Plug and Charge<\/a><\/span>, bidirectional charging, smart charging, and charging schedule control.<\/p>\nIn other words, compliance is not measured by “how many functions your charger offers,” but by “whether it can establish stable and smooth communication with electric vehicles that comply with the standard.”<\/p>\n
EV charger manufacturers can choose different combinations of AC\/DC charging, Plug and Charge, bidirectional charging, and other functions according to their product positioning. As long as the functions they provide are implemented in accordance with the corresponding technical requirements of the standard, they can meet the relevant requirements.<\/p>\n
This also means that implementing a function without immediately activating it does not constitute a violation. Operators can wait until the technology, market, or PKI ecosystem is mature before making the function available.<\/p>\n
2. What Does Compliance Actually Cover? Scope, Targets, and Boundaries<\/h4>\n
To understand ISO 15118-20 compliance correctly, three sets of boundaries need to be clearly defined.<\/p>\n
2.1 Equipment Scope: The Requirement Applies to Charging Stations<\/h5>\n
The mandatory obligations under AFIR apply only to the charging station side (charging points\/Electric Vehicle Supply Equipment, or EVSE). They do not require electric vehicles to implement ISO 15118-20 at the same time.<\/p>\n
The EU is evaluating the introduction of V2G and interoperability requirements for newly sold electric vehicles from 2030. However, this follows a separate timeline.<\/p>\n
2.2 Communication Scope: EV-to-Charger Communication<\/h5>\n
AFIR requires compliance with communication between the vehicle and the charging station. ISO 15118-20 itself is also purely a communication standard.<\/p>\n
Communication between the charging station and backend systems (such as IEC 63584\/OCPP), e-roaming, and Public Key Infrastructure (PKI) are not currently subject to specific mandatory standards under AFIR. These are areas that have been anticipated but have not yet taken effect as mandatory requirements.<\/p>\n
2.3 Functional Scope: TLS 1.3 Encryption Is Mandatory<\/h5>\n
TLS 1.3 encryption is a normative requirement of ISO 15118-20. Regardless of whether a charging station provides Plug and Charge or connects to a backend system, it must implement TLS 1.3.<\/p>\n
This is because TLS 1.3 provides the security foundation for every charging session and cannot be treated as an optional feature.<\/p>\n
By contrast, the EU e-mobility PKI ecosystem, which provides the trust framework supporting Plug and Charge (PnC), is currently still under voluntary development, led by the European Commission’s Joint Research Centre (JRC).<\/p>\n
2.4 When Does the Compliance Requirement Take Effect?<\/h5>\n
The key triggers for compliance are “installation” and “refurbishment.”<\/p>\n
After January 1, 2027, newly installed or refurbished charging points must comply with ISO 15118-20:2022, regardless of when they were manufactured or whether they were already in stock.<\/p>\n
Simply relocating a charging station, carrying out routine maintenance, or replacing individual components generally does not trigger the new requirements.<\/p>\n
3. How Can Compliance Be Demonstrated? Self-Declaration Is Currently Acceptable, but Third-Party Verification May Come Later<\/h4>\n
This is one of the most practical questions for manufacturers.<\/p>\n
The conclusion is straightforward: AFIR does not currently require EV charger manufacturers to follow a specific conformity assessment procedure, and certification by a third-party certification body is not a mandatory prerequisite.<\/p>\n
At this stage, a manufacturer’s evidence-based self-declaration is an acceptable approach for demonstrating compliance.<\/p>\n
However, “self-declaration” does not mean simply making an unsupported claim.<\/p>\n
It must be supported by technical documentation. The declaration should clearly identify:<\/p>\n
The product and its hardware and software configurations.<\/p>\n
The services and functions that have been implemented.<\/p>\n
The conformity tests performed and their coverage.<\/p>\n
Any unresolved limitations.<\/p>\n
For ISO 15118-20, currently available conformity testing standards include ISO 15118-21 (general test cases) and ISO\/PAS 15118-23 (DC test cases).<\/p>\n
Security-related testing (ISO 15118-22) has not yet been published. At this stage, manufacturers need to demonstrate security implementation through detailed test reports and established TLS 1.3 standards, while mapping their testing activities to future formal testing plans.<\/p>\n
It is important to note that conformity testing can demonstrate that a product has been implemented “in accordance with the standard,” but it does not automatically prove that it can actually interoperate with other chargers or vehicles.<\/p>\n
Compliance does not equal end-to-end interoperability.<\/p>\n
The direction of discussions between the EU and STF is to build on conformity testing by adding standardized interoperability testing and end-to-end validation through real PKI connections. Third-party certification may also gradually become part of the formal framework.<\/p>\n
4. Beyond 2027: Emerging Opportunities in MCS, TLS 1.3, and the PKI Ecosystem<\/h4>\n
For manufacturers following the latest industry developments, there are three important areas worth monitoring.<\/p>\n
4.1 Megawatt Charging System (MCS)<\/h5>\n
The Megawatt Charging System (MCS) is designed for heavy-duty commercial vehicles. Its communication functions were introduced through ISO 15118-20 Amendment 1, published in 2026. However, Amendment 1 has not yet been referenced by AFIR.<\/p>\n
The physical communication layer used by MCS is automotive Ethernet (10BASE-T1S), rather than traditional Power Line Communication (PLC).<\/p>\n
Therefore, its testing methods cannot simply follow those used for conventional charging communication. This represents an important technical difference and a potential area of differentiation for manufacturers.<\/p>\n
4.2 TLS 1.3 Is the Baseline Requirement Across All Scenarios<\/h5>\n
Even private home chargers that do not provide Plug and Charge or connect to a backend system must implement full TLS 1.3 functionality.<\/p>\n
Whether a product meets the requirement can therefore be initially assessed by checking whether it supports encrypted communication.<\/p>\n
4.3 The EU e-Mobility PKI Ecosystem<\/h5>\n
The trust framework supporting Plug and Charge is moving from voluntary initiatives toward a potentially mandatory EU-level framework.<\/p>\n
A single EU Certificate Trust List (CTL) is a long-term objective.<\/p>\n
For manufacturers exporting products or operating in overseas markets, connecting with established PKI providers in advance can help reduce future compliance and roaming integration costs.<\/p>\n
5. A Practical Compliance Framework: Three Milestones and Three Monitoring Checkpoints<\/h4>\n
Rather than chasing technical terminology, manufacturers should focus on several clear reference points.<\/p>\n
For EV charger manufacturers, operators, and teams targeting overseas markets, we recommend establishing the following monitoring framework.<\/p>\n
5.1 Three Important Milestones<\/h5>\n
January 1, 2027:<\/p>\n
Newly installed or refurbished public charging points in the EU must comply with ISO 15118-20:2022. This is a mandatory regulatory milestone.<\/p>\n
From 2030:<\/p>\n
The EU is evaluating the introduction of V2G and interoperability requirements for newly sold electric vehicles. This represents a separate timeline on the vehicle demand side.<\/p>\n
To Be Determined:<\/p>\n
Whether ISO 15118-20 Amendment 1 (including MCS) will be incorporated into the next AFIR revision remains an important development to monitor.<\/p>\n
5.2 Three Key Monitoring Indicators<\/h5>\n
1. TLS 1.3 Encryption Support<\/strong><\/p>\nDoes the charging station support TLS 1.3 encryption? This is the first essential technical checkpoint for ISO 15118-20 compliance.<\/p>\n
2. Evidence-Based Self-Declaration and Technical Documentation<\/strong><\/p>\nDoes the manufacturer have an evidence-based self-declaration supported by technical documentation? This is currently the most practical way to demonstrate compliance.<\/p>\n
3. Conformity Testing and Interoperability Validation<\/strong><\/p>\nIs there a testing plan covering conformity testing (ISO 15118-21\/-23), interoperability testing, and end-to-end validation? This determines whether “compliance” can translate into “real interoperability.”<\/p>\n
Conclus\u00e3o<\/h3>\n
AFIR is making ISO 15118-20 interoperability mandatory, essentially establishing regulatory requirements for communication between electric vehicles and charging stations.<\/p>\n
For the industry, what manufacturers really need to prepare for is not implementing every available function, but ensuring a reliable foundation for interoperability and security.<\/p>\n
Compliance is the entry threshold, interoperability is the capability, and the ecosystem (PKI, MCS, and V2G) represents future opportunities.<\/p>\n
This way of prioritizing development is more valuable than simply memorizing individual clauses of any technical standard.<\/p>","protected":false},"excerpt":{"rendered":"
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