AFIR and ISO 15118: How to Address the New Regulatory Landscape Without Putting Your Charging Infrastructure at Risk

Electric vehicle charging infrastructure is entering a decisive phase. For operators, energy companies, and manufacturers, network growth no longer depends solely on deploying new charging points, but on making decisions that ensure those investments remain viable in the years to come.

With the entry into force of the European Regulation on Alternative Fuels Infrastructure (AFIR), regulation has ceased to be a merely indicative framework and has become a critical factor shaping the planning, operation, and evolution of publicly accessible charging infrastructure.

When the risk is no longer technological, but strategic

In many organisations, charging networks have been deployed in a context of rapid growth, under pressure to reduce timelines and contain costs. However, the new regulatory framework raises an uncomfortable question for operations and technology managers: Are we certain that the charging points being installed today will meet the requirements that will be mandatory tomorrow?

The risk is significant. A charger that does not comply with AFIR requirements may result in:

• Investments losing value before being fully amortised
• Additional costs for upgrades or replacement
• Interoperability issues with certain vehicle models
• A direct impact on end-user experience and operator reputation

AFIR: a rule change that requires anticipation

AFIR establishes mandatory technical requirements for publicly accessible charging points across the European Union. Among them, the progressive adoption of the ISO 15118 standard represents a turning point in how vehicles and chargers communicate.

From 8 January 2026 onwards, newly built or refurbished publicly accessible AC charging points must comply with ISO 15118-2. From 2027, compliance with ISO 15118-20 will be mandatory—an evolution that prepares charging infrastructure for new services and business models.

For operations managers, these dates are not merely regulatory milestones: they are thresholds beyond which a poor technical decision can turn into an operational issue.

ISO 15118: what it really means for operations

From the outside, ISO 15118 is often associated solely with the concept of Plug & Charge. However, its impact goes far beyond that. Its implementation affects charger architecture, software, cybersecurity, and interoperability with multiple vehicle manufacturers and backend platforms.

In practice, this involves managing:

• Complex upgrades to already deployed chargers
• Dependencies on technology providers
• Validation and testing processes that are not always clearly defined
• Uncertainty over whether a solution will perform reliably under real operating conditions

The key is not just compliance, but knowing how to comply

In this context, the real challenge for operators and energy companies is not simply to “comply with regulation,” but to understand how to do so without compromising service continuity or significantly increasing costs.

This is where technical validation and testing play a fundamental role. Before deploying or upgrading infrastructure, it is essential to answer—based on data and evidence—questions such as:

• Which chargers can be adapted and which cannot
• What impact the regulation will have on daily operations
• What technical risks exist before certification or market rollout

CIRCE as a technical partner to reduce risk

At CIRCE’s Electric Mobility Laboratory, we work alongside manufacturers, operators, and energy companies to turn regulatory uncertainty into informed technical decisions. Our approach is based on supporting clients throughout the entire process—from analysing the real impact of AFIR on their infrastructure to integrating, validating, and testing ISO 15118-based solutions, always with a practical, real-world operational focus.

The goal is not just to ensure a solution works in the laboratory, but that it is reliable, interoperable, and sustainable over time.

Anticipate today to avoid correcting tomorrow

Experience shows that adapting late to a regulation of this scale often leads to higher costs and reduced flexibility. Anticipation, by contrast, helps protect investments, improve user experience, and prepare infrastructure for the next steps in the market, such as smart energy management or bidirectional charging.

In an environment where regulation advances at the same pace as technology, having an independent technical partner can make the difference between reacting to change—or leading it.

Shall we talk about your infrastructure?

Each charging network has its own specific characteristics. At CIRCE, we help you assess, validate, and prepare real charging infrastructures to comply with AFIR—without surprises.

If you would like more information, please do not hesitate to contact our technical team.