1. The Regulation That Is Reshaping European Charging Procurement
The Alternative Fuels Infrastructure Regulation (AFIR), formally EU Regulation 2023/1804, is the most significant policy driver for EV charging infrastructure in Europe since the push began. Unlike voluntary standards or manufacturer roadmaps, AFIR creates binding legal requirements for public charging point deployment on the Trans-European Transport Network (TEN-T) core and comprehensive routes.
For CPOs planning deployments in Europe, AFIR is not background context. It is a procurement constraint that determines which hardware you can legally install and where.
The regulation entered into force in July 2023. The compliance deadlines are staggered, but the nearest ones are approaching fast. Understanding the timeline is essential for any procurement cycle that extends beyond the next 12 months.
2. The Core Timeline: What Happens？
By 2026: All new publicly accessible electric vehicle charging points installed on TEN-T core network corridors must support payment by card without requiring registration or a subscription. This is the first hard deadline and the first area where non-compliant hardware becomes a legal problem.
By 2027: All new publicly accessible rapid charging points (above 50kW) on TEN-T core network corridors must be powered at least 50% from renewable energy sources where technically feasible. This requirement affects not only the charger hardware but the energy sourcing arrangements for each deployment site.
By 2027: All new publicly accessible electric vehicle charging points on TEN-T comprehensive network routes must meet the same non-discriminatory payment and accessibility requirements as the core network.
Ongoing: All new charging points must support OCPP 2.0.1 or later protocol versions. This is the technical specification that intersects most directly with hardware procurement decisions. Chargers certified only to OCPP 1.6J will not meet this requirement for new installations on regulated corridors.
3. The TEN-T Corridor Map: Where the Rules Apply
The regulation applies specifically to charging infrastructure on the TEN-T network, which covers approximately 125,000 kilometers of roads across the EU. The core network includes major highways connecting capital cities and primary economic centers. The comprehensive network extends to secondary routes and regional connections.
For a CPO deploying on these corridors, the implications are binary: compliant hardware or non-compliant hardware. There is no gray area. National implementing authorities are tasked with enforcement, and non-compliant installations may face removal orders or operational restrictions.
The European Commission publishes an interactive map of the TEN-T network. Procurement teams should cross-reference their planned deployment sites against this map before specifying hardware. Sites outside the TEN-T network are not subject to AFIR requirements, though many member states are adopting parallel national standards that mirror the EU regulation.
4. OCPP 2.0.1: The Technical Requirement Behind the Regulation
The OCPP 2.0.1 mandate is the procurement trigger with the shortest timeline and the widest impact. Unlike payment or renewable energy requirements, which affect operational arrangements, the protocol requirement affects the hardware itself.
A charger that does not support OCPP 2.0.1 can not be certified for AFIR compliance. This is not a software update that can be applied later — it is a hardware and firmware capability determined at the point of manufacture.
As of 2026, only 68 charger models worldwide hold valid OCPP 2.0.1 certification. The limited supply pool means that CPOs planning large deployments must evaluate suppliers carefully and commit to certified products before the procurement window narrows further.
The intersection of OCPP 2.0.1 certification and AFIR compliance creates a self-reinforcing requirement: even if your deployment is not on a TEN-T corridor, choosing OCPP 2.0.1-certified hardware now protects you against future regulatory expansion and simplifies any later transition to compliant sites.
5. The Renewable Energy Provision: What It Means for Procurement
The 2027 requirement for 50% renewable power on rapid charging points above 50kW is often misunderstood as a hardware specification. It is not. It is an energy sourcing requirement.
The regulation does not mandate specific charger capabilities for renewable integration. It mandates that the electricity powering the charger meets defined sustainability criteria. This is typically achieved through guarantee of origin certificates, on-site renewable generation, or green power purchase agreements.
However, the regulation does create procurement incentives for hardware that supports smart charging and demand response. Chargers with OCPP 2.0.1 smart charging profiles can dynamically adjust power consumption based on grid carbon intensity, making it easier for operators to demonstrate renewable energy usage and comply with the 50% threshold.
Chargers limited to OCPP 1.6J lack the native smart charging message structures required for this level of grid interaction. This is another reason the protocol upgrade is a procurement priority, even for sites not directly subject to the renewable energy provision.
6. The Procurement Window: Acting Before It Closes
CPOs with deployment plans extending beyond 2026 should treat AFIR compliance as a procurement constraint from this quarter forward. The gap between regulation announcement and enforceable requirement has narrowed significantly. National transposition deadlines are approaching in most member states, and enforcement mechanisms are being established.
The practical implication is straightforward: specify OCPP 2.0.1-certified hardware for all new European deployments. Verify the certification scope covers your required power classes and connector types. Confirm the supplier can demonstrate compliance with payment and accessibility requirements through their platform capabilities.
Suppliers who cannot provide this documentation are selling hardware that may become non-compliant before the first deployment is complete. The cost of switching hardware after a regulatory deadline has passed far exceeds any short-term savings from a lower-unit-price quotation.
Data note: AFIR provisions cited from EU Regulation 2023/1804. OCPP 2.0.1 certification status reflects publicly available records as of 2026. National transposition timelines vary by member state; consult local implementing authority guidance for specific deployment planning.
