CPS comments on: Alternative Fuels Infrastructure Regulation (AFIR)

CPS welcomes the overall ambition of the European Commission proposal for an Alternative Fuels Infrastructure Regulation (AFIR) to expand a cross-border, consumer-friendly EV (electric vehicles) charging infrastructure in the European Union.

While AFIR aims to simplify payments at charging stations, CPS has identified important issues with regards to payments that should be further clarified. CPS believes that to ensure a successful rollout of EV charging infrastructure, the market should be as open as possible.

The Issue

Articles 5 and 7 of the Commission’s proposal mandates specific payment technologies for EV recharging points. These do not reflect the market reality today nor would ensure a future-proof legislation.

Currently, consumers and corporate users are faced with a multitude of different payment schemes to access charging stations, including apps, RFID charging cards, and credit accounts. Despite the clear preferences of European consumers, spontaneous payment with payment cards is often not possible. (NOTE 1 )

The proposed regulation should ensure an open market, promote consumer choice and leave sufficient room for market operators to react to market and fintech developments.

To this end, CPS calls for the AFIR to adopt a technology neutral approach which includes the availability of the most widely used payments systems today.

CPS Recommendations

1. Technology neutral approach and user choice

 CPS believes that the EU payment market should be underpinned by certain key principles: fair competition, consumer demand and safety and security standards.

The EU should promote greater choices for consumers and companies without any bias for any specific technology solution, be it instant payments, credit cards, electronic bank transfers or any other. Consumer preference should continue to drive the evolution of the payments market, as preferences can differ among payment needs and Member States.

As such, we believe it is necessary to maintain a technology neutral approach regarding how payments for electric vehicle charging are made. User interest should ultimately shape how most payments on EV charging infrastructure are carried out.

2. Access and usability of charging points

The AFIR proposal aims to allow users quick and easy access to new charge points, even when they are not signed up to a particular subscription model. Indeed, for the widespread uptake of EVs, refuelling has to be as easily accessible and consumer-friendly as possible. To achieve this objective, charge points should accept all widely used payments systems, including payment cards.

Card payment is widespread, secure and leads to a wider usage of infrastructure. The number of cards in the euro area with a payment function reached 609.3 million, representing around 1.8 payment cards per euro area inhabitant (NOTE 2). Being internationally widespread, it would also ensure cross-border commuters and tourists are covered.

n a country like Sweden where a large part of the territory is marked by long distances and low population density, the accessibility of charge point payment is vital to promote the usage of electric vehicles, including both private and commercial. Based on this we recommend that AFIR require charge points to support more payment means and ensure that the most widely used ones including card payments are not excluded. Operators can of course also continue to offer alternative payment options such as web-based systems via an app or with a QR code.

CPS also welcomes the recent statements by AFIR rapporteur Ismael Ertug which note the importance that all users can access charging infrastructure and that payments by payment cards should be possible.


The Commission’s current approach to payments at EV charge points risks undermining the objectives of the AFIR proposal.

 CPS urges EU policy-makers to adopt a tech neutral approach, offering consumers choice. At the same time, the legislation should make charge points accessible and user-friendly by ensuring that users have the option to pay with their payment card stored in their smartphone.

Michael Hoffmann




More than two-thirds of the respondents confirm this in a recent study conducted by infas quo GmbH on behalf of the Initiative Deutsche Zahlungssysteme e.V. in selected European countries


European Central Bank, “Payment Statistics: 2020

Card Payment Sweden
Stortorget 13 B
SE-211 22 Malmö

+46 (0) 40 250 778