December closes out 2025 with a European Grids Package that directly addresses one of the longest-standing operational frustrations for charging operators: slow, opaque, and fragmented grid connection and permitting processes. Charging infrastructure is now explicitly recognised as being of overriding public interest — a legal designation that fundamentally strengthens its position in permitting procedures and could shave years off deployment timelines in Member States where multi-year delays have become the norm.

But December also delivered the EU Automotive Package, which confirms a strategic recalibration of Europe’s electrification trajectory. The Commission reduced the 2035 target to a 90% tailpipe emissions reduction, allowing the continued presence of ICEs, PHEVs, and hybrids through compensation mechanisms. For operators who have built business cases on the assumption of a hard 2035 ban — and who advocated through the Take Charge campaign to prevent exactly this outcome — the recalibration requires honest reassessment of utilisation forecasts and investment timing.

Meanwhile, the PSD3/PSR provisional deal reshapes payment rules for EV charging, the Netherlands advanced its RED III transposition for transport, the UK extended its PCPR uptime reporting deadline, and 16 US states filed a new lawsuit challenging the suspension of CFI and NEVI Accelerator funds.

Here’s what shaped the final month of 2025 and what it means heading into 2026.

Regulatory developments

European Grids Package targets charging deployment bottlenecks

The European Grids Package combines legislative proposals and non-binding guidance to accelerate grid build-out and ensure more efficient use of existing capacity. For charging operators, the headline provisions are transformative.

Charging infrastructure is explicitly recognised as being of overriding public interest, significantly strengthening its legal position in permitting procedures across all Member States. Small charging installations of 100 kW or below will no longer require administrative permits except for grid connection, while larger sites above 100 kW must be processed within a maximum six-month permitting window. This alone addresses years of uncertainty for CPOs who have faced multi-year delays in some Member States.

The package also tightens procedural discipline around grid connections. Authorities must rapidly assess whether applications are complete, and system operators are pushed to improve transparency by publishing hosting-capacity maps across all voltage levels and updating them regularly. Member States are explicitly encouraged to move away from first-come, first-served models toward more strategic grid allocation — an important signal for future-proofing high-power charging hubs.

This builds directly on the Flexible Connection Agreements position that ChargeUp Europe published in November, which called for exactly these kinds of structural reforms. The Grids Package provides the legislative framework; FCAs provide the practical deployment mechanism.

What this means for operators:

  • The six-month permitting cap for installations above 100 kW, if consistently implemented at the national level, would materially reduce project timelines and development risk across the EU
  • The permit exemption for installations of 100 kW or below removes a barrier for destination charging, workplace charging, and residential deployments — operators can accelerate these segments immediately once national transposition occurs
  • Hosting-capacity map publication requirements give operators critical grid intelligence for site selection — this shifts grid access from guesswork to data-driven planning
  • The shift away from first-come, first-served toward strategic allocation means operators planning high-power hubs should engage with grid planning processes early rather than simply submitting connection requests
  • National implementation is the key variable — operators should monitor transposition timelines in their priority markets and engage through industry associations to ensure consistent application

EU Automotive Package reduces 2035 target to 90% CO₂ reduction

The European Commission’s Automotive Package confirms a strategic recalibration of EU transport policy. While the overall direction toward electrification remains intact, the Commission has opted for flexibility over rigidity — most visibly by reducing the 2035 target to a 90% tailpipe emissions reduction, allowing the continued presence of ICE vehicles, PHEVs, and hybrids through compensation mechanisms.

The package delivers mixed signals for the EV ecosystem. On the positive side, it introduces targeted incentives for small, EU-made electric vehicles, mandatory decarbonisation targets for large corporate fleets, and substantial backing for a European battery value chain through the €1.8 billion Battery Booster. At the same time, looser CO₂ trajectories — especially for vans — will likely slow BEV rollout compared to earlier projections.

What this means for operators:

  • EV growth continues, but at a less linear pace than the original 100% target implied — infrastructure planning, utilisation forecasts, and investment timing must reflect a market shaped by regulatory flexibility and industrial policy rather than hard bans
  • The corporate fleet decarbonisation mandate remains a strong demand driver — as we covered in March, corporate fleets account for approximately 60% of new EU car registrations, and the mandate ensures sustained demand for depot and workplace charging
  • The Battery Booster and small EV incentives should accelerate affordable EV adoption, which benefits operators focused on urban and residential charging segments
  • Operators who built business cases assuming a complete ICE phase-out by 2035 should revisit utilisation assumptions — the 90% target means a tail of combustion vehicles will persist longer than originally projected

PSD3 and Payment Services Regulation reshape EV charging payment rules

Parliament and Council reached a provisional deal on PSD3 and the Payment Services Regulation, strengthening EU-wide rules on fraud prevention, fee transparency, and competition between bank and non-bank payment service providers. The package expands PSP liability where anti-fraud controls are insufficient, tightens authentication requirements for suspicious payments, and advances a more harmonised payments market.

For EV charging, the shift from PSD2 to the combined PSD3/PSR framework addresses long-standing inconsistencies but does not automatically exempt charging payments from Strong Customer Authentication. The reforms raise expectations for payment harmonisation and liability clarity while the PSR’s direct applicability reduces national divergence and supports more consistent cross-border deployment.

What this means for operators:

  • The absence of an automatic SCA exemption for EV charging payments means operators must continue managing authentication requirements for unattended, low-value transactions — the industry’s push for a proportionate approach aligned with AFIR’s frictionless access goal remains unresolved
  • The PSR’s direct applicability (no national transposition required) means compliance obligations will be consistent across Member States — this simplifies cross-border deployment compared to the current PSD2 patchwork
  • Operators should review their payment processing arrangements with PSPs to ensure alignment with the strengthened fraud prevention and liability requirements

Netherlands advances RED III implementation for transport

The Dutch government has taken decisive steps toward RED III implementation for transport, confirming that from 2026 the existing Renewable Energy for Transport system transitions into a Fuel Transition Obligation. Legislative amendments increase the sub-target for renewable fuels of non-biological origin — specifically hydrogen and e-fuels — with a gradual ramp-up toward 2030 providing long-term investment certainty for hydrogen refuelling infrastructure.

A targeted mitigation measure applies in 2026 for maritime and inland shipping fuels to address uncertainty around Belgium’s RED III implementation. From 2027, originally announced targets fully apply, reaffirming the Netherlands’ commitment to a predictable transition — notably contrasting with Germany’s delayed transposition that we covered in July.

UK extends PCPR uptime reporting deadline to January 30

OPSS notified charge point operators that the reporting deadline for the 99% reliability requirement for rapid public charge points (50 kW+) is temporarily extended to January 30, from the original January 14 date. Under the PCPR reliability regime, operators with rapid chargers must also publish a short statement on their website confirming compliance — a compliance confirmation that does not require disclosing detailed performance metrics.

AMPECO already provides a live, operational, and PCPR-compliant uptime reporting solution, enabling UK operators to meet both reporting and public confirmation obligations without additional development.

Funding and incentive updates

16 US states sue DOT and FHWA over suspended CFI and NEVI Accelerator funds

On December 16, a broader coalition of states filed a new lawsuit challenging the US Department of Transportation and Federal Highway Administration for indefinitely suspending the Charging and Fueling Infrastructure and NEVI Accelerator grant programmes. This second case builds directly on the June 24 preliminary injunction that blocked the NEVI Formula Program freeze — an injunction the agencies notably declined to appeal.

The December filing argues that the same approach — executive orders, unpublished guidance, and categorical refusal to obligate congressionally mandated funds — is now being applied to CFI and Accelerator awards, placing billions of dollars and dozens of state and local EV infrastructure projects at risk. The states are effectively asking the court to enforce what Congress already decided: federal agencies cannot nullify infrastructure law by refusing to spend the money.

What this means for operators:

  • This is the second major legal challenge to federal EV funding suspension in six months — the pattern of successful state litigation strengthens the legal precedent protecting congressionally appropriated infrastructure funds
  • Operators with CFI or Accelerator-dependent projects should monitor the case closely while continuing to prioritise state and utility programmes that remain insulated from federal administrative action
  • The expanding coalition (from 14 states in June to 16 in December) signals growing bipartisan frustration with the funding suspension strategy

AMPECO leadership and advocacy

AMPECO joins NCWM

AMPECO has become an Associate Member of the National Council on Weights and Measures, the body that underpins how electricity and other commodities are legally measured and trusted in commercial transactions in the US. Through this membership, AMPECO gains access to key NCWM handbooks, NTEP work groups, and certification frameworks — enabling alignment with established legal-metrology standards while actively engaging in discussions shaping their application to modern, software-driven charging infrastructure. The membership is directly relevant as the MID modernisation in Europe and California’s reliability reporting requirements converge on the same theme: accurate, transparent metering as a regulatory baseline.

Key dates and deadlines for 2026

  • January 1, 2026: Germany V2G double taxation elimination takes effect
  • January 1, 2026: Germany company car home-charging tax guidelines take effect
  • January 1, 2026: California 97% uptime mandate takes effect
  • January 8, 2026: ISO 15118-2 compliance for newly installed public chargers
  • January 29, 2026: CALeVIP FCCP extended application deadline
  • January 30, 2026: UK PCPR uptime reporting deadline (extended)
  • April 14, 2026: DATEX II reporting deadline
  • June 1, 2026: MCS standard expected formal publication
  • January 1, 2027: ISO 15118-20 compliance for new public and private chargers
  • January 1, 2027: ViDA Union OSS applies to B2C EV charging

Looking back at 2025

This final edition caps a year that transformed EV charging from a policy-driven sector into a compliance-intensive one. The AFIR delegated acts, DATEX II, ISO 15118 timelines, CRA, EAA, RED, and MID modernisation have collectively moved the industry from broad regulatory frameworks to granular technical requirements with binding deadlines.

The operators best positioned for 2026 are those who treated this year’s regulatory developments as implementation priorities rather than monitoring exercises. The deadlines are now close, the standards are published, and the compliance window is narrowing.

We’ll be back in January with the first Policy Corner of 2026. Until then, the AMPECO regulatory team remains available to help you navigate the year ahead.


Need help preparing for 2026’s compliance deadlines?
Schedule a consultation with AMPECO’s regulatory intelligence team →

Author

Ivelina Kadiri

Policy Compliance Manager

About the author

Ivelina is a trend-seeking policy compliance manager who skillfully navigates complex regulatory landscapes and bridges the gap between sustainable transportation goals and actionable implementation.