invoices that meet the content requirements of the VAT Directive. For a van fuelled forty times across three countries, “supported by invoices” is the expensive part: forty small documents, each of which must name the vehicle, the fuel, the rate and the customer.

A fuel card is a machine for producing that set of documents at the moment of sale. The payment function is incidental. Contactless cards, mobile wallets and in-app settlement have commoditised payment; none of them produces the categorised, vehicle-attributed, tax-decomposed record that a revenue authority accepts without a human reading it.

This is also why electronic-invoicing mandates do not threaten the card so much as formalise it. Germany made the receipt of structured electronic invoices mandatory from January 2025, with issuance phased in across 2027 and 2028. A structured invoice is what the card was already generating internally; the mandate makes everyone else catch up.

Electricity is where the rulebook moves

The card’s second act is charging, and here the fleet’s problem is not payment. It is price. Dataforce found that among German companies running electric vehicles, 60% hold a charging card. At public chargers, company-car drivers pay by card in two out of three cases and by app in a third. More than 60% of company charging happens on the company’s own premises and 23% at public points.

EnBW leads charging-card penetration at 30%, with DKV just behind on 27% — and among large fleets DKV ranks first. The gap between those two numbers and the fuel-card ranking tells you what is happening: an energy supplier beats the oil brands at the charger, but not by much, and not at the top end.

Fleets expect a card to work at a charger for the same reason they distrust apps: the price is unreadable. Public charging has been priced per minute, per session or per kWh depending on the network, which makes comparison almost impossible. In the same study, 53% of fleet managers rated price transparency for electricity as very important — a higher share than for fuel.

Regulation (EU) 2023/1804, the Alternative Fuels Infrastructure Regulation, now forces the format. Article 5(4) requires that at publicly accessible recharging points of 50 kW or more, the ad hoc price charged by the operator be based on the price per kWh for the electricity delivered, and that the price be shown at the point. The Commission’s own guidance is strict about that word: shown means visibly present at the station, on a screen or a sticker, and a reference to a website is not enough at 50 kW and above. Below that threshold the price may merely be made available, which a QR code can satisfy. The same article permits an occupancy fee per minute, but only to discourage long occupancy, and the Commission reads that as not normally chargeable from the first minute of a session. All publicly accessible points had to be digitally connected by October 2024, and ad hoc card payment at higher-power points is being phased in across 2027 and 2028.

That is a legislative decision to make the ad hoc price legible, in a unit a fuel card already reconciles, at the point of sale. It hands the incumbent issuers a market they did not earn. The charging networks built their commercial model on app-based subscription and roaming agreements; the Regulation has just made the walk-up, card-paying, per-kWh customer the reference case that every other price has to be measured against.

The reconciliation nobody has published

There is a real problem in this sector and it is not competitive. If an issuer earns a fixed fee per transaction plus a basis-point margin on litres, electrification moves the two in opposite directions: more transactions, much less volume. Card counts can rise while revenue per vehicle falls, and both statements can be true in the same year, in the same company, in the same accounts.

Nothing in the public record resolves this, because card issuers report either card numbers or billed volume, never both against the same vehicle base. That is the number to ask for in diligence: transactions per vehicle per year, and revenue per transaction, disclosed together. Everything else — penetration, brand rankings, network size — is a proxy that can move without the economics moving with it.

The number I will not give you

There is no single European fuel-card market size in this article, because I do not believe one exists. Three perimeters are routinely added together: cards issued, litres settled, and fee revenue. They move independently. A market can add cards (micro-fleets) while losing litres (electrification) while growing fee revenue (more transactions per vehicle). And “Europe” blends markets where the card exists mainly to recover cross-border VAT with markets where it is a fuel brand’s loyalty scheme wearing a corporate form.

The defensible statement is narrower and more useful: the card’s revenue is a function of transactions, not of energy. Anything that raises the number of transactions per vehicle — electrification does — while leaving the transaction fee intact, is accretive. Anything that removes the document requirement is fatal. Regulation is currently doing the first and not the second, which is an unusual position for a payments product to be in.

Frequently Asked Questions

Is the European fleet fuel card market growing or declining?

Both, depending on what you measure. Card penetration is still rising: Dataforce's 2025 study found 78% of German companies using fuel cards, up slightly year on year, with growth coming from fleets of up to 19 vehicles because penetration among fleets of 20 or more is already above 90%. But litres per vehicle fall as fleets electrify, so revenue per vehicle can decline while the number of cards rises. This article deliberately does not put a single market size on the category, because cards issued, litres settled and fee revenue are three different perimeters that move independently.

Why has EuroShell lost share to DKV and UTA?

Because acceptance breadth and neutral billing are the two criteria fleet buyers rank above fuel price, and a card issued by an oil major cannot be neutral about that oil major's price. In Dataforce's 2025 German study DKV ranks first, Aral second and UTA third, with EuroShell falling out of the top three into fourth. The wider trend is that brand-independent issuers are gaining while oil-major brands lose share.

Does electrification threaten fuel cards?

It changes their unit economics rather than their existence. A fleet that swaps a diesel van for an electric one may double its card transactions while removing most of the litres those transactions were attached to, so a fixed fee per transaction plus a margin on volume moves in two directions at once. The card's survival then depends on whether the compliance and reporting record it produces remains required — which is the part regulation is reinforcing, not weakening.

What does AFIR require at public charging points?

Regulation (EU) 2023/1804, Article 5(4), requires that at publicly accessible recharging points of 50 kW or more the ad hoc price be based on the price per kWh of electricity delivered and be shown at the point — which the Commission interprets as visibly present on a screen or sticker, not merely referenced digitally. Below 50 kW the price may be made available through electronic means such as a QR code. An occupancy fee per minute is permitted, but only to discourage long occupancy. Ad hoc card payment at higher-power points is being phased in across 2027 and 2028, and all publicly accessible points had to be digitally connected by October 2024.