The payment rules of the Alternative Fuels Infrastructure Regulation (AFIR) are in Article 5, and they do not apply the same way to every point. The date that matters most is 1 January 2027, when part of the existing fleet must meet a requirement that new points have met since April 2024. A CPO should know which of its points are concerned, and when.
What Article 5 requires
Operators must offer ad hoc charging, without a contract, on publicly accessible points. The method depends on the date of deployment and the power.
So the rule is not that every public point needs a terminal by a single date. A low-power point in a city centre, deployed before April 2024, is not concerned by the 2027 obligation. A 150 kW point on a corridor is.
Prices and user choice
Prices must be reasonable, easy to compare, transparent and non-discriminatory between users and between mobility service providers. Differences are allowed if proportionate and justified.
For points of 50 kW or more, the ad hoc price is set per kWh of electricity delivered, with a possible occupancy fee per minute. The price per kWh and the fee must be displayed before the session starts. Below 50 kW, price components are presented in a set order: price per kWh, per minute, per session, then others. These rules apply to all points deployed from 13 April 2024.
If you offer automatic authentication, for example Plug & Charge, the driver keeps the right to refuse it and to pay ad hoc or under another contract. ISO 15118 requirements for new or renovated points are set separately, in delegated regulation 2025/656. Mobility service providers must show session prices before the start and may not add extra charges for cross-border e-roaming.
Three implementation choices
AFIR does not choose the technical solution. In practice an operator has three levers:
1. Buy hardware with the terminal built in. The supply chain is simpler, but you depend on one manufacturer and on its updates.
2. Retrofit an external terminal on existing points. It reuses installed hardware but adds integration and test work, and you manage several suppliers.
3. Rely on a QR code where the rule allows it. This is valid only below 50 kW and does not cover the 2027 case.
For a mixed network, most of the effort is the integration, not the terminal itself.
What the back-end must handle
A card payment at the point must end up as a charging session in your system and as a payment you can reconcile. Check these points:
AFIR does not require a particular protocol for this, and OCPP does not appear in the text.
Who is responsible
If the operator does not own the point, the owner must provide a point with technical characteristics that allow the operator to comply. Settle this in the site contract before the 2027 date. The Commission must also review the payment means and the pricing mechanism before 31 December 2026, so the rules may change.
What to do this week
Export your public points with their power, location (TEN-T, safe parking area or other), deployment date and current payment method. Mark every point of 50 kW or more on a corridor that has only a QR code. GFO Omni is a CSMS supporting OCPP 1.6, 2.0.1 and 2.1 that supervises charging points.