EU AFIR Regulation Explained: What It Means for EV Charging Station Procurement

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Executive Summary

The EU's Alternative Fuels Infrastructure Regulation (AFIR, Regulation EU 2023/1804) is the most consequential piece of EV charging legislation in European history. In force since April 13, 2024, it sets legally binding targets for charger density, power output, payment accessibility, data transparency, and interoperability standards, all of which directly determine which charging hardware can be lawfully deployed, financed, and operated across the EU's 27 member states. This guide decodes every major AFIR requirement and translates it into concrete procurement criteria, RFP language, and vendor evaluation checkpoints.

The Alternative Fuels Infrastructure Regulation (AFIR), officially Regulation (EU) 2023/1804, was published in the Official Journal of the European Union on September 22, 2023, and entered into full legal force on April 13, 2024. It replaced the earlier Alternative Fuels Infrastructure Directive (AFID, 2014/94/EU), upgrading from a non-binding directive to a directly applicable regulation, meaning no national transposition is required. Every EU member state is bound by its terms on day one.

AFIR is a core pillar of the European Green Deal's Fit for 55 package, which targets a 55% reduction in EU greenhouse gas emissions by 2030 relative to 1990 levels. The regulation recognises that EV adoption at scale is only possible if drivers have confidence in a dense, interoperable, and user-friendly charging network, and that market forces alone will not deliver this within the required timeframe.

Why AFIR Supersedes AFID: From Directive to Regulation

Under AFID, member states were required only to publish national policy frameworks, targets were indicative, not binding. AFIR changes the game entirely. It establishes minimum requirements that apply directly to charge point operators (CPOs), equipment manufacturers, and eMobility service providers (eMSPs) without the need for domestic legislation. Non-compliance can be penalised by national authorities and, ultimately, the European Commission.

For procurement professionals and fleet managers, this shift from directive to regulation eliminates regulatory arbitrage. Equipment that meets AFIR's technical specifications is lawful across the entire EU single market; equipment that does not cannot be deployed on publicly accessible infrastructure, regardless of which member state it is in.

AFIR's most immediate procurement impact comes from its mandatory infrastructure density targets along the Trans-European Transport Network (TEN-T). These targets define the minimum power output and geographic spacing of charging sites, and therefore set the floor specification for any publicly funded or publicly accessible charging deployment.

Passenger Vehicle Targets (Light-Duty Vehicles)

• By end of 2025: At least one fast-charging site (≥150 kW total capacity, with at least one connector at ≥150 kW) every 60 km in each direction on the TEN-T core network.
• By 2027: Total site capacity at TEN-T core network stations must reach ≥400 kW, including at least one connector at ≥150 kW.
• By 2030: Site capacity rises to ≥600 kW, with at least two connectors at ≥150 kW each, on the TEN-T core network.
• Urban and national capacity: Each member state must maintain publicly accessible charging power of at least 1.3 kW per registered battery-electric vehicle (BEV) and 0.8 kW per plug-in hybrid (PHEV).

Heavy-Duty Vehicle Targets

• By 2025: At least one charging hub every 120 km on TEN-T core corridors, with a minimum aggregated power of 1,400 kW per hub.
• By 2027: Every 60 km, minimum 2,800 kW aggregated,with at least two 350 kW connectors per hub.
• By 2030: Comprehensive coverage across the extended TEN-T network with significantly higher density and output requirements.、
  
  

Understanding the AFIR compliance calendar is essential for structuring multi-year procurement contracts, selecting hardware with appropriate feature roadmaps, and timing capital expenditure decisions. The table below maps every major AFIR milestone to its procurement implication.

Source: Regulation (EU) 2023/1804 Official Text | EU Commission AFIR Delegated Acts (2025)

AFIR's most technically demanding requirements relate to interoperability standards. These are no longer vendor preferences or market differentiators, they are legal minimum requirements for hardware sold into publicly accessible EU charging infrastructure. Procurement specifications must reflect these standards explicitly.

ISO 15118: The Interoperability Backbone

ISO 15118 defines the digital communication protocol between electric vehicles and charging stations. It enables critical capabilities including Plug & Charge (automatic authentication without cards or apps), smart charging coordination, and, in its most advanced form, Vehicle-to-Grid (V2G) energy services.

• January 8, 2026,ISO 15118-2 mandatory: All newly installed or renovated publicly accessible AC charging points must support EN ISO 15118-2:2016. This enables basic Plug & Charge authentication and high-level communication (HLC) between vehicle and charger.
• January 1, 2027,ISO 15118-20 mandatory: Full ISO 15118-20:2022 support required for all new public and private Mode 3 (AC) charging points. This unlocks bidirectional charging (V2G, V2H), automated connection devices (ACD), and wireless power transfer (WPT) readiness.

While ISO 15118 governs EV-to-charger communication, the (OCPP) governs charger-to-backend-system communication. AFIR's Article 5 data transparency requirements, real-time pricing, availability, connector status, and energy delivered, are technically achievable only with OCPP 2.0.1 or later.

• OCPP 2.0.1 minimum: Required for AFIR's real-time data sharing mandates. Provides the richer transaction model and metering capabilities that AFIR Article 5 demands.
• OCPP 2.1 (released January 2025): Adds native Plug & Charge support, V2X operations block, and enhanced DER integration. Backwards compatible with OCPP 2.0.1, enabling staged migration.
• OCPI (Open Charge Point Interface): Required for roaming interoperability between different charging networks,essential for pan-European driver access.

DATEX II: The Data Exchange Standard

From April 14, 2026, all AFIR-regulated charging data must be published in DATEX II format. CEN published the official extension standard (PD CEN/TS 16157-11:2025) in October 2025, covering energy infrastructure including EV charging networks. Charging operators must share real-time data, pricing, availability, charger status, via open APIs accessible to third-party platforms, navigation services, and national access points (NAPs).

Procurement teams should require confirmation from hardware and software vendors that their charging management systems (CMS/CSMS) are DATEX II compliant or have a certified integration partner.

AFIR fundamentally changes the commercial model for public charging by mandating open, frictionless access. The regulation is explicit: no driver should be excluded from using a public charger because they lack a subscription, an app, an RFID card, or an account with a specific operator.

Ad-Hoc Payment: The Baseline Requirement

• From April 13, 2024: All new DC charging points ≥50 kW must support ad-hoc payment,charging and paying without a prior contract or account.
• From 2027 (retrofit deadline): Existing DC charging points ≥50 kW must be retrofitted to support ad-hoc payment.
• Payment terminals: Physical contactless card terminals are required on new DC chargers ≥50 kW. At sites with multiple chargers, a single central payment terminal serving all chargers is permitted.
• QR code payments: Acceptable for lower-power AC chargers without displays, but AFIR requires dynamic QR codes (generated uniquely per session),static QR code stickers are not compliant.

Price Transparency Requirements

AFIR mandates that pricing information must be available to drivers before a session begins, through freely available digital means (app, website, or display). Pricing must be presented on a per-kWh basis for energy delivery, time-based pricing models (per-minute) are acceptable only where per-kWh metering is technically infeasible, and must include the per-kWh equivalent.

• eMSP pricing obligations: eMobility service providers must provide EV drivers with transparent, up-to-date pricing via digital tools. Roaming price transparency across networks is explicitly required.
• Non-discrimination principle: Prices must be reasonable, transparent, and non-discriminatory. Operators cannot charge dramatically different rates based on network membership without transparent justification.

The following consolidated checklist translates every major AFIR requirement into actionable procurement criteria. Use it to evaluate vendor proposals, structure RFP requirements, and conduct technical due diligence on shortlisted equipment.

Mistake 1: Procuring to 2024 Standards for 2027 Deployment

Hardware with a 10-15 year operational lifespan must be specified against the most demanding AFIR requirements it will face during its lifetime, not just those in force at purchase date. A charger procured in 2025 must be ISO 15118-20 capable before mandatory compliance kicks in January 2027.

Mistake 2: Accepting Static QR Code Solutions for AC Chargers

Many low-cost AC charging stations ship with static QR code stickers linking to payment portals. AFIR requires dynamically generated QR codes, unique per charging session, to prevent quishing (QR code fraud) and ensure compliant ad-hoc payment. Only chargers with a screen and a controller capable of generating session-specific QR codes meet this requirement.

Mistake 3: Neglecting DATEX II Data Export in CMS Selection

Charging Management System (CMS) vendors are often evaluated purely on operator-facing dashboards and billing capabilities. From April 2026, DATEX II-formatted real-time data export is a legal requirement. Ensure your CMS vendor has a certified DATEX II integration and can demonstrate compliance with the CEN/TS 16157-11:2025 standard.

Mistake 4: Under-Specifying Power for TEN-T Adjacent Sites

Sites within or adjacent to the TEN-T network that are designated as public charging locations must meet AFIR's power floor requirements. Deploying a 50 kW charger at a motorway service area today may be compliant today but non-compliant by 2027 when minimum site capacity rises to 400 kW. Model the full target-year power requirement before specifying hardware.

Mistake 5: Accepting Proprietary Charging Protocols

AFIR is built on open, vendor-neutral standards: OCPP, ISO 15118, OCPI, DATEX II. Proprietary backend protocols lock operators into single-vendor ecosystems and prevent the interoperability AFIR mandates. Any RFP should explicitly disqualify chargers that cannot operate independently of a specific vendor's CMS through open OCPP communication.

ISO 15118-20's mandatory adoption by January 2027 is not just a compliance checkbox, it is the technical foundation for Vehicle-to-Grid (V2G) and Vehicle-to-Everything (V2X) energy services. These capabilities allow electric vehicles to discharge stored energy back into buildings (V2H), local microgrids (V2L), or the public electricity grid (V2G), creating new revenue streams for fleet operators and CPOs.

Hardware procurement decisions made today determine whether operators can participate in grid services markets when they mature. V2G-capable hardware requires bidirectional power electronics, ISO 15118-20 communication firmware, and grid-code certifications (e.g., G99 in the UK, equivalents across EU member states). Procuring unidirectional-only hardware locks operators out of these markets for the hardware's entire operational life.

AFIR compliance is increasingly a prerequisite for accessing EU funding instruments for charging infrastructure. The Connecting Europe Facility (CEF), the European Regional Development Fund (ERDF), and national AFIR implementation funding all require grant recipients to demonstrate technical compliance with AFIR specifications.

Public procurement tenders for charging infrastructure, whether issued by member state authorities, motorway operators, or municipal governments, now routinely include AFIR compliance as a mandatory award criterion rather than a desirable specification. Vendors unable to demonstrate AFIR compliance across all relevant articles are disqualified at the technical evaluation stage.

• CEF Transport calls: Explicitly require AFIR-compliant infrastructure as a condition of funding eligibility.
• National implementation plans: Member states' AFIR National Policy Frameworks (NPFs) typically require AFIR compliance for nationally co-funded charging programmes.

Private investment: Institutional investors in charging infrastructure increasingly require AFIR compliance as a condition of investment, recognising stranded asset risk from non-compliant equipment.

The following official and authoritative sources are essential reading for procurement teams, legal counsel, and technical specification writers working on AFIR-compliant charging projects:

• Official AFIR Text,Regulation (EU) 2023/1804, EUR-Lex
• EU Alternative Fuels Observatory (EAFO),AFIR News & Delegated Acts
• IEA Policy Brief,Regulation (EU) 2023/1804 Policy Overview
• ISO 15118 Standard,org: Road vehicles – Vehicle to grid communication interface
• OCPP Standard,Open Charge Alliance: OCPP 2.1 Specification
• AMPECO AFIR Compliance Guide,The AFIR Compliance Guide for Charge Point Operators
• Delegated Act,EU Commission Implementing Regulation (EU) 2025/655, Data Accessibility Specifications for AFIR
• DATEX II Standard,CEN/TS 16157-11:2025 (Energy Infrastructure Extension)

The EU's Alternative Fuels Infrastructure Regulation represents the most comprehensive and binding framework for EV charging infrastructure ever enacted. For procurement professionals, the message is unambiguous: every charging station purchased today for deployment in publicly accessible EU locations must meet AFIR's technical, payment, data, and interoperability standards, or risk stranded assets, regulatory penalties, and exclusion from EU and national funding.

The compliance journey is structured around a clear timeline: ad-hoc payments are already mandatory (April 2024), ISO 15118-2 arrives January 2026, ISO 15118-20 and DATEX II follow in 2026-2027, and network-wide deployment targets scale through to 2030. Hardware with the operational longevity typical of EV charging equipment must be specified for the end-state requirements, not the current minimum.

Organisations that embed AFIR compliance into their procurement frameworks now, specifying open protocols, future-proof hardware, and contractually committed upgrade paths, will capture funding opportunities, avoid retrofit costs, and position their charging networks for the V2G and smart energy services that will define the next decade of sustainable mobility.