AFIR sets the ground rules for public charging.
AFIR has applied directly in all EU member states since 2024, without national implementation laws. For operators of publicly accessible charging points it defines three core obligations: ad-hoc charging without a prior contract, transparent prices before the session starts, and the provision of location and status data. These obligations are no longer a future topic but applicable law in day-to-day operations.
Ad-hoc charging means in practice: a driver without a charging contract must be able to start a session and pay electronically. At new DC charging points of 50 kW and above this includes a card terminal or a contactless payment option. The price must be clearly visible before the session starts, so that ad-hoc customers are not worse informed than contract customers.
Data provision is often underestimated. Static data such as location and connector types, as well as dynamic data such as availability and the ad-hoc price, must be available in machine-readable form so that routing services and fleet systems can use them. In Germany, calibration law (Eichrecht) applies on top: MID-compliant meters and OCMF-signed measurement values with transparency software remain mandatory independently of AFIR.
- Ad-hoc charging without a prior contract at publicly accessible charging points.
- Electronic payment, at new DC charging points of 50 kW and above via card terminal or contactless.
- Price displayed before the session starts, clear and comparable.
- Static and dynamic data (location, availability, price) provided in machine-readable form.
Since January 2026: ISO 15118 for new public AC charging points.
Since January 2026, newly installed public AC charging points in the EU must support ISO 15118, i.e. digital high-level communication between vehicle and charging point. Existing infrastructure is not affected retroactively. Nevertheless, the obligation immediately changes every procurement decision, because whatever is ordered today has to meet the requirement.
Technically this is more than a firmware switch. ISO 15118 requires a PLC modem for communication over the control pilot, while many AC wallboxes so far only implement basic signalling according to IEC 61851. Hardware without a PLC modem cannot be retrofitted in software, and this is exactly where retroactive upgrade requests regularly fail.
In projects we also see that firmware maturity varies considerably between manufacturers. A charging point can list ISO 15118 on the datasheet and still fail the handshake with certain vehicles. Procurement should therefore not just ask for the standard, but for interoperability evidence and a clear update commitment from the manufacturer.
Plug & Charge stands or falls with the certificate chain.
Plug & Charge replaces RFID card and app with certificate-based authentication: the vehicle presents a contract certificate, and the charging point validates the chain up to the root CA. Several roles are involved: a V2G root CA at the top, CPO certificates on the charging points, contract certificates from the eMSP, and provisioning in the vehicle by the manufacturer. Each of these parties has to issue, distribute and renew its certificates correctly.
Operationally this means a certificate lifecycle that many CPOs have not had so far: installation, renewal and revocation of certificates on every charging point. OCPP 2.0.1 and 2.1 provide the corresponding messages, for example for certificate installation and for forwarding 15118 certificate requests. In practice, PKI integration usually runs through established operators; Hubject is the most common point of contact as a roaming hub and PKI provider.
Without this discipline, Plug & Charge fails silently: the vehicle falls back to another authorization method or the session does not start at all, and the backend only shows an unspecific abort. Diagnosis requires the complete sequence of 15118 handshake and OCPP messages in one shared timeline. Individual error codes are almost never enough here.
ISO 15118-20: Plug & Charge evolved, V2G prepared.
ISO 15118-20 is the new protocol generation and brings two essential extensions: bidirectional charging as a standardized use case and a reworked Plug & Charge mechanism, including support for multiple contract certificates in the vehicle. This turns V2G from a pilot topic into something that can be built in a standards-compliant way.
Important to know: 15118-2 and 15118-20 are separate protocol generations that vehicle and charging point negotiate when the connection is established. For operators this means new hardware should be 15118-20 capable or at least upgradeable by the manufacturer. This applies especially where bidirectional use cases such as fleet buffering or depot load shifting are realistic in the medium term.
On the backend side, OCPP 2.1 supports this development: the version is available, backward compatible with 2.0.1, and addresses bidirectional energy management among other things. Building an OCPP 2.0.1 foundation today therefore does not block the path to 2.1. The real break lies elsewhere, namely between 1.6 and 2.0.1.
Practical to-dos for CPOs with existing infrastructure.
Existing infrastructure does not have to be rebuilt, but every extension, every replacement and every backend change should take the new obligations into account. The first step is an honest inventory: which charging points have PLC hardware, which OCPP version runs where, which sites already meet the AFIR requirements for payment and price display, and which do not.
The second step is an OCPP strategy. OCPP 1.6 and 2.0.1 are not compatible, and certificate management for Plug & Charge is only properly solved from 2.0.1 onwards. Mixed operation over several years is realistic for most operators, so migration should be planned per site or per manufacturer batch rather than as a big bang across the entire fleet.
In projects an OCPP broker proves its worth here, running 1.6 and 2.0.1 charging points in parallel against the same backend, while CPMS modules take over certificate, pricing and data processes step by step. This way, AFIR and ISO 15118 do not become deadline projects but a controlled transition during ongoing operations.
- Create an inventory: record PLC capability, OCPP version and AFIR status per charging point and site.
- Adjust procurement: new AC charging points only with ISO 15118 support, ideally 15118-20 ready.
- Clarify PKI and roaming integration: certificate lifecycle, Hubject connection, OCPI 2.2/2.3.
- Check the ad-hoc payment path and price display per site against the AFIR requirements.
- Automate the provision of static and dynamic data instead of maintaining it manually.