Ad hoc charging: when your charge points count as publicly accessible

What ad hoc charging means

Ad hoc charging, also referred to as point-by-point charging, means charging without an existing contract. Someone drives up to a charge point, charges and pays, without installing an app, registering or holding a charging card.

AFIR, the EU Alternative Fuels Infrastructure Regulation, requires ad hoc charging to be possible at publicly accessible charge points. As a regulation it applies directly, with no national transposition needed. For operators in Austria that means the requirements apply as they stand.

The key question: is your charge point publicly accessible?

This is where most operators misjudge their situation. A charge point does not count as private simply because it stands on company premises or a hotel car park. What matters is who is allowed to charge there.

Typical indicators of a publicly accessible charge point:

• The group of users is not clearly defined, for example on a customer car park, in an underground garage without a barrier, or on commercial land that anyone can drive onto.

• External users can charge via an app, a charging card or a roaming service.

• The site is open to anyone at certain times. Restricted opening hours do not change the classification.

• Even an employee car park can fall under the rules as soon as visitors or guests are able to charge there.

Signage alone is often not enough. A sign reading "customer parking only" does not sufficiently define the user group, because "customer" is too vague. Operators who deliberately want to keep their charge points private need a genuine access restriction: a barrier, unambiguous signage, or technical access control via RFID or app.

What AFIR actually requires

Since 13 April 2024, the following applies to newly built publicly accessible charge points:

• Ad hoc charging must be offered. Payment has to be possible using a widely used payment instrument, which in practice means debit or credit cards.

• New DC charge points of 50 kW and above need a card reader. Payment with common debit or credit cards must be possible, either through a terminal at the station itself or through a central payment terminal at the site.

• Below 50 kW, a secure ad hoc payment process is sufficient. A built-in card terminal is not mandatory here. QR code solutions that lead to a payment page remain permissible under certain conditions, as long as the code stays readable and the payment process is secure.

• Price transparency. The ad hoc price has to be visible before the charging session starts. From 50 kW upwards, billing per kilowatt hour is also required.

There is no retrofit obligation for AC charge points below 50 kW. For existing DC charge points along the European TEN-T transport corridors, payment by debit or credit card must be possible by 1 January 2027.

ISO 15118 comes on top

Alongside the payment requirements, the communication standards take effect. Newly built or substantially renovated publicly accessible charge points must support ISO 15118-2, and from 2027 ISO 15118-20 applies to new non-publicly accessible charge points as well.

One point matters for planning: not every existing AC station can be brought up to ISO 15118 with a software update. Without a PLC modem in the hardware it is technically impossible. Anyone procuring charge points over the coming months should have this in the specification.

Three cases from practice

The hotel. Two AC charge points on the guest car park, freely accessible. Guests charge there, occasionally passing drivers too. There is no barrier. That makes the charge points publicly accessible, and an ad hoc option is required. For AC no card terminal is needed, a secure QR code solution is enough.

The business park. Charge points for tenants, access via RFID card. As long as only registered users can charge and the area is recognisably restricted, there is a good case that the points are not publicly accessible. The moment visitors can charge through a roaming app, the classification flips.

The retail site. Charge points on the customer car park, free of charge while shopping. Free charging does not make a charge point private either. Accessibility decides, not price.

What to check now

• Which of your charge points are in practice accessible to third parties?

• Is there an access restriction that deserves the name, or only a sign?

• Can someone charge and pay at those points without registering?

• Is the price visible before the session starts?

• Were any DC charge points of 50 kW or more built after 13 April 2024, and is card payment available there?

• Do ad hoc users receive a traceable receipt?

The answers determine whether you have anything to do. In many cases the fix is not new hardware but a software function.

Ad hoc charging with NeuraCharge

NeuraCharge provides ad hoc charging through a QR code at the charge point. The user scans it, sees the price before starting, charges and pays directly, with no app installation and no registration. The receipt is generated automatically.

In parallel, all other user groups keep their familiar access: employees via RFID, tenants through their user account, company car drivers through the app. Every session is assigned to the right group and billed according to the tariff stored for it.

Because NeuraCharge is manufacturer independent, this can be layered onto existing charging infrastructure. In many cases a compliance question turns into a configuration task rather than an investment.

Please note: this article provides general information and does not replace legal advice. Whether a specific charge point qualifies as publicly accessible is a case by case assessment.