AFIR in context: what it is and what it isn't
Regulation (EU) 2023/1804 — the Alternative Fuels Infrastructure Regulation — replaces the earlier Alternative Fuels Infrastructure Directive (AFID, 2014/94/EU) and converts infrastructure targets from optional national transposition into directly applicable EU law. That shift from directive to regulation matters: member states no longer have discretion to water down targets. The requirements apply uniformly from the dates specified in the regulation text.
AFIR's primary focus is on the public charging network: the TEN-T core and comprehensive road networks, urban nodes, and publicly accessible points across member states. This is where the regulation is most frequently misunderstood by depot operators. AFIR does not directly mandate infrastructure at private logistics depots or commercial properties. What it does is create a policy environment — and, increasingly, a supply chain reality — that affects how depots plan their own charging infrastructure, their public charging access for drivers on long-haul routes, and how they interact with DSOs and energy communities under the broader energy regulation ecosystem that AFIR sits within.
That said, AFIR's knock-on effects on depot operators are real and worth understanding precisely.
The AFIR articles that touch depot operations directly
Article 4: light-duty vehicle recharging infrastructure
Article 4 establishes minimum power output requirements for publicly accessible charge points and minimum total pool power targets per member state. For depot operators, the relevant clause is less about the charging hardware itself and more about the AC minimum output standard: publicly accessible AC charge points must deliver at least 7.4 kW per connector from 2025 onwards. If your depot has a public-facing element — a shared car park used by fleet drivers and visitors, or a commercial property where tenant charging is nominally public — the 7.4 kW AC minimum and the IEC 62196-2 Type 2 connector mandate apply. Many older 3.7 kW AC single-phase installations will need upgrading or reclassification as private.
Article 5: heavy-duty vehicle recharging infrastructure
Article 5 is the one logistics operators should read carefully. It sets mandatory power pool targets for publicly accessible truck charging at TEN-T nodes. The requirement at TEN-T Comprehensive Network nodes is 350 kW per location by 2025, scaling to 1,400 kW by 2030 and requiring at least one 350 kW output connector at each node. For depot operators whose vehicles regularly use public TEN-T charging nodes on inter-city routes, Article 5 is what ensures that the charging infrastructure they depend on mid-route will actually exist and will be capable of delivering meaningful charge within a driver's mandatory rest window.
Article 5(8): smart charging requirements
The smart charging provisions of Article 5(8) require that publicly accessible recharging points deployed after entry into force must support smart charging functionality and be capable of communicating with vehicles and energy management systems. The technical baseline aligns with OCPP 1.6 or later and the ISO 15118 communication standard between vehicle and charge point. This is where AFIR intersects directly with depot software: any depot deploying infrastructure that may later need to serve a public-access function must build to the smart charging communication baseline from the outset.
What AFIR means for depot charging software decisions made today
The practical question for depot operators is not "must I comply with AFIR?" — in most cases, private depot charging is outside AFIR's direct scope. The question is "will decisions I make today about depot infrastructure create compliance exposure or operational inflexibility as the regulatory landscape continues to evolve?"
Three specific decision points where AFIR creates downstream exposure:
Connector type selection. AFIR mandates IEC 62196-2 Type 2 for AC and CCS Combo 2 for DC at publicly accessible points. Deploying proprietary or non-CCS connectors at a depot that might later convert part of its infrastructure to public-access use creates a hardware retrofit cost that is entirely avoidable with upfront specification.
OCPP version. Article 5(8)'s smart charging baseline effectively requires OCPP 1.6 at minimum; OCPP 2.0.1 is the direction of travel for ISO 15118 Plug and Charge support and the demand response features that REI III will eventually require. A depot deploying proprietary charge management protocols that don't support OCPP profile pushes has limited interoperability and cannot participate in grid services even if it wants to later.
Data reporting. AFIR Article 19 requires operators of publicly accessible recharging pools above certain thresholds to report static and dynamic data to the EVSE Data Pool (or national equivalent). Depot software that cannot export session data in OCCS/DATEX II compliant formats will create compliance overhead when reporting obligations expand.
A scenario: mixed-use logistics park, southern Germany, 2025
A logistics park operator manages 12 hectares outside Augsburg with five tenant companies running combined 180 commercial vehicles — a mix of light vans, medium rigid trucks, and articulated trailers. The park has a shared car park area accessible to visitors and delivery contractors. The site has a 1,600 kVA medium-voltage connection feeding three distribution transformers.
In late 2024, two of the tenants announce fleet electrification timelines beginning Q2 2025. The park operator commissions an EVSE installation: 60 AC points at 22 kW (Type 2) and 4 DC fast chargers at 150 kW (CCS Combo 2) in the shared public car park area. The shared car park charging infrastructure triggers AFIR Article 4 compliance obligations because it is publicly accessible — registered in the national EVSE point database and accessible to non-tenants.
The complication: the 60 AC points were spec'd without a building energy management system (BEMS) integration, and the charge point vendor selected uses a proprietary cloud backend that does not support OCPP SetChargingProfile.req. When two of the tenant fleets begin unmanaged overnight charging simultaneously, the aggregate demand from EV charging plus baseline building loads reaches 1,100 kW against a 1,440 kW transformer capacity — acceptable on paper, but the Leistungspreis spike from peak-hour simultaneous connections is generating demand charges 60% above pre-electrification levels. The park operator cannot implement smart charging without replacing the charger firmware or the entire CPMS, because the proprietary backend has no OCPP profile push capability.
This scenario is avoidable. AFIR's smart charging requirements, combined with sensible infrastructure spec decisions, would have led to OCPP-capable hardware from the outset.
The boundary between AFIR compliance and operational optimisation
We're not saying that AFIR compliance alone produces an efficient depot charging operation. Compliance with AFIR Article 5(8) means your infrastructure can receive smart charging profile pushes — it does not mean you have a scheduling system that actually sends useful profiles. Compliance is the floor; optimised operations require a layer above it.
A depot with AFIR-compliant OCPP hardware but no fleet scheduling software is in the same position as a factory with ISO 9001-certified processes but no quality control engineers. The standard creates the capability requirement; the software realises the capability. Fleet operators planning depot infrastructure should evaluate their charge point hardware against OCPP 2.0.1 smart charging profile support, and their management software against the ability to generate MILP-optimised charging schedules that use those profiles.
The German regulatory dimension adds a further layer: §14a EnWG (steuerbare Verbrauchseinrichtungen) creates a framework for DSO-triggered load reduction of EV charging, heat pumps, and other flexible loads. Under the 2023 BNetzA framework decision, DSOs can curtail controllable loads to 4.2 kW per connection point during congestion events. Fleet operators on regulated tariff structures who want protection against excessive DSO curtailment need a Netzentgeltverordnung (StromNEV) — compliant grid connection agreement that specifies their charging load profile. Smart charging software that can enforce a real-time DSO curtailment signal — typically received via the OCPP Remote Start/Stop or via a separate USEF or EEBus signal — is increasingly a contractual requirement from German DSOs for high-load commercial consumers.
Immediate actions for depot operators in 2025
Given the AFIR timeline and the German-specific regulatory overlay, the actions that create the most durable options for depot operators are:
- Audit existing EVSE hardware against OCPP version support — specifically whether
SetChargingProfile.reqandGetCompositeSchedule.reqare implemented, not just the basic Start/Stop transaction flows. - Review the grid connection agreement with your DSO. Understand whether your Netzanschlussvertrag includes §14a-compliant curtailment clauses and what the contracted demand ceiling is relative to your planned fleet electrification load.
- If any part of your site provides publicly accessible charging, verify registration in the BDEW (Bundesverband der Energie- und Wasserwirtschaft) Ladesäulenregister and assess whether your reporting data pipeline meets the AFIR Article 19 data publication format requirements.
- Decouple hardware and software decisions. The charge point hardware (connector, protocol, power rating) is a long-lived capital asset. The charging management software is a shorter operational cycle. Selecting OCPP-native hardware preserves optionality across software vendors and future regulatory requirements.
AFIR is not a checklist to file and forget. It's part of a multi-year regulatory trajectory — alongside RED III, the Energy Efficiency Directive, and the emerging ISO 15118-20 bidirectional standard — that will progressively tighten the technical baseline for EV charging infrastructure across Europe. Building to that trajectory now, rather than retrofitting at each regulatory revision, is consistently the lower-cost path.