With the January 1, 2027, ISO 15118 deadline now three months out, the regulatory conversation has shifted from what the rules require to how compliance actually works.
The Commission has convened a working group to answer exactly that, while the industry is still split on whether AFIR leaves room for Autocharge at new charge points. The Netherlands has locked in its smart foundation deadline, and the UK is drawing the boundaries of its new load control licence.
AMPECO was active on both sides of the Atlantic this month: submitting formal feedback to the AFIR review, joining the Commission’s ISO 15118-20 working group, and putting forward four amendments to the US national standard for EV charger metering and billing.
This month’s funding update covers Round 7 of New South Wales’ EV Fleets Incentive, now open for bids.
Here’s what changed in September and what it means for your operations.
Regulatory developments
Plug & Charge vs. Autocharge: an open question under AFIR
Delegated Regulation (EU) 2025/656 requires public charge points installed or renovated from January 1, 2027, that offer automatic authentication, such as Plug & Charge, to comply with ISO 15118-2 and ISO 15118-20. What it doesn’t settle is where that leaves Autocharge, the vehicle-ID-based method already running across much of the existing network.
Two readings are circulating in the industry. One holds that the Regulation effectively rules out anything other than ISO 15118-based Plug & Charge at new or renovated points. The other holds that it only requires ISO 15118 support where automatic authentication is offered, without barring Autocharge alongside it.
The practical stakes are significant. Plug & Charge readiness across vehicles and certificate infrastructure isn’t there yet, and restricting Autocharge to legacy sites would leave CPOs with an uneven experience across their own networks. Running both on one charge point raises its own problem: two “plug in and it works” experiences with different enrollment, failure modes, and providers. AMPECO is following the question through the STF working group below.
STF working group to clarify ISO 15118-20 compliance
On September 2, DG MOVE convened an ad hoc working group under the Sustainable Transport Forum to produce Q&A guidance on how compliance with ISO 15118-20 under Delegated Regulation 2025/656 is demonstrated, verified, and enforced. It follows industry concerns raised over the summer about compliance pathways while the standard’s conformance test parts are still being finalized. The ISO 15118-20 amendment published in July settled the standard’s content; this group settles how compliance with it is shown.
The work covers two blocks: compliance demonstration and enforcement, including whether manufacturer self-declarations will suffice, and the scope of application of the standard’s parts. Working rounds run through mid-October, followed by Member State consultation, with the final Q&A due for endorsement at the STF Plenary on November 25. That leaves just over a month between the guidance and the deadline it clarifies.
NAPCORE’s second AFIR data workshop
On September 25, NAPCORE and the European Commission held their second workshop on AFIR data, with contributions from the EVRoaming Foundation, EAFO, POLIS, and several OEM and end-user operators. The agenda covered the pilot status of the Common European Access Point, OCPI-CEN standardization progress, and how charging data is created at the source by hardware manufacturers. Google, Metergram, and ACE Auto Club Europa presented how National Access Point data is reused downstream.
The Common European Access Point is the EU-level answer to the fragmentation visible in national regimes such as Portugal’s and the single reporting point AMPECO called for in its AFIR submission below.
Smart foundation mandatory in the Netherlands from February 1, 2027
ElaadNL’s NTA 8042 inspection team, comprising CPOs, grid operators, and ElaadNL, has confirmed February 1, 2027, as the date on which the NTA 8042-compliant “smart foundation” becomes mandatory for public charging infrastructure, aligned with version 4.0 of the charging station connection requirements. The original deadline of five months after publication proved too optimistic.
The new date is a final deadline, not a starting point. Once the first foundations are certified, the sector is encouraged to adopt them early and build experience with placement and grid connection. Amendments to NTA 8042 are now with NEN for committee approval, after which certification can follow quickly.
UK proposes exemptions from the load control license
On August 7, DESNZ published a notice proposing three class exemptions from the forthcoming load control licence, which will apply to Load Controllers and Flexibility Service Providers operating EV smart charge points, heating, and battery storage under the Smart Secure Electricity Systems Program. The exemptions would cover appliances outside the regime’s scope (Class A), flexibility services for larger non-domestic consumers only (Class B), and, newly proposed, load control carried out solely for the consumer’s benefit rather than for grid operators or traders (Class C).
The notice also sought views on small and micro businesses, from a load-based exemption (with illustrative thresholds of 1 to 35 MW) to none at all. The consultation closed on September 7, and the Secretary of State’s decision will set which CPOs and flexibility providers fall inside the licensing regime. It runs alongside the large load controller provisions in the Cyber Security and Resilience Bill we covered in May, which together define how UK regulation reaches smart charging platforms.
Funding and incentive updates
NSW opens Round 7 of the EV Fleets Incentive
New South Wales has opened Round 7 of its EV Fleets Incentive competitive bid stream, co-funding the cost gap between BEVs and ICE or hybrid equivalents for fleets of 21 or more vehicles, with an optional smart charging contribution. The program was extended to medium trucks under the updated EV Strategy in April.
Charging support moves to capped maximums: up to AUD 2,000 per commercial AC port, AUD 1,200 per home charger, and AUD 8,000 per DC port. Charging-as-a-Service is now eligible, with third parties able to procure and install chargers on the grantee’s behalf.
Delivery rules are tighter. Purchase orders must be raised by June 25, 2027, or funding is forfeited, and applicants with a history of under-delivery can be excluded. A 50% advance payment option and an early-registration bonus partly offset the timeline. Bidding opened on September 14, with results expected on December 18.
AMPECO leadership and advocacy
AMPECO submits formal feedback to the EU’s AFIR review
AMPECO submitted formal feedback to the European Commission’s public consultation on the review of AFIR, which ran until August 3, bringing the perspective of the software layer behind Europe’s charging infrastructure into the discussion.
AMPECO now enables more than 200,000 charging ports across all 27 EU Member States. That gives us a particular view of regulation. When requirements differ from one country to another, the impact isn’t limited to a single charge point operator. The complexity is repeated across every market and every CPO that a charging management platform supports.
Our submission focused on one central principle: Europe needs greater regulatory clarity and harmonization, not more fragmentation. Among our recommendations:
- Improve AFIR rather than reopen it wholesale. The existing framework has already created much-needed certainty around infrastructure deployment, payments, and price transparency. We support targeted amendments, with greater emphasis on effective national competition oversight rather than blanket pricing mandates.
- Create a single EU-level reporting point. Today, AFIR’s Article 25 reporting requirements are implemented through 27 national interfaces, with differences in how standards such as OCPI and DATEX II are applied. For software providers operating across Europe, that can mean maintaining dozens of integrations for essentially the same information. A single reporting point and technical specification would significantly reduce unnecessary complexity.
- Take a pragmatic approach to interoperability. We support regulatory recognition of OCPP 2.0.1, and later OCPP 2.1, provided the industry has sufficient notice and existing charging hardware is not forced into costly retrofits. We also cautioned against moving too quickly on ISO 15118-20 while key elements, including PKI governance, conformity assessment, and corresponding vehicle-side requirements, remain unresolved.
The broader message is simple: regulation should make it easier to build and operate charging infrastructure across Europe, not require the same technical work to be repeated 27 different ways.
Read the full AMPECO submission →
AMPECO joins the Commission’s ISO 15118-20 working group
AMPECO has been invited to join the European Commission’s ad hoc working group on the implementation of ISO 15118-20, described above. Delegated Regulation (EU) 2025/656 makes EN ISO 15118-20:2022 mandatory for new and renovated public and private recharging points from January 1, 2027, but the conformance test parts that would give the standard an objective pass/fail basis are only partially in place. Without a settled method of demonstration, the same implementation can be judged differently across Member States, and equipment can be formally compliant with the protocol yet still fail to interoperate in the field.
AMPECO will submit questions to both thematic blocks and join the answering teams. Our focus is on what documentation actually satisfies an enforcement authority, where the obligation sits between manufacturer, operator, and software provider, what role Autocharge and other services play, and how compliance is assessed for requirements whose test parts are not yet finalized.
AMPECO proposes four amendments to the US EV charging metering standard
In August, AMPECO filed a formal proposal with the National Conference on Weights and Measures (NCWM) to update the US standard for EV charging systems as part of the ongoing review cycle. The filing follows AMPECO joining NCWM as an Associate Member in December and the Handbook 44 changes we covered in January.
The current rules were written for fuel-pump-style dispensers with built-in screens, which leaves much of today’s hardware in a gray area. Our first ask is straightforward: let chargers without a screen meet the price display requirement another way, either through an attached payment terminal or through a QR code that opens the operator’s pricing page on the driver’s phone, with no app or login required.
The other three amendments tackle billing questions the standard doesn’t yet answer. One resolves a mismatch between the required metering precision and what older OCPP 1.6 systems report (previously addressed by an Open Charge Alliance workaround) by clarifying which record evaluators should check. Another covers cases where a driver charges using a third-party card or app that adds its own markup: the charger should show the operator’s price alongside a clear notice that the final bill may differ. The last sets out that idle and parking fees must be disclosed before a session starts and itemized on the receipt.
Looking ahead
Most of what’s on the table this month is clarification rather than new obligation: how compliance is proven, who the rules apply to, which reading of the text holds. That work runs right up to the deadlines themselves, with the ISO 15118-20 Q&A due in late November for a January start.
For CPOs and eMSPs, the practical move is to plan for the stricter reading now and adjust if the guidance lands more generously.
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