TCA Statement on AFIR

Making AFIR work in practice – for simple, affordable and verifiable charging in Europe

Good regulation is measurable – not open to interpretation. AFIR can bring about a breakthrough in user-friendly charging. To achieve this, key requirements must be clearly defined, verifiable and economically feasible.

Vienna, 9 December 2025 – The EU Regulation on the deployment of alternative fuels infrastructure (AFIR) sets important guidelines for the expansion of charging infrastructure and a better user experience. The Trusted Charging Alliance (TCA) expressly supports the objectives of AFIR. From a practical implementation perspective, however, more precise, verifiable and economically feasible specifications are needed in key areas to ensure that user-friendliness and expansion speed are not slowed down by room for interpretation, unnecessary costs and unclear testing logic.

Background and objective of the statement

To achieve climate neutrality by 2050, the EU is focusing heavily on electrification in the transport sector. This can only be achieved with a reliable charging infrastructure that is available throughout the EU. With AFIR (EU) 2023/1804), the EU is creating central guidelines for this – from minimum coverage and technical standards to payment. Between 2025 and 2027, further binding requirements will follow in the form of legal acts, in particular on open data, standards, and private charging infrastructure. The aim of our statement is to strengthen this implementation phase with clear, verifiable and economically feasible requirements – so that user-friendliness and expansion are not slowed down by room for interpretation and inconsistent interpretation.

“We all want public charging to be as easy as refuelling across Europe. For AFIR to achieve this goal, key requirements must not be open to interpretation, but must contain clear minimum standards and clear test criteria,” explains Gerald Stiepan, Vice President of the Trusted Charging Alliance (TCA).

Eight points that now need to be clearly regulated

In an open letter published today, the Trusted Charging Alliance (TCA) identifies eight key areas for action:

 

  1. Clearly specify card payments at DC and AC charging points – clear minimum requirements, no contradictory interpretations.
  2. Regulate direct payment practically – define equivalent options in such a way that user-friendliness is achieved without unnecessary additional costs. Allow Plug & Charge based on Secure Codes (SRCI) at terminals instead.
  3. Define accessibility in a binding and verifiable manner – measurable criteria instead of unclear “recommendation” interpretations. Align disability with e-mobility (treat blind/deaf people in the same way as roadworthiness)
  4. Address uniform, consumer-oriented standards binding – interoperability requires clear guidelines.
  5. Clearly define “publicly accessible” – clear demarcation (e.g. semi-public/business) for legal certainty.
  6. Private charging points from 2027: regulate transition/existing stock/calibration law logic – predictable paths instead of retrofitting uncertainty.
  7. Ensure verifiability – including vehicle-to-grid (V2G) – requirements must be auditable and take future grid utility into account. All testing centres in the EU must be recognised.
  8. Clearly regulate liability – assign responsibilities along installation/operation and private/business lines.

“If specifications remain unclear or audit trails are missing, this leads to delays, higher costs and, ultimately, higher prices for consumers. Smaller and rural locations in particular must not be left behind due to additional complexity,” Gerald Stiepan continues.

Goal: consistent implementation instead of a patchwork quilt

“People who charge publicly shouldn't have to interpret rules first. Uniform payment and clear standards must work the same everywhere.”
Gerald Stiepan
TCA Vize President

Update Summer 2026

After the Call of evidence the European Commission got nearly 1100 Feedbacks on the AFIR regulations. The TCA wanted to highlight some of them: 

Spanish Association of Cars and Trucks:
The current regulatory approach, focused on vehicle manufacturers and an asymmetrical sanctioning framework, is insufficient without equivalent development of enabling infrastructure conditions

Inspire EV : German electric mobility association
Given the current state of the market, it is difficult to understand why compliance with
the ISO 15118-20 standard is to become mandatory from 1.1.2027. In particular, the
requirement that this should also apply to private charging points is incomprehensible.

German Association of the Automotive Industry (VDA)
The VDA perceives a clear disconnect between regulatory ambition and supporting market conditions

Amazon
The Alternative Fuels Infrastructure Regulation (AFIR) is a cornerstone regulatory instrument, which upon being properly implemented, enables companies across the transportation and logistics industry to develop their decarbonisation strategies and deploy zero emission vehicles at scale. In parallel to the upcoming AFIR review, it is therefore critical that EU member states increase their efforts to meet the requirements of the current legislation However, significant challenges remain — particularly for the heavy-duty vehicle segment Grid investments of up to €600 billion will be required to support this scale of electrification.

Eni S.p.A. Italy
While AFIR has established a common framework, particularly along the TEN-T network, it does not fully reflect evolving market needs and technologies. Its revision is a key opportunity to adopt a more pragmatic and holistic approach, aligning infrastructure with market realities, technological progress, hence ensuring the Regulation is fit for purpose and future-proof.

LeaseEurope : Belgium
While AFIR establishes a coherent and structured framework for the deployment of alternative fuels infrastructure across the Union, its effectiveness remains limited in practice

Avere France
Avere-France wishes to place particular emphasis on the issue of ISO 15118-20. AvereFrance supports the gradual introduction of this standard, which is a structuring step forward for smart charging and bidirectionality. However, its entry into force on 1 January 2027 raises real operational difficulties for the sector, in particular for the AC terminals, the compliance of which involves material changes that cannot be ‘backdated’.

Charging Interface Initiative (CharIN) e.V.
Global To ensure future interoperability, it is important to distinguish between hardware and software compliance of charging stations with ISO 15118-20. On one hand, the necessary investments are being made as industry moves towards hardware which is capable of supporting ISO 15118-20. Nonetheless,despite investments and industry efforts, there exists a substantial amount of charging infrastructure stock which is unable to use ISO 15118-20, using ISO 15118-2 instead. The current mandate would lead to the creation of unnecessary E-waste which is counter to the green interests of the EU and simultaneously creates an economic disadvantage for several companies, notably European ones. On the other hand, the situation for software compliance is more complex. Significant concerns remain regarding the feasibility of the proposed application date of 1 January 2027 for ISO 15118-20 for newly installed or renovated chargers. Industry stakeholders widely consider this timeline to be technically unrealistic given the current state of development of ISO 15118-20 and the broader complementary and necessary standards. In this context, allowing additional time for implementation, or introducing greater flexibility for certain use cases such as private or residential charging, would help ensure interoperability while avoiding disproportionate burdens on market actors.

ACEA (European Automobile Manufacturers’ Association) (Belgium)
V2G charging capability of light-duty vehicles increased modestly from 12% to 13% but there is still a room for significant growth. The legal and economic structures for V2G in Europe are still being developed. & Beyond reporting and corrective action plans, the Regulation does not provide for effective consequences in situations of delayed or insufficient compliance. From an overall regulatory perspective, this creates a clear imbalance. While vehicle manufacturers are subject to immediate and substantial penalties under the CO₂ fleet regulations for both light- and heavy-duty vehicles, Member States face no comparable consequences if charging infrastructure targets under AFIR are not achieved within the prescribed timelines. To ensure credibility, effectiveness and fairness of the regulatory framework, the AFIR review should address this asymmetry. A more balanced enforcement approach is needed, in which binding infrastructure targets are accompanied by appropriate and effective consequences in cases of non-compliance by Member States

EON – Energy
Utility On data governance and smart charging, implementation should build on existing roles and direct machine-to-machine access, rather than creating new market roles. Interoperability also needs to be delivered symmetrically: if ISO 15118-20 is required for charging infrastructure, corresponding obligations should also apply to vehicles. In short, AFIR does not need new headline targets or a broader reopening. It needs disciplined implementation, targeted clarification and better enabling conditions for delivery

Vattenfall Sweden
AFIR is a cornerstone of the energy transition and an essential instrument for achieving the EU’s Fit for 55 objectives. Therefore, it is key to keep AFIR intact as far as possible and make only minor adjustments. Vattenfall calls for further clarification of roles and responsibilities between CPOs and EMSPs to ensure both roles work towards enabling a simple charging experience As a leading CPO and eMSP, we see that parts of ISO 15118-20 are ready to deliver value now— especially Plug & Charge, which brings immediate benefits for drivers and can be rolled out gradually. Other elements, notably bidirectional charging and V2G, depend on wider market and system readiness that is not yet in place. Vattenfall therefore calls for a phased, capability-based approach: prioritize Plug & Charge and forward compatibility by 2027 and align any mandatory V2G-related requirements with proven readiness across vehicles, grids, and markets.Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.

Chademo Association : (Original Statement December 2024)
We were surprised to see the mandate extended to the private domain. As a member of the STF expert sub-group*, we began our work on the premise of considering public domain charging standards covered by AFID/AFIR. It is regrettable that the proposal to apply such technical requirements (which are anticipated to have a significant impact on the industry) to the entire private domain was made without thorough discussion from the outset in the expert group

Tesla
While AFIR has successfully accelerated infrastructure deployment, the next phase must address fragmentation, ensure regulatory coherence, and better align obligations with technological and market realities.

ChargeUp Europe
Additional prescriptive requirements on pricing structures risk distorting the market and increasing costs for consumers. Our attached Q&A on pricing sets out in more detail the factors determining the pricing of EV charging services in Europe today. In this context, we consider that the immediate priority should be on effective implementation, enforcement, reducing national fragmentation, and practical operability of the existing framework, including addressing remaining barriers on the ground. Strengthening delivery will be more impactful in the short term than introducing additional obligations. 

Climate Group EV100 (United Kingdom)
Smart and bidirectional charging: AFIR mandates smart charging readiness but should promote usability by expanding availability of dynamic, time-based price signals at charge points. These price signals are critical to unlocking the business case for charging services and lowering total cost of ownership (TCO) via electrification for fleets. Integrating bidirectional charging (V2G) capability via implementing ISO 15118-20 by 2027 will be key, but aligning with vehicle capabilities is also required for V2G to scale in practice

AMPECO- Emsp
Regarding technical mandates, upcoming adoption of OCPP 2.0.1/2.1 is desired and it must avoid compulsory hardware retrofits to protect operator economics. At the same time, obligations for ISO 15118-20 should be deferred until parallel vehicle typeapproval mandates and PKI governance frameworks are finalized

ABB
ABB welcomes the launch of the revision process of Regulation (EU) 2023/1804 Alternative Fuels Infrastructure Regulation (AFIR). However, with regard to Commission Delegated Regulation (EU) 2025/656 of 2 April 2025, amending Regulation (EU) 2023/1804, the technical requirements set out in Annex IIapplicable from 1 January 2027are considered excessively stringent for EVSE and EV manufacturers. This gives rise to the following impacts: 1. Significant difficulties in the technical development of products. 2. Timelines that are not suitable for the proper certification of products. 3. A lack of accredited laboratories capable of performing conformity testing for ISO 15118- 20 communication. 4. An increase in the costs of EVSE and EVs. Furthermore, it is currently not possible to verify communication in accordance with ISO 15118-20, as the relevant test cases are still under development: ISO 15118-22 Ed.1 is expected to be published in December 2027 ISO PAS 15118-23 Ed.2 (including AC test cases) is expected in the first half of 2028 Regarding EVSE, we also believe it is fundamental to await the publication of the updated product standards IEC 61851-1 (for AC Mode 3 Charging station) and IEC 61851-23 (for DC Mode 4 Charging station), which will include dedicated annexes about communication via the ISO 15118-20 protocol. These standards are expected to be published between the end of 2026 and the 2027 and subsequently harmonised at European level by 2028. For these reasons, we consider it necessary to postpone the entry into force of the applicable requirements to 1 January 2029

GEWISS
Gewiss welcomes the launch of the revision process of Regulation (EU) 2023/1804 Alternative Fuels Infrastructure Regulation (AFIR). However, with regard to Commission Delegated Regulation (EU) 2025/656 of 2 April 2025, amending Regulation (EU) 2023/1804, the technical requirements set out in Annex IIapplicable from 1 January 2027are considered excessively stringent for EVSE manufacturers. This gives rise to the following impacts: 1. Significant difficulties in the technical development of products. 2. Timelines that are not suitable for the proper certification of products. 3. A lack of accredited laboratories capable of performing conformity testing for ISO 15118-20 communication. 4. An increase in the costs of EVSE and EVs. Furthermore, it is currently not possible to verify communication in accordance with ISO 15118-20, as the relevant test cases are still under development: – ISO 15118-22 Ed.1 is expected to be published in December 2027 – ISO PAS 15118-23 Ed.2 (including AC test cases) is expected in the first half of 2028. Regarding EVSE, we also believe it is fundamental to await the publication of the updated product standards IEC 61851-1 (for AC Mode 3 Charging station) and IEC 61851-23 (for DC Mode 4 Charging station), which will include dedicated annexes about communication via the ISO 15118-20 protocol.

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