AFIR Compliant EV Charger Procurement Guide for EU Projects

An AFIR compliant EV charger cannot be selected from one logo, connector, or payment feature. Regulation (EU) 2023/1804 assigns obligations across the charging point, station, payment device, software platform, operator, and data interface. The correct procurement question is whether the complete deployed service will meet the rules that apply to its location, power, installation date, access model, and operating country.

This guide helps EU charge point operators, public authorities, EPC contractors, importers, and equipment distributors turn AFIR into a practical specification. Luxman Energy can review the requested charger configuration, but the buyer still needs to define the local payment, backend, metering, installation, and operating responsibilities that sit outside the charger cabinet.

Define an AFIR compliant EV charger by project scope

Start by classifying the deployment. AFIR defines publicly accessible infrastructure broadly: a charging point can be on public or private property and still be publicly accessible when the site is open to the general public. A supermarket, hotel, petrol station, or privately owned car park should not be assumed private merely because the land is privately owned.

Record these scope facts before writing the tender:

Scope question	Why it changes the requirement
Is the point publicly accessible	Payment, price, digital connectivity, smart charging, data, and other AFIR duties may apply
Is it a new installation or a renovation	Several requirements use deployment or renovation dates rather than the purchase-order date
Is rated output below 50 kW or at least 50 kW	Ad hoc payment and price presentation differ across this threshold
Is the site on the TEN-T road network or a safe and secure parking area	The 1 January 2027 retrofit rule for certain older points depends on this location
Is the project for light-duty or heavy-duty vehicles	Pool targets, bay geometry, connectors, and power requirements differ
Will the point offer automatic authentication	Drivers must retain a convenient alternative, and future technical specifications may affect the design
Which Member State will operate the site	Permitting, metrology, tax, accessibility, payments, enforcement, and grid rules still require national review

Do not let a supplier answer all seven questions with a generic declaration that a charger is AFIR ready. Require a compliance matrix that names the applicable clause, responsible party, ordered component, software release, evidence, and acceptance test.

Specify ad hoc payment by power class and date

Article 5 of the current consolidated AFIR text requires operators of publicly accessible charging points to offer ad hoc charging without forcing the driver to register or establish a relationship beyond purchasing the session.

For publicly accessible points deployed from 13 April 2024, the operator must accept widely used electronic payment through a payment terminal or device. The regulation lists card readers and contactless devices. For points below 50 kW, a device using an internet connection for a secure transaction, such as one generating a specific QR code, is also an available route.

This creates a clear procurement distinction:

Deployment	Minimum payment direction to evaluate
New publicly accessible point below 50 kW	Card reader, contactless device, or qualifying secure internet payment such as a specific QR flow
New publicly accessible point at least 50 kW	Card reader or a contactless device able to read payment cards
Older point at least 50 kW on TEN-T or a safe and secure parking area	Card reader or qualifying contactless device must be available from 1 January 2027
Free public charging service	Article 5 paragraph 1 payment requirements do not apply while no payment is required

AFIR permits one payment terminal or device to serve several publicly accessible points within a charging pool. That permission does not prove that a shared-terminal design is operationally suitable. The site still needs unambiguous connector selection, live availability, accessible positioning, queue capacity, terminal redundancy, and recovery when payment succeeds but charging fails.

Ask the payment integrator to identify the terminal model, payment application, PSP, acquirer, supported cards and wallets, merchant country, currencies, connectivity, terminal management, receipt method, refund process, and offline policy. A charger housing that can physically accept a terminal is not evidence that the full payment combination can be boarded and supported in the destination market.

Make the price visible before charging starts

AFIR price rules are an operator and user-interface requirement as much as a billing function.

At publicly accessible points rated at 50 kW or more, the ad hoc charge must be based on the price per kWh for electricity delivered. The operator may also add an occupancy fee expressed per minute. The station must show the ad hoc price per kWh and any occupancy fee before the session begins.

Below 50 kW, all applicable ad hoc price components must be clearly available at the station. AFIR specifies the display order as price per kWh, price per minute, price per session, and any other component.

The procurement specification should identify:

• Which screen, sign, or payment page presents the price

• Which system is the authoritative tariff source

• How tariff versions and effective times are controlled

• How taxes, roaming fees, discounts, and occupancy charges are represented

• What happens when the charger, terminal, and CSMS hold different tariff versions

• How the exact price shown to the driver is retained for complaints and audit

Test price changes at a pilot site. A correct tariff in the management portal is not enough if the terminal or charger displays stale values.

Include digital connectivity smart charging and fixed cables

AFIR requires all publicly accessible points to be digitally connected. Its definition includes real-time information exchange, remote monitoring and control, session start and stop, and electricity-flow measurement. The charger, communications path, and CSMS must therefore be assessed as one operating chain.

Publicly accessible points built after 13 April 2024 or renovated after 14 October 2024 must be capable of smart recharging. The tender should convert that phrase into testable functions, such as remote power limits, schedules, charging profiles, site-capacity control, status reporting, and safe fallback when the control path is unavailable. The exact functions depend on the selected charger, protocol version, and energy-management architecture.

AFIR also required operators to ensure that all publicly accessible DC points had a fixed charging cable by 14 April 2025. For a mixed AC and DC procurement, do not apply one cable assumption to every point. Record connector, cable, reach, handling, cooling, replacement, and accessibility requirements separately.

Use the current technical specifications

AFIR Annex II is not static. Commission Delegated Regulation (EU) 2025/656 updated its references and is incorporated into the consolidated text. For relevant AC and DC points installed or renovated from 8 January 2026, the updated annex refers to EN IEC 62196-2:2022 for Type 2 and EN IEC 62196-3:2022 for Combo 2. Existing equipment can remain under the earlier referenced editions until renovation where the transition provisions allow.

The 2025 technical amendment also introduces staged vehicle-to-grid communication requirements. From 1 January 2027, defined new or renovated points that provide automatic authentication and authorization services such as Plug and Charge must be evaluated against both EN ISO 15118-2:2016 and EN ISO 15118-20:2022 requirements.

Buyers should therefore request the exact standards list and edition used for the ordered model. A certificate or report citing a product family, another connector, or an earlier hardware revision may not cover the delivered configuration.

Connect AFIR data duties to the management platform

Article 20 requires operators or owners, according to their arrangement, to make specified static and dynamic data available through an API and provide information about that API to the national access point.

The statutory data set includes information such as location, connector count and type, current type, maximum power, vehicle compatibility, operator contact details, opening hours, operational status, availability, ad hoc price, and whether supplied electricity is reported as fully renewable. Some fields change rarely; others must reflect current station state.

This requirement usually reaches beyond charger firmware. The CSMS, asset register, tariff engine, maintenance workflow, and national data interface must keep the same identifiers and publish consistent records. Procurement should assign ownership for:

• EVSE, connector, station, pool, and CPO identifiers

• Static asset-data creation and approval

• Status and availability updates after faults or maintenance

• Tariff and ad hoc price publication

• API operation, authentication, monitoring, and change control

• National access point onboarding and country-specific data profiles

• Data-quality alerts and correction times

Do not accept a one-time spreadsheet as the operating solution for dynamic data. Demonstrate the production API path and test changes from charger event to published record.

Separate equipment evidence from operator evidence

An effective AFIR procurement file distinguishes what the equipment supplier can prove from what the operator and its partners must implement.

Compliance area	Typical equipment evidence	Typical operator or integration evidence
Electrical safety and product conformity	Declarations, test reports, technical file, exact model identification	Installation design, inspection, commissioning, maintenance
Connector interoperability	Ordered connector and cited standard edition	Vehicle scope, bay layout, cable reach, user instructions
Ad hoc payment	Terminal mounting and tested interface where included	Acquiring, merchant setup, tariff, receipts, refunds, support
Price presentation	Display capability and interface specification	Approved tariff, tax treatment, content control, audit record
Digital connection	Communications hardware and protocol functions	SIM or network service, CSMS, certificates, monitoring, SLA
Smart recharging	Supported commands, profiles, and local limits	Site controller, grid or building interface, allocation policy
Open data	Charger status and meter records	Master data, API, national access point, data-quality operations

This split prevents a familiar tender failure: the charger supplier marks a requirement compliant because the hardware has an interface, while the CPO assumes the complete operational service is included.

Build an AFIR evidence schedule

Request evidence by model, firmware, connector, optional module, and market. A useful schedule includes:

1. Ordered product designation and configuration code.

2. EU declaration of conformity and applicable test documentation.

3. Connector and cable specification with cited standard editions.

4. Charger-to-CSMS protocol version, functions, and certification status.

5. Payment architecture, terminal model, acquirer availability, and tested transaction flow.

6. Price-display screens and tariff-update process.

7. Digital connection, remote-control, smart-recharging, and fallback behavior.

8. Meter records and interfaces required for billing and local metrology review.

9. Static and dynamic data fields, identifiers, API owner, and export method.

10. Accessibility, language, environmental, installation, maintenance, and cybersecurity evidence.

For each line, mark whether proof is a certificate, test report, screenshot, protocol trace, contract, configuration record, or site test. Supplier statements without a document reference should remain open actions.

Review Luxman public charging configurations

Luxman’s public charging solution describes charging facilities, customer services, smart energy management, white-label network options, and selected split DC equipment with a 7-inch touch screen, POS payment, ISO 15118, Modbus TCP, and optional 4G, Wi-Fi, or Ethernet.

Those published functions are relevant to an EU project, but they do not establish blanket AFIR compliance for every model or site. Ask Luxman to confirm the exact EU configuration, connector, power, cable, firmware, OCPP functions, payment-terminal integration, communications, technical documentation, and standards evidence. Payment acquiring, national data access, local metrology, permitting, installation, and CPO operating procedures should be assigned separately.

Run factory and site acceptance tests

Factory acceptance should exercise the exact charger firmware, connector arrangement, CSMS release, terminal model, and test payment environment. Site acceptance should repeat the critical journey with production connectivity, merchant settings, signage, tariffs, and physical labels.

Include at least these tests:

• Ad hoc start without account registration

• Required cards, contactless wallets, and declines

• Correct connector selection at shared terminals

• Price visibility before authorization and charging

• Meter, tariff, final amount, receipt, and settlement reconciliation

• Payment approval followed by charger-start failure and reversal

• Digital status, remote control, and smart power-limit response

• Loss and recovery of charger, CSMS, payment, and site networks

• Static and dynamic data update through the operating API

• Accessibility, cable reach, language, lighting, weather, and support instructions

Retain timestamps, non-sensitive payment references, screenshots, protocol logs, meter records, and pass criteria. The evidence should be strong enough to diagnose a later fault and identify the responsible supplier.

Frequently asked questions

Is an AFIR compliant EV charger a certified product category?

No single AFIR certificate proves the complete deployed service. Product conformity evidence matters, but AFIR also creates duties for operators, payment services, software, pricing, smart charging, and data publication.

Does every public charger need a bank card terminal?

The answer depends on power, deployment date, location, and payment architecture. New public points at 50 kW or more need a card reader or qualifying contactless device, while new points below 50 kW can also use a qualifying secure internet payment route.

Can one payment terminal serve several charging points?

Yes. AFIR allows one terminal or device to serve several publicly accessible points in one pool. The project must still prove connector mapping, accessibility, capacity, resilience, and failure recovery.

Does OCPP 1.6 make a charger AFIR compliant?

No. OCPP can support charger-to-CSMS communication, but it does not by itself provide acquiring, price compliance, open-data publication, local metrology, or the complete operator process.

Are private workplace chargers covered by AFIR payment rules?

Not automatically. First determine whether the site is publicly accessible under AFIR’s definition. Access conditions and private land ownership do not by themselves settle that classification.

What should an importer request before shipment?

Request the exact configuration code, declaration and test evidence, applicable standards and editions, firmware, connector and cable details, communications, payment interface, meter records, installation instructions, and a written list of items requiring local integration.

AFIR compliant EV charger conclusion

An AFIR compliant EV charger project needs a traceable chain from legal scope to ordered equipment, software, payment, pricing, data, installation, and operating controls. Buyers should classify the site first, allocate every obligation, and accept the system against evidence rather than relying on an AFIR-ready label.

For a configuration review, provide Luxman Energy with the EU country, public-access model, installation or renovation date, AC or DC power, vehicle class, connector, cable, payment architecture, CSMS and protocol, price-display method, smart-charging functions, data-interface plan, environmental conditions, and required standards evidence. Luxman Energy can then confirm available equipment functions and identify the project-specific work that must be completed by other parties.