Plug & Charge is often presented as an EU obligation. The text is more precise than that. The AFIR does not name ISO 15118 in its main articles, and it does not oblige anyone to offer Plug & Charge. What it does is set the technical standards that new and renovated public points must meet, on two dates. This article lays out those dates, what they cover, and what to check in your estate.
What the regulation says, and what it does not
The AFIR is a regulation: it is directly applicable in every Member State and has applied since 13 April 2024. No national transposition is needed.
Its article 5 covers payment, price transparency, connectivity and smart charging. Public points must be digitally connected, meaning they can be monitored and controlled remotely, since 14 October 2024. Public points built after 13 April 2024, or renovated after 14 October 2024, must be capable of smart recharging. Article 5 does not mention ISO 15118, and neither the AFIR nor the delegated act names OCPP.
The communication standards between vehicle and charge point sit in annex II. That annex was amended by delegated regulation 2025/656, which applies from 8 January 2026.
The two dates that matter
The delegated act sets requirements by installation date.
The text says "installed or renovated". It does not require a retrofit of the existing estate, and the recitals provide an exemption for existing points that use basic PWM communication. If you read a summary saying that all stations must be upgraded by a given date, check it against the delegated act.
Why -20 and not only -2
The recitals explain the choice. ISO 15118-2 lacks advanced smart charging, bidirectional charging and multi-contract support. These functions are in ISO 15118-20. That is why the 2027 requirement moves to -20 while keeping -2 alongside it for Plug & Charge.
For a CPO, the practical consequence is on procurement. A charger installed from 1 January 2027 must be supplied with the -20 capability. A charger installed in 2026 before that date must meet the earlier set. Ask for the version in writing, per model.
Plug & Charge stays optional, and the driver keeps a choice
Two points are easy to miss.
First, the recitals leave the operator free to offer Plug & Charge or not, in line with the options the standards themselves contain. The obligation is on the standard supported, not on the commercial offer.
Second, article 5(2) protects the driver: where automatic authentication is offered, the user keeps the right not to use it and to pay ad hoc, or through another contract. A Plug & Charge rollout does not replace the card reader or contactless terminal required for ad hoc payment. The two coexist.
What it means for your CSMS
ISO 15118 is the vehicle-to-charge-point link. Your CSMS talks to the charge point over another protocol, and the AFIR does not impose which one. In practice most operators use OCPP, and the Open Charge Alliance's 2.0.1 certification includes an ISO 15118 support profile, while OCPP 2.1 adds support for ISO 15118-20 with bidirectional power transfer. OCPP 1.6 and 2.0.1 are not compatible with each other, so the protocol version of each model in your estate decides how it will carry these functions.
The questions to put to your backend and your hardware suppliers:
What to do this week
Build an inventory of your public points with three columns: installation or renovation date, OCPP version, ISO 15118 parts supported. Mark the points that will be installed or renovated after 1 January 2027, because those need -20. Then add the ISO 15118 version as a written requirement in your next purchase specification.
GFO Omni is a CSMS that supervises charge points over OCPP 1.6, 2.0.1 and 2.1, which makes the protocol version of each charger visible in one place.