If 2024 was the year of regulatory enforcement—with AFIR in the EU, NEVI in the U.S., and Australia’s new standards all taking effect—then 2025 is shaping up to be the year of data and cybersecurity. National governments have recognized that transparent, standardized data is critical to future-proofing the EV charging business model. From Brussels to Washington, regulators are rolling out technical frameworks that will fundamentally change how charge point operators report, secure, and monetize their infrastructure.
The stakes are high. April 14, 2025 marks a critical compliance deadline for AFIR data reporting, while new cybersecurity mandates under NIS2 and the Cyber Resilience Act are already in force across the EU. Meanwhile, fiscal frameworks are evolving rapidly—from VAT treatment clarifications to new e-invoicing requirements—and the Portuguese market is about to undergo its biggest structural reform in years.
Regulatory developments
AFIR data reporting to National Access Points (April 14 Deadline)
Under AFIR, EU Member States were required to establish National Access Points (NAPs) by December 30, 2024, to enable technical implementation of the regulation’s data-sharing provisions. In December, the European Commission published draft Delegated Acts that define the technical specifications for how CPOs must provide data, implement APIs, and support V2G functionality.
The data categories—originally outlined in April 2024—have now been significantly expanded with dozens of new parameters covering everything from real-time availability to pricing transparency and connector specifications. While these requirements are still undergoing final regulatory scrutiny, industry consensus suggests there will be minimal deviation from the draft language.
What this means for network operators:
- Compliance deadline: April 14, 2025
- CPOs must implement compliant APIs capable of delivering both static and dynamic data to NAPs
- Data must be provided in standardized formats (OCPI 2.2.1 or DATEX II, depending on jurisdiction)
- Non-compliance could result in penalties and restricted market access
The implementation of enhanced data reporting will strengthen the EV ecosystem by improving interoperability, enabling more accurate infrastructure planning, and streamlining cross-border operations. But it also introduces new technical and operational obligations that require immediate attention.
Cybersecurity in EV Charging: NIS2 and the Cyber Resilience Act
With the NIS2 Directive entering force in October 2024 and the Cyber Resilience Act now active, cybersecurity has become a foundational compliance requirement for EV charging operations in Europe. As of January 2025, most EU countries are still in the process of transposing NIS2’s minimum requirements into national law, but the core obligations are clear. Key requirments include criteria for product conformity, firmware performance, and cybersecurity risks. These criteria and requirements are quite aligned with the ISO27000 family of standards.
What this means for network operators:
- CPOs must work with hardware suppliers to verify compliance with NIS2 and CRA standards
- Software platforms (including CPMS providers) must implement secure authentication, encrypted communications, and regular security audits
- Operators may be classified as “essential entities” or “important entities” under NIS2, triggering additional governance requirements
- Supply chain due diligence is now mandatory—non-compliant equipment cannot be deployed
The regulatory focus on cybersecurity reflects growing awareness of EV charging infrastructure as critical national infrastructure. Operators who treat this as a checkbox exercise rather than a strategic priority will face both compliance risk and reputational exposure.
Fiscalization and VAT Treatment: Navigating New E-Invoicing Rules
New fiscalization rules rolled out across Europe in 2024, and 2025 will bring further harmonization—particularly around e-invoicing and VAT treatment of cross-border charging transactions. Requirements vary by market, but common elements are emerging:
- E-invoicing mandates: Several EU Member States now require real-time transmission of invoice data (in .xml or .csv format) directly to national tax authorities
- QR code requirements: Receipts and invoices must include machine-readable codes for verification
- VAT clarity: A landmark October 2024 ruling by the European Court of Justice confirmed that electricity sales are taxable supplies of goods, and that related services (such as network access fees) are separate transactions unless they are auxiliary to the electricity supply
This ECJ ruling has major implications for eMSPs operating cross-border services. It clarifies where VAT liability falls in complex roaming scenarios and will influence how charging transactions are structured and taxed across the Union.
What this means for network operators:
- CPOs and eMSPs must ensure their billing systems can generate compliant e-invoices
- Cross-border operators should review VAT treatment with legal and tax advisors
- Integration with national fiscal reporting platforms may be required depending on jurisdiction
Portugal’s Mobi.E liberalization
The Portuguese government has proposed a bill to liberalize the country’s EV charging market, aiming to boost competition and simplify payments for drivers. The proposal, scheduled for discussion in the Assembly of the Republic on January 30, represents one of the most significant structural reforms in European EV charging policy.
Key changes include:
- Removing mandatory contracts between operators and energy providers
- Enforcing transparent tariffs across all public charging networks
- Requiring ad hoc payment options to improve accessibility for occasional users and tourists
- Aligning local regulations with AFIR’s interoperability and transparency requirements
If adopted, this reform will fundamentally reshape the Portuguese market, reducing barriers to entry for new CPOs and improving the user experience for drivers who have long complained about the complexity of the existing system.
Funding & Incentive Updates
EU: €1 Billion in AFIF Funding Still Available
To date, the EU’s Alternative Fuels Infrastructure Facility (AFIF) has allocated €1.3 billion across 131 projects, supporting the installation of approximately 24,000 150kW charging points and 2,500 350kW ultra-fast chargers along the EU’s TEN-T corridors.
CPOs were able to submit project proposals at the end of 2024 as part of the latest €1 billion funding envelope. While results from the first cut-off date are still pending, new and returning participants have two additional opportunities to apply: June 11, 2025 and December 17, 2025.
Eligibility requirements:
- Projects must be located along TEN-T core or comprehensive network corridors
- Infrastructure must meet AFIR technical standards (already supported by AMPECO’s platform)
- Applicants must demonstrate financial viability and operational capability
AFIF remains one of the most substantial sources of non-dilutive capital for European charging infrastructure. Operators should prioritize applications for high-traffic corridors and strategically underserved regions.
New US administration and federal incentives
The Trump Administration’s Executive Order has introduced a 90-day pause on certain funding under the Inflation Reduction Act, raising questions about the future of federal EV charging incentives like NEVI and CFI.
NEVI (National Electric Vehicle Infrastructure Formula Program):
The NEVI Program, managed by the U.S. Federal Highway Administration (FHWA), is a $5 billion initiative aimed at expanding EV charging infrastructure across the United States from 2022 to 2026. As of January 2025, NEVI has allocated funding to 1000 projects in 35 states, DC and Puerto Rico, equaling $615.7 million in total and 204,000 ports.
Upcoming NEVI funds for FY26 could be rescinded, as the rest has already been allocated to states. However, dispersed funds with no contracts might be reclaimed by the federal government through an act of Congress.
CFI (Charging and Fueling Infrastructure Program):
The CFI program already had several rounds, allocating $1.9 billion out of the $2.5 billion envelope. CFI funding, awarded at the project level, is similarly paused, with some awards possibly at greater risk due to contractual status. Any reduction in funding could heavily affect companies and communities relying on these programs.
What this means for network operators:
While federal incentives face uncertainty, substantial funding remains available at the state and utility level. AMPECO’s platform already meets the operating conditions set by major state rebate programs including CALeVIP, NYSERDA, NJDEP, and National Grid.
Operators should prioritize applications for state and utility programs, which are insulated from federal policy shifts and offer more predictable funding timelines.
AMPECO leadership & advocacy
AFIR Delegated Acts: Industry Input on Data Standards
AMPECO submitted formal comments to the European Commission supporting the introduction of additional static and dynamic data types under AFIR Article 20(2). The implementation of enhanced data reporting will strengthen the EV ecosystem by enabling:
- Improved interoperability between networks and platforms
- More accurate reporting for regulators and investors
- Streamlined infrastructure development and grid integration
Our feedback emphasized the need for regulatory alignment between AFIR data requirements and existing communication protocols like OCPP 1.6 and OCPP 2.0.1. Read AMPECO’s full submission →
RED III Article 20a(3): Real-Time Battery Data Sharing
The revised EU Renewable Energy Directive (RED III) introduces Article 20a(3), which mandates that vehicle manufacturers provide real-time data on battery performance and vehicle status. Key data points include: Battery state of health (SoH), State of charge (SoC), Power set point, Battery capacity, Vehicle location (where applicable).
These parameters are essential for enabling smart charging, V2G technologies, and predictive maintenance. Article 20a(3) is set to be enforced starting January 1, 2025, according to European Commission guidelines.
AMPECO’s position: While some of this data is already available through OCPP protocols, full implementation requires embedding all RED III data reporting requirements into OCPP specifications. This will enable secure data transmission from vehicles to CPOs to regulatory authorities via standardized CPMS APIs.
Ireland: Supporting ZEVI’s Grid Integration Strategy
Zero Emission Vehicles Ireland (ZEVI) has published a data strategy aligned with AFIR mandates, introducing an important additional requirement: associating EV charging points with Meter Point Reference Numbers (MPRNs) to link them directly to the national electricity grid.
The suggested approach would enable accurate quantification and geographic localization of electricity demand from EV charging. The MPRN data offers critical benefits, including enhanced capacity planning for grid upgrades, optimized flexibility schemes to support energy services, detailed technical assessments for new charging infrastructure, and improved demand modeling to ensure the grid meets future capacity needs and aligns with AFIR targets.
AMPECO supported this approach by responding to ZEVI’s industry survey, emphasizing the operational benefits of standardized grid integration data.
United States: Medium- and Heavy-Duty Charging Infrastructure
AMPECO submitted comments to the U.S. Department of Transportation and the Joint Office of Energy and Transportation in response to a Request for Information on medium- and heavy-duty (MHD) electric charging technologies and infrastructure needs.
AMPECO’s recommendations for enhancing medium- and heavy-duty (MHD) fleet charging infrastructure emphasize the need for standardized protocols and seamless system integration to ensure compatibility across networks and manufacturers. They advocate for advanced management solutions, including load balancing and smart charging, alongside strategically placed charging stations near depots and transport routes.
Key Deadlines for Q1 2025
- January 1, 2025: RED III Article 20a(3) enforcement begins (battery data sharing)
- January 30, 2025: Portuguese Assembly debate on Mobi.E liberalization
- April 14, 2025: AFIR data reporting to National Access Points deadline
- June 11, 2025: AFIF funding application cut-off date
Need help navigating these regulatory changes? AMPECO’s regulatory intelligence team provides tailored compliance guidance for CPOs operating across global markets.
Schedule a consultation →
Stay updated on policy changes and funding opportunities: Discover the most comprehensive collection of EV charging grants, incentives, tax credits, and rebate programs—exclusively curated by AMPECO’s policy experts.
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