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AFIR, smart charging and energy prices: what charge point operators must do

4 min read
  • afir
  • smart charging
  • energy prices
  • dynamic pricing
  • iso 15118
  • ocpp

AFIR does not tell you how to buy electricity. It tells you what your charge points must be able to do, and what drivers must be shown before they plug in. Energy prices, for their part, are becoming more dynamic. The operators who benefit are those whose stations can receive instructions and whose price display is accurate. This article separates what the rules require from what remains your commercial choice.

What AFIR requires for smart charging

Regulation (EU) 2023/1804 (AFIR) applies directly in all Member States since 13 April 2024. It contains no national transposition step.

Three obligations matter for energy management:

  • Since 14 October 2024, public charge points must be digitally connected: able to send and receive information in real time, to communicate in both directions with the grid and the vehicle, and to be monitored and controlled remotely (art. 5(7)).
  • Public points built after 13 April 2024, or renovated after 14 October 2024, must be capable of smart recharging (art. 5(8)).
  • Smart recharging means that the charging intensity can be adjusted in real time, based on information received by electronic communication (art. 2).
  • The regulation sets a capability, not a tariff strategy. It does not oblige you to follow wholesale prices.

    ISO 15118 and the protocol question

    AFIR does not name OCPP. The vehicle-to-station standards come from Delegated Regulation (EU) 2025/656, which replaces point 2.1 of Annex II.

  • Public AC and DC points installed or renovated from 8 January 2026 must meet at least EN ISO 15118-1 to -5.
  • From 1 January 2027, they must meet at least EN ISO 15118-20:2022. A point that offers Plug and Charge must meet both -2 and -20.
  • The text covers points installed or renovated at those dates. It does not require retrofitting the existing estate.
  • In practice, a CSMS still needs a back-end protocol to send limits to stations. OCPP 2.1 extends 2.0.1 with improved smart charging tools and support for ISO 15118-20. OCPP 1.6 and 2.0.1 are not compatible with each other, so a mixed estate means managing both.

    Where energy prices enter the picture

    Three texts shape the price side.

    Dynamic price contracts. Under Directive (EU) 2019/944, art. 11, a final customer with a smart meter can ask for a dynamic price contract from any supplier with more than 200 000 customers. Check what your supplier offers for your connection.

    Grid data. The renewable energy directive (RED III, Directive (EU) 2023/2413) requires network operators to publish the renewable share and greenhouse gas content of electricity by zone, at steps of one hour at most, in a form readable by charge points (art. 20a).

    Renewable credits. Under the same directive (art. 25(4) of Directive 2018/2001 as amended), operators who supply renewable electricity to vehicles through public points receive credits that they can sell to fuel suppliers. Member States may extend this to private points.

    None of these texts obliges you to shift load. They make it easier to do so, and to prove the renewable share of what you deliver.

    What AFIR asks on the price shown to drivers

    Price volatility on your side must not turn into opacity on the driver side.

  • Ad hoc prices must be reasonable, easily comparable, transparent and non-discriminatory (art. 5(3)).
  • For points of 50 kW or more, the ad hoc price is expressed per kWh, with possible occupation fees per minute, and displayed before the session starts (art. 5(4)).
  • The ad hoc price is also part of the dynamic data you must publish through the national access point (art. 20(2)).
  • If your energy cost varies during the day, your display and your published data must still be coherent. That is a data quality question before it is a pricing question.

    What the rules do not say

  • No availability or uptime threshold is set in the operative text. Operational status and availability are data to publish (art. 20(2)).
  • No protocol is imposed by name.
  • No obligation to optimise against market prices exists. That is your decision.
  • Beware of articles that claim otherwise.

    What to check this week

    1. List your public points and note, for each, the OCPP version and whether it accepts charging limits from your CSMS.

    2. Confirm which points were built or renovated after the dates above, since they fall under the smart recharging obligation.

    3. Ask your electricity supplier whether a dynamic price contract is available for your connection.

    4. Check that the ad hoc price shown on the station matches the price published in your open data feed.

    GFO Omni is a CSMS supporting OCPP 1.6, 2.0.1 and 2.1 that supervises charge points, which is the layer where these limits and prices are applied.

    Sources

  • Regulation (EU) 2023/1804 (AFIR)
  • Delegated Regulation (EU) 2025/656
  • Directive (EU) 2023/2413 (RED III)
  • Directive (EU) 2019/944
  • Open Charge Alliance, OCPP 2.1
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