AFIR Price Transparency Requirements for Charge Points

AFIR, the European regulation on the deployment of alternative fuels infrastructure, has applied directly in every member state since 13 April 2024. Many operators read one message into it: the price now has to stand still. That is not in the text. The regulation requires the driver to know the price before the session starts, which is a different thing from a price that stays the same all year.

What does AFIR require about charging prices?

AFIR obliges the operator to make the ad hoc price and all its price components known before a charging session begins, and to keep that price reasonable, transparent and non-discriminatory. At publicly accessible charge points of 50 kW and above, the ad hoc price must be based on a price per kWh for the electricity delivered, and that price must be shown at the station itself rather than only behind a link or inside an app. Below 50 kW it is enough to make the price with all its components clearly and easily available, for example through a QR code or a web page. An occupancy fee per minute may sit alongside it, as long as it exists to discourage long occupancy and is proportionate to that aim. Since 14 April 2025 the ad hoc price must also reach your national access point as dynamic data, updated within one minute of any change.

Does AFIR forbid your price from moving?

No. There is no provision that fixes a tariff in time. The European Commission's questions and answers on the regulation put the weight on visibility, reasonableness and equal treatment, not on standing still. A price that differs between Tuesday morning and Saturday evening complies, provided the driver sees that price before plugging in and everyone plugging in at that moment pays the same.

Price transparency under AFIR is the obligation that a driver knows the ad hoc price with all its components at the moment the session begins. It is not price regulation and it is not a price freeze. The distinction is worth making, because a share of the operators postponing dynamic tariffs are postponing them for a rule that does not exist.

What exactly changes at 50 kW?

The 50 kW threshold mainly decides the shape of the tariff and where it has to appear.

That last row costs the most money and gets forgotten the most often. An operator running a fixed session fee above 50 kW has to fold that amount into the kWh price or replace it with an occupancy fee that carries a real behavioural purpose. How to build such a price without giving away your margin is covered in our explanation of the platform and the pricing model.

Why did transparency get worse in practice?

Because the price goes missing somewhere between the platform and the invoice. The 2023 charging study by NKL in the Netherlands looked at more than 1,100 charging sessions at over a hundred public and semi-public charge points. In 73 percent of those sessions the price was known in advance, against 81 percent in 2021. In 80 percent of sessions the price on the invoice was correct, against 98 percent in 2021. The user rating for the charging experience fell from 6.3 to 6.0 over the same period.

The second figure is the painful one. A tariff that is set correctly and still lands wrong on the invoice has stopped being a communication problem and become a revenue problem. Sent and applied are two events on two systems you do not control. That is why a nightly tariff deviation check runs across our whole network, comparing the configured tariff with what the CDR actually billed.

How do you build a demand-aware tariff that follows AFIR?

By letting the price move at moments when nobody is charging, and holding it still the second somebody plugs in. Five design choices carry the work.

• Freeze the price at the start of the session. What the driver sees when plugging in holds until the cable comes out. A price that jumps mid-session is the one variant that genuinely conflicts with the spirit of the regulation.
• Publish the rule, not only the price. Stating that the off-peak rate runs from 22:00 to 06:00 makes the variation predictable and defensible during an inspection.
• Work with a floor and a ceiling. An upper bound is exactly what separates dynamic pricing from surge pricing. We wrote earlier about setting a price floor and a price ceiling.
• Let changes take effect on a day boundary. A tariff that starts tomorrow and is known today gives roaming partners time to push the change through.
• Check that the tariff arrived. At every eMSP, and since April 2025 in the national access point as well. A tariff you sent but that landed nowhere will show up wrong on somebody else's map.

Where does a price that only follows the energy market belong?

As a discount layer for members and subscribers, never as the base or roaming tariff. A tariff that simply passes through the spot price plus a fixed margin exposes your entire margin to the energy market and says nothing about demand on your own site. Under AFIR it is also the hardest variant to explain, because the price changes for a reason the driver at the pole cannot see. On a member rate the same mechanism does work, since that driver is a returning customer who reads the rule once and then plans around it.

A demand-aware base tariff does the opposite. It moves with hour, day and occupancy, stays inside limits you set yourself, and is at every moment a single number you can display at the station. Whether it pays off for you depends on your occupancy pattern. The free potential analysis works that through on your own figures.

What would you do differently on Monday?

Walk your fast chargers through the four rows in the table, starting with whether a fixed session fee is still sitting inside your price build-up above 50 kW. Then check whether the tariff you changed last month actually shows up on every map and in every app. In most networks we see, the problem is not the setting but the propagation of it. An operator who has that in order has no remaining reason to keep the price frozen out of caution.