January opens 2026 with a cybersecurity package that makes NIS2 simpler for operators running networks in more than one EU market. The European Commission’s January 20 package introduces maximum harmonization. Member States can no longer add their own national requirements on top. For CPOs that have been tracking a different NIS2 variant in every country, that means one standard and one point of contact through ENISA.
In the US, the rules for selling electricity by the kWh got stricter. NIST’s 2026 edition of Handbook 44 tightens accuracy requirements for both AC and DC charging. California now treats any charger that bills per kWh as a fuel pump. No charger can enter commercial service until a Registered Service Agency commissions it.
Meanwhile, the Commission announced a single EU company structure at Davos, Italy’s competition authority opened proceedings against A2A over roaming prices, the Netherlands introduced ERE certificates that pay charge point owners per kWh charged, the California Energy Commission opened two NEVI funding rounds with spring deadlines, and AMPECO joined 50+ companies at the European Parliament to press MEPs to hold the line on 2035.
Here’s what shaped the first month of 2026 and what it means for your operations.
Regulatory developments
EU Cybersecurity Package simplifies NIS2 compliance
The European Commission’s January 20 cybersecurity package (COM(2026) 11 and COM(2026) 13) simplifies NIS2 through maximum harmonization. It creates a single EU standard. Member States cannot add national requirements. Around 22,500 entities move to “important” status with lighter supervision. ENISA takes on cross-border coordination and becomes a single contact point for operators active in several countries.
EU cyber posture certificates now carry a presumption of NIS2 conformity. In practice, certification equals compliance. The package also sets deadlines for post-quantum cryptography (PQC): 2030 for critical systems and 2035 for general infrastructure. It introduces standardized ransomware reporting with liability protections. It also clarifies that only electricity producers above 1 MW capacity are covered.
Implementation is set for Q1 2027.
What this means for operators:
- One NIS2 rulebook across the EU means multi-market operators can build one compliance program instead of tracking national add-ons country by country.
- ENISA as a single contact point reduces duplicate reporting to different national authorities.
- Cyber posture certificates work across NIS2, the Cyber Resilience Act, and sector legislation. Certification is now the most efficient route to compliance.
- Chargers and components bought in 2026 will likely still be in the field when the 2030 and 2035 PQC deadlines arrive. Build PQC readiness into procurement specs now.
- Operators need geopolitical risk assessments for critical components sourced from third-country suppliers. Start by mapping your hardware supply chain.
- The 1 MW threshold clarifies obligations for CPOs with co-located generation or storage. Check whether your sites fall above or below it.
EU Inc. proposes a single company structure for cross-border operations
At WEF Davos 2026, Commission President von der Leyen announced EU Inc. It is a unified European company structure under a “28th regime.” One registration would be valid across all Member States, with 48-hour online incorporation and harmonized governance and capital rules.
There is an important limit. Energy market directives, fiscalization mandates, and AFIR requirements operate independently of company law. EU Inc. will not remove them. Its practical value for CPOs stays unclear until the legislative proposal, expected in March 2026, shows how it interacts with these regulatory layers. Trilogue negotiations will follow.
Italy’s antitrust action against A2A sets a pricing precedent
The Italian Competition Authority opened proceedings against A2A for alleged abuse of dominance. The case targets A2A’s dual role as both CPO and MSP, and whether its pricing unlawfully squeezed independent MSPs. It builds on the Enel X Way precedent, which established that charging rivals higher wholesale prices than internal rates is exclusionary conduct under Article 102 TFEU.
The Authority alleges that A2A’s roaming prices to rival MSPs exceeded its own retail prices at the same locations over a sustained period. Competitors buying wholesale access could not match A2A’s retail offers without losing money. The effect was strongest for AC charging, still the backbone of Italy’s public network. Subscription and flat-rate offers made it worse. Negative margins were observed from early 2024 through late 2025, particularly in Milan and Brescia.
What this means for operators:
- Operators acting as both CPO and MSP should compare the roaming prices they offer rival MSPs against their own retail prices at the same locations. A sustained gap where wholesale exceeds retail is exactly what regulators are testing for.
- Subscription and flat-rate offers need particular scrutiny. They widened the gap in the A2A case.
- The precedent rests on EU competition law, not Italian rules alone. Operators with dual roles in other markets should review their pricing with that in mind.
NIST Handbook 44 introduces stricter accuracy requirements
NIST published the 2026 edition of Handbook 44 with substantive changes to EV charging accuracy requirements.
Section 3.40 on Vehicle Fueling Systems covers legacy DC systems commissioned before January 1, 2025, that operate under the 5.0% tolerance threshold. These must now be marked “Class 5.” Grandfathering ends January 1, 2034. AC charging now requires three-point accuracy verification: low load (4-10 amperes), mid range (40-60% of maximum), and high load (70-100% of maximum). EVSE must keep transaction data for at least 15 minutes during a power outage, extended to eight hours for long-term parking installations.
Section 3.41 on Non-Utility Electricity-Measuring Systems remains a tentative code, subject to field evaluation. It applies to electricity sold on measured consumption outside utility billing, such as landlord-tenant billing and commercial park distribution. Where the primary meter display is not accessible, operators must offer a remote display or mobile app for real-time consumption monitoring.
This is the legal-metrology framework AMPECO engaged with directly when it joined the National Council on Weights and Measures in December.
What this means for operators:
- Legacy DC chargers under the 5.0% tolerance need “Class 5” marking now. The 2034 end of grandfathering gives a clear date to plan replacement or upgrade cycles around.
- Three-point AC verification adds steps to commissioning and inspection. Build them into field service schedules.
- Outage data retention (15 minutes, or eight hours for long-term parking) depends on hardware and firmware. Confirm support with your suppliers before your next procurement round.
- Section 3.41 is still tentative. Operators billing tenants or business park users on measured consumption should still prepare a remote display or app option.
California treats commercial EV charging as a regulated fuel sale
California now places commercial EV charging firmly under the legal regime for regulated fuel sales. Any charger billing per kWh is treated like a fuel pump, not a digital service. Type approval under the California Type Evaluation Program (CTEP) is a prerequisite. NTEP approval is accepted only where California-specific requirements are fully met.
The biggest operational change is commissioning. A charger may only enter commercial service after a Registered Service Agency (RSA) places it into service. Installation alone is not enough. Only a limited number of RSAs are authorized for EV charging, which creates a real bottleneck for rollout schedules.
This lands alongside the 97% uptime mandate for commercial charging that took effect on January 1, which we flagged in December’s key dates.
What this means for operators:
- “Operate first, regularize later” is no longer viable. Chargers billing per kWh need type approval and RSA commissioning before they earn revenue.
- Confirm CTEP approval before you procure hardware for California. NTEP alone is not enough unless it meets every California-specific requirement.
- Book RSAs early. With few authorized for EV charging, commissioning capacity may become the constraint on your go-live dates.
Funding and incentive updates
Netherlands introduces ERE certificates for home charging
The Netherlands introduced a polluter-pays mechanism that pays charging point owners directly. As of January 2026, the Dutch Emissions Authority (NEa) operationalized the ERE (Emissiereductie Eenheden) certificate system. Oil companies must buy certificates to offset their emissions, and that money flows to charging infrastructure owners.
Market rates reach €0.10 per kWh charged, or roughly €200-500 a year for residential owners. Payment goes to the electricity contract holder registered in the Central Connection Register. To qualify, the charging point needs an integrated MID-certified meter, and kWh must be reported annually through an authorized booking service provider. The regulation awaits approval from the Dutch First Chamber.
What this means for operators:
- ERE shows how revenue can come from beyond energy margins as markets move past subsidy models.
- Only chargers with integrated MID-certified meters qualify. That splits the market between compliant and legacy hardware, and it raises the stakes on the MID modernization agreed in November.
- Operators managing residential chargers can make the annual kWh reporting simpler for their customers through authorized booking service providers.
- Certificate prices move with oil company compliance costs and supply. Treat ERE income as variable in business cases.
California opens third NEVI Formula round for corridor fast charging
In December 2025, the California Energy Commission opened GFO-25-602, its third NEVI Formula Program funding round. It focuses on public DC fast charging along major transport corridors for light-duty EV travel. Applications require full alignment with NEVI rules, utility coordination, ADA accessibility, and environmental approvals.
The NEVI Formula freeze was blocked by the June 2025 injunction we covered in December, and California is putting that money to work. Applications are due March 25, 2026.
California commits $69.5 million to NEVI MDHD charging
The California Energy Commission’s GFO-25-604 solicitation provides $69.5 million in NEVI Formula funding for high-capacity medium- and heavy-duty charging along Alternative Fuel Corridors in Northern and Central California. Projects can receive up to $8 million, covering 80% of costs.
The technical bar is high: at least 3 MW station capacity, 150 kW continuous port output, and full OCPP 2.0.1 and ISO 15118 interoperability. Projects must guarantee 97% uptime, comply with the Build America, Buy America Act, and use EVITP-certified labor. The Charging Management System must support OCPI 2.2.1, allow hardware-agnostic network switching, and offer open-access payment without membership requirements. The application period closes April 22, 2026.
What this means for operators:
- The CMS requirements rule out closed, proprietary platforms. Confirm your software supports OCPI 2.2.1, network switching, and open-access payment before you apply.
- The 80% cost share makes this one of the stronger MDHD funding opportunities in the US right now. Price the compliance costs (BABA, EVITP labor, uptime guarantees) into the project from the start.
- With about three months between opening and close, applicants should line up utility coordination and hardware specs early.
AMPECO leadership and advocacy
AMPECO joins 50+ businesses at the European Parliament for #TakeChargeEU
On January 20, AMPECO joined more than 50 companies from across the e-mobility ecosystem for a day of meetings at the European Parliament in Strasbourg during Plenary week.
The Take Charge EU campaign is built around a €175 billion investment commitment to the European e-mobility ecosystem by 2030, spanning vehicles, batteries, and charging infrastructure. The campaign compares the scale of this investment to the build-out of the North Sea oil and gas industry. It also puts numbers on the jobs at stake. The battery sector employs 60,000 people today and could reach 300,000. The charging sector supports 58,000 jobs, with 191,000 potential new roles.
The market is moving in the right direction. BEV sales grew 30% year over year in 2025, reaching a 17% market share. Public charging points across the EU-27 now exceed 1 million, growing at a 36% CAGR.
The core message AMPECO and its partners brought to Strasbourg was about regulatory uncertainty. It is the main risk to this momentum. Our presentations called on MEPs to stand firm on the 2035 zero-emission goal. Weakening it risks investment moving elsewhere and a fragmented European strategy. The aim is to keep electrification at the center of the EU’s plan for long-term competitiveness.
This follows the EU Automotive Package we covered in December, which reduced the 2035 target to a 90% CO₂ reduction. For operators, the outcome shapes utilization forecasts and investment timing for the next decade.
AMPECO recognized as a CALeVIP-ready Charging Management System
In January 2026, the California Energy Commission officially recognized AMPECO as a CALeVIP-ready Charging Management System. AMPECO is the only pure software provider with this distinction on California’s approved registry.
Operators using AMPECO get automated compliance reporting, native OCPP 2.0.1 support, and 15-minute interval data collection. They keep full control over hardware selection, brand identity, customer relationships, and data ownership.
AMPECO is also recognized as a network provider in New York’s NYSERDA Charge Ready 2.0 program, and EPRI lists it as an approved provider for more than 20 utility programs nationwide, including Duke Energy, Xcel Energy, and SMUD. Together, these programs give operators on the platform access to nearly $2 billion in public incentives.
Key dates and deadlines
- March 25, 2026: California NEVI Formula Solicitation 3 (GFO-25-602) applications due
- April 14, 2026: DATEX II reporting deadline
- April 22, 2026: California NEVI MDHD (GFO-25-604) application period closes
- June 1, 2026: MCS standard expected formal publication
- January 1, 2027: ISO 15118-20 compliance for new public and private chargers
Need help with NIS2 readiness, California type approval, or NEVI applications?
Schedule a consultation with AMPECO’s regulatory intelligence team →
