At Hubject, we welcome the review of Regulation (EU) 2023/1804 on the deployment of alternative fuels infrastructure (AFIR) and acknowledge its significant potential to drive substantial improvements in interoperability and support the growth of the eMobility sector. In response to the measures outlined in the Call for Evidence for the review of AFIR, we propose several key considerations to ensure the regulation’s effectiveness and clarity:
1) Enhancing user experience through fair and transparent prices:
- Enhance clarity on AFIR pricing provisions: AFIR has created a solid foundation for price transparency and diverse payment options. The European Commission should preserve this framework and ensure its consistent enforcement across Member States. In this regard, it would be beneficial if the EU Commission could provide further clarification regarding the pricing provisions in Article 5 of the AFIR. While the regulation requires prices for publicly accessible charging points to be "reasonable, easily and clearly comparable, transparent, and non-discriminatory," the lack of specific metrics or definitions creates ambiguity and inconsistent implementation across Member States and related companies. We suggest including non-binding EU guidelines or further clarifications in a Q&A format to help national authorities and industry stakeholders assess permissible price differences consistently. At the same time, we believe it is crucial that the revised AFIR maintains a balanced approach to pricing and avoids overly prescriptive legislative provisions, which could distort the market, hinder innovation, and reduce investment. Moreover, it is important to note that key pricing aspects are already covered by complementary EU laws, such as consumer rights and competition rules (e.g., Directive (EU) 2019/2161), which should be considered in complementarity with AFIR to prevent market distortions.
- Clarifying the role of eRoaming Platforms: EV charging prices must be understood as the outcome of a complex and interdependent value chain-one that supports accessibility, reliability, and fair competition across Europe’s expanding charging infrastructure. Unlike charging at home or the workplace, public EV charging involves a multifaceted ecosystem of actors and systems that extend far beyond simply supplying electricity. We believe it is essential to emphasize that eRoaming Platforms act solely as intermediaries, facilitating secure and standardized communication between Charge Point Operators and eMobility Service Providers and do not participate in price setting. eRoaming platforms like Hubject serve as centralized hubs, simplifying the operational process by enabling multiple parties to connect through a single interface, thereby enhancing scalability and ease of use. By streamlining these interactions and ensuring seamless interoperability, eRoaming platforms deliver significant value by reducing complexity, improving efficiency, and driving growth in the eMobility field. Their role is to provide the technical infrastructure that supports transparency and interoperability, ensuring that pricing decisions remain fully within the control of market actors. While roaming fees have at times been identified as a factor driving charging prices, its actual cost contribution is minimal compared to the broader infrastructure and operational expenses within the e-mobility ecosystem. In the complex and fragmented value chain that determines the pricing structure, eRoaming Platforms add standardized fees for authentication, data exchange, clearing, and settlement, which amount to around 1–2% of the total charging cost.
- Digital-First price transparency: We strongly support the principle of digital-first transparency, which is vital for improving the user experience. While the regulation requires users to have access to relevant price information before charging, this information is not always available across all interfaces- both physical and digital. To address this, we believe that pricing information should be easily accessible via multiple channels: mobile apps, charger screens, and, where feasible, in-vehicle systems. This would allow users to make informed decisions and compare options before initiating a charging session, ensuring that they are fully aware of the costs involved.
2) Driving seamless interoperability through technical standards and protocols:
The significant transformations in the eMobility and energy sectors-through smart and bidirectional charging, renewable energy integration, power grid decentralization-present both opportunities and challenges. We recommend that the Commission foster increased coordination and interoperability across industries to navigate these complex shifts and ensure the integration of eMobility into the broader energy system.
- Promote subscription-based models and eRoaming: To achieve the full interoperability envisioned in AFIR, we recommend that the revised regulation focuses on leveling the playing field between ad-hoc payments and subscription-based model. While the current focus of interoperability has primarily been on ad-hoc payments, we believe that interoperability should also extend to subscription models and eRoaming. Subscription models provide advanced features, such as dynamic pricing, smart charging, reservation systems, and the ability to manage multiple users under a single account, which are not possible with ad-hoc payment methods. Additionally, a key benefit would be the simplification of billing processes, and consolidated invoicing, which would significantly reduce administrative burdens and enhance user convenience. Furthermore, they enable eRoaming, facilitating seamless charging across different networks without the need for multiple contracts or apps. Based on AFIR Annex II, point 2.3, we recommend the Commission mandate interoperable communication standards (e.g., OCPI), to ensure a seamless, accessible, and user-friendly EV charging experience.
- Enabling timely and efficient ISO 15118-20 implementation: The implementation of ISO 15118-20 supports the development of value-added services such as smart and bidirectional charging, Plug&Charge, and wireless charging. These services are essential for optimizing the user experience and enhancing the efficiency of charging processes. In this context, it is crucial to implement the ISO 15118-20 standard starting with January 2027, in alignment with the AFIR Delegated Acts, to prevent any additional uncertainty or delays. We recommend that the Commission prioritize the implementation of ISO 15118-20 and specific use cases, as this is key for enabling seamless data exchange and interoperability between mobility and energy ecosystems. In addition, we recommend that the Commission provide clear guidance on how compliance will be demonstrated and verified in practice. This should include a focus on defining the specific use cases, testing, verification, and certification, as these processes are essential for ensuring that ISO 15118-20 is implemented correctly. While certain technical elements related to ISO 15118-20 implementation such as conformance and performance testing frameworks are still in development, Hubject is already addressing these gaps. Through our dedicated Hubject Testing Facility, we offer tests specifically designed for this standard. Our testing facility plays a crucial role in accelerating the industry's ability to meet ISO 15118-20 requirements and supports manufacturers in navigating the transition toward a fully mature ecosystem. In this way, we are helping to build a more robust and reliable foundation for the broader market. We fully support also the establishment of a European testing ecosystem that links regulatory authorities, standardization bodies, and testing facilities, enabling effective compliance with the regulation.
- Hubject’s contribution to a secure, interoperable EU PKI Ecosystem: We, at Hubject, are actively involved in the STF expert group on the implementation of the governance and architecture for the EU PKI ecosystem for eMobility, with Plug & Charge as the primary use case. For Plug&Charge, ISO 15118-20 ensures robust data encryption and secure communication, which are vital for protecting user data and ensuring trust in the system. As a neutral platform, Hubject is committed to facilitating interoperability across the entire eMobility ecosystem. We fully support the Commission’s focus on creating a trusted, secure, and interoperable PKI ecosystem, fully aligned with AFIR. We recommend the Commission consider accelerating the development timeline to ensure the timely implementation of Plug&Charge and smart charging solutions. In addition, AFIR lacks clarity on how to handle Plug&Charge based on ISO15118 and Autocharge (MAC address based) in parallel. According to the AFIR Delegated Acts, all publicly accessible recharging points for light- and heavy-duty vehicles installed or renovated after 1 January 2027 must offer automatic authentication and authorization services, such as Plug &Charge, in compliance with ISO 15118-2 and ISO15118-20. Existing publicly accessible charging points providing automatic authentication and authorization solutions other than Plug &Charge based on ISO 15118-2 and ISO 15118-20 may continue to do so until a full market transition is achieved. However, many industry stakeholders consider Autocharge is still possible for deployment after January 2027. Furthermore, we would like to point out that a Charge Point Operator (CPO) who is implementing both technologies and has both at the same time activated may create confusion for end customers, as the customer most likely expects the EV enabled Plug&Charge contract and not Autocharge. It is essential to clearly define when Plug&Charge is mandatory and when, or if, Autocharge remains acceptable.
- Establish coherent regulatory frameworks for ISO 15118-20 implementation: The successful implementation of ISO 15118-20 requires ecosystem-wide coordination-from charging infrastructure, OEMs, energy providers, and regulatory authorities. Under the AFIR Delegated Acts, OEMs are encouraged to integrate ISO 15118-20 into the design and manufacturing of new electric vehicles, with the possibility of updating existing models from ISO 15118-2 to ISO 15118-20 where technically feasible. Additionally, the Automotive Omnibus Art. 2. introduces an amendment to Article 5(4) of Regulation (EU) 2018/858, according to which the Commission is empowered to adopt delegated acts to set technical requirements for PEVs and OVC-HEVs, ensuring interoperability with charging infrastructure and grids, and supporting smart and bidirectional charging. Therefore, we recommend the Commission ensure consistency in regulatory frameworks for EVs and charging infrastructure to support ISO 15118-20 implementation, enabling demand-side flexibility and smart and bidirectional charging.
3) Accelerating the rollout of publicly accessible charging infrastructure:
- Publicly accessible charging infrastructure for light-duty vehicles: Member States have successfully met or even exceeded their targets for light-duty vehicles, demonstrating the effectiveness of the AFIR in driving infrastructure development. While the number of charging points is keeping pace with the sales of electric vehicles, the installed power capacity is growing at twice the rate. We recommend therefore that the European Commission maintain the current targets for light-duty vehicle charging infrastructure, as they have proven effective in accelerating the transition to electromobility and ensuring that infrastructure keeps pace with growing demand.
- Publicly accessible charging infrastructure for heavy-duty vehicles: The situation for heavy-duty vehicles presents different challenges. Achieving the CO₂ reduction targets for this segment requires a sustainable business model for investors to ensure the widespread adoption of charging infrastructure. To support this transition and facilitate market transformation, we recommend that the European Commission complement the targets outlined in Article 4 of the AFIR with an investment framework designed to attract capital. Such a framework would encourage proactive infrastructure development for heavy-duty vehicles and help ensure the availability of sufficient charging points to meet their specific needs.
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