September brought a convergence of data access, market design, and infrastructure standardisation developments that will shape EV charging operations well into 2027. The EU Data Act entered full application on September 12, establishing new rules for how vehicle data generated by connected products flows to operators and third parties — sitting alongside the RED III battery data provisions we’ve been tracking throughout the year. In Germany, three major developments landed simultaneously: a federal truck charging tender that could set the precedent for open market models across Europe, the publication of the national DATEX II data profile, and draft energy tax reforms that eliminate V2G double taxation and simplify CPO reporting obligations.
Meanwhile, the EU published advisory accessibility guidelines with concrete design parameters for charging infrastructure, the Measuring Instruments Directive amendments moved toward trilogue with both Council and Parliament aligned, and Mexico marked one year since adopting its first nationwide EV charging framework.
Here’s what changed in September and what it means for your operations.
Regulatory developments
EU Data Act enters full application with vehicle data guidelines published
The EU Data Act (Regulation 2023/2854) entered into force on January 11, 2024 and applies in full from September 12, 2025. The Commission’s guidance on vehicle data, published the same day, clarifies that the regulation applies directly to OEMs, covering only vehicle-related services essential for the operation of a connected vehicle — remote control functions and cloud-based services storing driver settings — but not repair, maintenance, or derived insights such as charging session information.
OEMs must provide users and third parties with access to raw and pre-processed data along with the metadata needed for interpretation. This covers sensor outputs and simple calculations such as vehicle speed, battery level, odometer readings, and engine status, but excludes inferred or analytical data. Access must be non-discriminatory, of equal quality, and free from undue barriers, whether granted directly via the vehicle or indirectly through back-end systems.
This framework sits alongside RED III Article 20a(3), which imposes additional obligations on OEMs to provide specific EV battery and vehicle data in real time, free of charge, and on equal terms — the provision we first covered in January and tracked through February’s transposition timeline.
What this means for operators:
- The Data Act and RED III create complementary but distinct data access rights — CPOs should understand what data is available under each regulation and how to access it
- Raw vehicle data such as battery level and vehicle speed becomes accessible on non-discriminatory terms, enabling more sophisticated smart charging algorithms and energy management
- The exclusion of charging session information from Data Act scope means CPOs cannot use this regulation to access competitors’ session data — it applies to vehicle-generated data only
- Operators planning V2G or advanced smart charging services should begin engaging with OEMs on data access pathways, as these services depend on the real-time data streams both regulations mandate
EU publishes accessibility guidelines for EV charging infrastructure
The EU published new advisory guidelines providing public authorities with minimum accessibility requirements for use in tenders and funding schemes. While not yet legally binding, the guidelines set concrete design parameters — accessible parking spaces should measure 5 metres by 3.5 metres, with operable elements positioned within a height range of 750 to 1,200 millimetres.
The scope is currently limited to persons legally entitled to drive, but the guidelines explicitly envision future extension to passengers and non-drivers. Significantly, the EU has formally asked CEN-CENELEC to draft a European Standard on Accessible EV Charging, a process expected to take two to three years. This will deliver a consistent, legally recognised framework replacing the current patchwork of national definitions — moving the industry toward a single benchmark for full accessibility.
What this means for operators:
- Although advisory today, these guidelines will increasingly appear as requirements in public tenders and funding schemes — operators bidding for public contracts should design to these specifications now
- The CEN-CENELEC standardisation process will eventually produce binding requirements, so early compliance creates competitive advantage rather than just regulatory readiness
- The future extension beyond drivers to passengers and non-drivers signals that accessibility requirements will broaden — operators should consider universal design principles in current infrastructure planning
Measuring Instruments Directive amendments advance toward trilogue
The Commission’s proposed MID amendments, presented in November 2024 to modernise the legal framework for measuring instruments, took significant steps forward in September. The Council adopted its position on September 24, followed by the Parliament’s IMCO Committee vote on September 25. With both institutions now aligned on initial positions, interinstitutional negotiations begin in early October, with several meetings scheduled before mid-November. Both institutions have expressed commitment to swift adoption, suggesting a final text could be agreed before end of 2025.
What this means for operators:
- The MID modernisation will determine how metering requirements apply to EV chargers — the outcome affects hardware certification, billing accuracy standards, and compliance costs
- The pace of the trilogue process suggests operators should prepare for new metering obligations potentially taking effect in 2026-2027
- CPOs should monitor trilogue outcomes closely, as the final text will define whether existing metering approaches remain compliant or require upgrading
Germany’s truck charging tender sparks debate over open market models
Germany’s federal tender for a nationwide heavy-duty EV charging network has brought a fundamental market design question to the forefront of the sector. The tender mandates a pass-through model requiring network operators to accept third-party electricity providers, making the infrastructure fee — rather than electricity sales — the primary revenue source.
The model is welcomed by the VDA (German Association of the Automotive Industry), which sees it as a way to lower charging costs and provide planning certainty for logistics operators. However, major CPOs including EnBW, Aral, and Shell have pushed back strongly, arguing that separating infrastructure from energy sales jeopardises long-term investment profitability, particularly in less-trafficked rural locations included in the mandate. Some have reportedly threatened withdrawal from the tender.
The German government, through the National Centre for Charging Infrastructure and the Federal Ministry for Digital and Transport, has been clear about the policy rationale. The tender is designed to create a needs-based network filling critical gaps along the autobahn — starting with 130 locations and growing to 350 by 2030 — while ensuring a non-discriminatory, competitive market that accelerates electric truck adoption.
What this means for operators:
- The outcome of this tender will set a precedent for HDV charging market design across the EU — if the pass-through model succeeds in Germany, expect other Member States to adopt similar approaches
- CPOs whose business models depend on integrated energy-and-infrastructure revenue should assess their exposure to pass-through regulation and develop contingency strategies
- The tension between government objectives (open competition, lower fleet costs) and CPO concerns (investment viability, rural coverage) is a structural challenge that will recur in other markets
- Operators positioned to operate profitably under infrastructure-fee-only models will have a significant strategic advantage if this approach becomes the European norm
Germany publishes DATEX II data profile and advances energy tax reform
Two additional German developments merit attention. Germany published the DATEX II data profile v01-00-00, providing the national reference for AFIR-compliant data provision. Available on the Mobilithek platform with GitHub repository support, the profile sets out the precise data model for transparent, interoperable information on charging station location, status, availability, and pricing across the EU. This moves Germany from the DATEX II standard we covered at the EU level to concrete national implementation that CPOs operating in Germany must now align with.
Separately, the draft Third Law Amending the Energy and Electricity Tax Acts, published July 23, introduces substantial e-mobility clarifications. A new legal fiction attributes electricity consumed at charging points to the CPO regardless of contractual arrangements with e-mobility service providers or roaming partners, preventing automatic supplier classification and simplifying reporting. Bidirectional charging is explicitly recognised as tax neutral — EV drivers do not become suppliers when re-feeding electricity to the grid, and stored electricity is taxed only once, eliminating double taxation risks. The draft also secures tax advantages for PV-powered charging and shifts exemptions to the site level.
What this means for operators:
- CPOs operating in Germany should begin aligning data systems with the published DATEX II profile now, ahead of the April 2026 compliance deadline
- The tax reforms are strongly positive for V2G deployment — the elimination of double taxation and supplier reclassification risk removes two of the most cited barriers to bidirectional charging business cases in Germany
- The site-level exemption shift simplifies compliance for operators managing multiple charging assets at a single location
Mexico marks one year of national EV charging regulation
Mexico’s first nationwide EV charging framework, which entered into force on September 10, 2024 through CRE’s Acuerdo A/108/2024, has now completed its first year. The framework governs grid integration, anchors technical requirements in NOM-001-SEDE-2012, and requires operators to hold separate supply contracts and provide transparent consumer information.
The regulations mandate a national Electromobility Platform by September 10, 2026. On March 13, 2025, the regulator unveiled ElectroCRE — a registry and mapping tool with pre-registration, equipment certificate validation, and per-charger unique IDs. Until the platform is fully live, operators must publish required data on their own websites or charger screens. For operators and CPMS providers, the obligation is clear: maintain grid-code evidence and consumer disclosures, and align asset inventories with ElectroCRE requirements to ensure readiness for definitive registration.
Funding and incentive updates
AMPECO listed as participating network provider in CALSTART’s Communities in Charge Wave 4
Communities in Charge, funded by the California Energy Commission and administered by CALSTART, launched Wave 4 in August 2025 with a budget of $56.5 million. Open until January 9, 2026, the programme focuses exclusively on multi-family housing and related sites, providing $8,500 per Level 2 charging port with higher support for Tribal projects. All installations must be shared, networked, and compliant with safety and accessibility standards. At least half of available funds are reserved for disadvantaged, low-income, and Tribal communities.
AMPECO has been officially listed as a Participating Network Provider, confirming that the platform meets Wave 4’s compliance standards and can be used by applicants seeking funding.
AMPECO leadership and advocacy
Take Charge campaign defends EU’s 2035 EV target
AMPECO’s CEO joined over 150 executives from across the EV, charging, and clean-tech sectors in signing an open letter to European Commission President Ursula von der Leyen. The “Take Charge” campaign, coordinated by E-Mobility Europe and ChargeUp Europe, urged the EU to maintain its 100% CO₂ reduction target for new cars and vans by 2035 — serving as a direct counter-message to automaker lobbying efforts to delay or weaken the deadline.
The letter argued that any hesitation would erode investor confidence, slow EV market progress, and threaten the hundreds of billions of euros already invested in European charging and supply chains. It called on the EU to back the 2035 deadline with robust industrial policy, consistent consumer incentives, and accelerated charging grid investment. AMPECO’s participation ensured that the perspective of charging infrastructure and software providers was represented alongside vehicle manufacturers and fleet operators in this critical policy conversation.
Key dates and deadlines
- January 9, 2026: CALSTART Communities in Charge Wave 4 application deadline
- January 1, 2026: California 97% uptime mandate takes effect
- January 8, 2026: ISO 15118-2 compliance required for newly installed public chargers
- April 14, 2026: DATEX II reporting deadline (Germany profile now available)
- September 10, 2026: Mexico ElectroCRE platform mandatory registration deadline
- January 1, 2027: ISO 15118-20 compliance required for new public and private chargers
Need help navigating DATEX II compliance, pass-through model implications, or market entry strategies?
Schedule a consultation with AMPECO’s regulatory intelligence team →
Discover the most comprehensive collection of EV charging grants, incentives, tax credits, and rebate programs — exclusively curated by AMPECO’s policy experts.
Access the incentive tracker →
