AFIR for public charging: the data and payment rules, and how to add them without replacing your backend

If you operate public charging, you have heard "AFIR" by now, usually attached to a worry: do we need a new backend to comply? In most cases the honest answer is no. AFIR mostly changes what your charging points have to expose to drivers and to data users: a way to pay on the spot, prices that can be compared, and open data about each point. A lot of that is a software and routing problem, not a reason to throw away a working setup.

That is the practical angle of this article. AFIR is real and the deadlines have started. But the parts that are about data and payment flows can often be added on top of what you already run, by routing your chargers through a layer that can talk to a compliant data and billing path. The Plugchoice OCPP Proxy is built for exactly that kind of bolt-on, without a rip-and-replace. The one thing software cannot conjure is physical hardware at the station, and this piece is clear about where that line sits.

First, what the regulation says, from the text itself.

What AFIR is, and what changed from AFID

AFIR is the Alternative Fuels Infrastructure Regulation, Regulation (EU) 2023/1804. It was adopted on 13 September 2023 and applies from 13 April 2024. It repealed the older AFID Directive (2014/94/EU) from that same date.

The change from a directive to a regulation matters more than it sounds. A directive had to be transposed into each country's own law, so the rules drifted between member states. A regulation is, in the text's own words, "binding in its entirety and directly applicable in all Member States." The baseline is now the same across the EU, even where national details still sit on top.

For charge point operators, the operative parts are two articles. Article 5 covers ad-hoc charging, payment and pricing. Article 20 covers data. The rest of this article works through both.

Who AFIR applies to, and who it does not

AFIR's charging obligations apply to publicly accessible recharging points. The definition is broad and catches a point that many operators expect to be exempt. A site counts as publicly accessible if it is "open to the general public," and the regulation says this holds "irrespective of whether the alternative fuels infrastructure is located on public or private property" and irrespective of the use conditions.

In plain terms: ownership of the land is not the test. A charger in a supermarket car park, a hotel forecourt or a retail park is publicly accessible even though the property is private. A charger behind a barrier that only staff or a single company's vehicles can reach is generally not.

Private home charging and closed depot charging sit outside Article 5's payment and pricing rules. If your sites are a mix, the test runs point by point: who can actually walk up and charge.

Ad-hoc payment, without a contract

The core driver-facing rule is ad-hoc charging. Operators must let an end user "recharge their electric vehicle on an ad hoc basis," which the regulation defines as paying for a session "without the need ... to register, conclude a written agreement or enter into a commercial relationship" beyond buying that one charge. No app account, no subscription, no roaming card required as the only option.

For publicly accessible points deployed from 13 April 2024, that ad-hoc payment has to use a payment instrument widely used in the Union, and the operator must accept electronic payment through at least one of:

• a payment card reader;
• a contactless device that can at least read payment cards;
• for points below 50 kW, an internet-connected device allowing secure payment, such as one that generates a QR code.

The threshold is the part to read carefully. The QR-code or in-app route is only offered to points below 50 kW. At 50 kW and above, the menu narrows to a card reader or a contactless terminal that reads cards. A QR code alone does not satisfy a new high-power DC point.

Two reliefs sit alongside this. A single payment terminal may serve several points in a recharging pool, so you do not need one terminal per socket. And the payment rules "shall not apply to publicly accessible recharging points that do not require payment for the recharging service," so genuinely free charging is exempt from the payment-means obligation (though, as the data section shows, free points are also exempt from some dynamic-data duties).

Existing sites are not all off the hook. From 1 January 2027, operators must make sure that publicly accessible points at or above 50 kW on the TEN-T road network, or on a safe and secure parking area, meet the card-reader or contactless requirement, "including recharging points deployed before 13 April 2024." That is the retrofit deadline for high-power roadside and parking sites.

Transparent, comparable pricing

AFIR also sets a pricing standard. Prices at publicly accessible points must be "reasonable, easily and clearly comparable, transparent and non-discriminatory." Operators cannot discriminate on price between end users and mobility service providers, or between different providers, though a justified and proportionate difference is allowed.

How the price is built depends, again, on power:

• At 50 kW and above, the ad-hoc price "shall be based on the price per kWh for the electricity delivered." An occupancy fee per minute is allowed on top, but the energy itself is billed per kWh. The station has to show the price per kWh and any per-minute occupancy fee "before they initiate a recharging session," so a driver can compare.
• Below 50 kW, the regulation does not force a per-kWh basis, but it does require the price components to be shown, before the session starts, in a set order: price per kWh, then per minute, then per session, then any other component.

These pricing rules apply to points deployed from 13 April 2024. The intent is plain: a driver should know what a session costs before plugging in, in a form they can compare against the point down the road. Worth not overstating: per-kWh as the charged basis is a high-power rule, not a blanket ban on per-minute or per-session pricing everywhere.

Open data on your charging points

Article 20 is the part operators most often miss, because it is not driver-facing. By 14 April 2025, operators of publicly accessible points (or the owners, by arrangement) must make static and dynamic data about their infrastructure available "at no cost," through an API that gives "free and unrestricted access" to it.

The data splits in two:

• Static data, set once and rarely changed: geographic location, number of connectors, accessible parking spaces, owner and operator contact details, opening hours, and for recharging points the operator ID codes, connector type, current type (AC or DC), and maximum power output of the station and of the point.
• Dynamic data, which moves: operational status (operational or out of order), availability (in use or not), the ad-hoc price, and whether the electricity supplied is 100% renewable. Points that do not require payment are exempt from the dynamic-data duties.

That data does not just sit on the operator's own system. Member states had to make it accessible through their national access points by 31 December 2024, and the Commission is to set up a common European access point by 31 December 2026. The regulation also has each member state appoint an organisation to issue the unique ID codes that identify operators and service providers, by 14 April 2025. For an operator, the practical obligation is upstream of all that: expose clean static and dynamic data through an open API so it can flow to those access points.

The dates worth diarising

Where Plugchoice fits: add the missing pieces, keep your backend

Read AFIR's two articles together and most of the work is about flows of data and payment, not about the brand of CSMS you run. That is the gap the Plugchoice OCPP Proxy is designed to close. The proxy keeps your charger connected to Plugchoice while OCPP traffic is routed on to another operator, billing platform, CSMS or EMS. So you can leave a working backend in place and route the chargers through a layer that can also feed a compliant data and payment path.

Concretely, three of AFIR's demands map onto things a routing-and-data layer can add:

• Open data (Article 20). Plugchoice already speaks OCPP to the charger, so the live status, availability and session data needed for the static and dynamic data set can be exposed through the REST API and routed onward, rather than waiting on a legacy backend to grow an API it never had.
• Ad-hoc payment below 50 kW. For AC and sub-50 kW public points, the QR-code or in-app ad-hoc route can be served by connecting a billing platform through the proxy, alongside whatever contract-based setup you already run. The billing and integrations layers are where that connection lives.
• Price transparency. Per-kWh pricing and clear price display lean on trustworthy metering and a tariff setup that can publish the ad-hoc price. That is the job of the tariff management layer, and it ties back to MID metering when the kWh value has to hold up for settlement.

The point is not that the proxy makes you compliant on its own. It is that you can add the data, the sub-50 kW ad-hoc payment route and the pricing transparency on top of an existing backend, instead of migrating everything to satisfy a regulation. If you want to see how that routing works in practice, explore the OCPP Proxy, browse the integrations overview, or contact us about a specific public-charging estate.

A fair note on what "AFIR-ready" can and cannot mean

Compliance is per deployment, and nobody honest can hand you a blanket "AFIR-compliant" badge for a platform. Whether a given site complies depends on its power level, where it sits (a TEN-T road or parking area pulls in the retrofit rule), whether it is publicly accessible, when it was deployed, and whether it takes payment at all.

The clearest limit is hardware. At 50 kW and above, AFIR wants a physical card reader or a contactless terminal that reads payment cards. No software layer, proxy included, can add a card reader to a station that does not have one. What software can do is handle the data obligations, enable the sub-50 kW ad-hoc payment route, and make pricing transparent and comparable. For high-power DC payment hardware, plan the terminal in.

So treat "AFIR-ready" as a direction, not a guarantee: a setup where the data flows, the prices are transparent, and the payment paths software can provide are in place, with the hardware obligations identified for the sites that carry them. If you tell us the power levels and locations in your estate, we can be specific about which parts are a routing-and-data exercise and which need work at the station.

Sources and links

• Regulation (EU) 2023/1804 (AFIR), full text on EUR-Lex, the source for every article quote above (Article 2 definitions, Article 5 payment and pricing, Article 20 data, Articles 25 and 26 on repeal and application)
• AFIR consolidated version, the current text including later corrigenda
• European Commission, Alternative fuels infrastructure, the policy framing
• Questions and answers on AFIR, the Commission and EAFO plain-language guidance, including that Article 5 applies to all publicly accessible points unless stated otherwise
• Plugchoice OCPP Proxy, the routing layer that adds a compliant data and payment path to an existing backend
• Plugchoice integrations and billing, where a payment platform is connected
• MID meters for EV charging, background on metering that holds up for settlement