Market and policy analysis: Two EU regulations (AFIR and EPBD) converge to redefine destination charging infrastructure — and what it means for hotels, retail, and commercial parking operators.
- April 2024: The Alternative Fuels Infrastructure Regulation (AFIR) takes effect across the EU.
- May 2026: Member states must transpose the Energy Performance of Buildings Directive (EPBD) into national law.
Between these two dates, thousands of building owners will discover they've been classified as public charging infrastructure operators—even if they consider themselves semi-public charge point operators (CPOs).
The scenario is already playing out. When a hotel plans a renovation, EPBD Article 14 mandates EV charging infrastructure for non-residential buildings undergoing major renovations. The hotel installs chargers, runs cost calculations on providing free charging as a guest amenity, and configures the system for guest priority access.
Then AFIR arrives with its definition: if the car park is publicly accessible, the chargers are public charging infrastructure and the following things become mandatory:
- Ad-hoc payment.
- Price transparency.
- Data reporting to National Access Points.
The hotel discovers it's now operating under the same regulatory framework as motorway charging hubs.
This isn't a regulatory gap or an oversight. It's working as designed. But the interaction between EPBD, a building efficiency directive, and AFIR, a transport infrastructure regulation, creates compliance obligations that many hotel, retail and parkingoperators installing charging infrastructure for the first time didn't anticipate.
While the two regulations were developed independently with different policy objectives, their combined effect is only now becoming clear to building owners planning renovation projects. Understanding what changed, and why it matters, requires going back to what ’semi-public’ charging actually meant in practice.
In this blog, we'll discuss how EPBD and AFIR bring new EV charging obligations for hotel retail and parking operators. And, how the semi-public charging'' terminology was killed by AFIR.
What AFIR eliminated—and what it didn't
What is semi-public charging?
The term ‘semi-public charging’ was never formally defined in EU regulation, but it described a widespread operational reality. Chargers that weren't fully open to anyone (like motorway fast chargers) but weren't strictly private either (like residential home charging).
Hotel guest chargers accessible with a room key code. Workplace chargers available to employees and occasional visitors. Retail car park chargers intended primarily for customers but technically usable by anyone who parked there.
AFIR officially eliminated this middle ground. Article 2(45) defines 'publicly accessible recharging point' as any recharging point 'located at a site or premises that is open to the general public, irrespective of whether in private ownership, whether the access is free of charge or subject to restrictions, limitations or conditions, or whether access involves a fee.'
The critical phrase: 'irrespective of whether access is subject to restrictions, limitations or conditions.'
The European Commission's official Q&A clarifies what this means in practice. Question 2.11 explicitly states: 'As long as the parking area is accessible to the general public, all recharging points located within this parking area are publicly accessible recharging points. Putting a sign has no influence on the assessment.'
So, what does that mean?
- A supermarket car park with 'Customer Parking Only' signs? Public.
- A hotel car park accessible to anyone who books a room? Public.
- A gated parking facility that anyone can access by becoming a customer? Public.
What is private charging?
What qualifies as genuinely private? Charging infrastructure restricted to 'a limited and determinate group of persons who have been specifically authorised by the owner of the property to access the property for purposes other than using the parking or charging infrastructure.'
In practice: employee-only workplace charging with physical access control. Apartment building residents with keycard entry. Fleet depots with security gates.
The question isn't whether you call it semi-public. The question is whether the general public can access the car park by becoming a customer, booking a room, or simply parking there. If yes, AFIR classifies the charging infrastructure as public.
The only industry acknowledgement of this shift came from Pluginvest: 'Semi-public opening of charging stations will no longer be possible under the new AFIR regulations. Under the new rules, all charging stations made public that use roaming will have to be visible on platforms and apps accessible to third parties.'
What used to exist in a regulatory grey zone—chargers that participated in roaming networks but weren't publicly indexed, chargers that were 'available but not advertised'—disappeared overnight when AFIR took effect.
Why the business model distinction still matters
The industry used the term semi-public to refer to charging infrastructure installed by hotels, retailers, and shopping centres because it serves a fundamentally different purpose than infrastructure operated by dedicated charging network providers. AFIR's regulatory reclassification didn't change this underlying commercial reality.
For traditional charge point operators, charging sessions are the product. Revenue comes from electricity sold, utilisation drives profitability, and success is measured in kilowatt-hours delivered and charger uptime. The entire business model optimises for throughput and charging session value.
For destination charging hosts—hotels, restaurants, retail, entertainment venues—charging infrastructure is an operational cost that drives revenue elsewhere. A hotel offering free overnight charging isn't losing money on electricity; it's investing in guest acquisition and satisfaction.
The calculation only makes sense if the guest books the room, uses the restaurant, and returns for future stays. If non-guests flood the car park to use the chargers, the economics break down completely. The hotel becomes an accidental charge point operator (CPO), bearing operational costs without capturing the intended indirect revenue.
Commercial parking operators occupy a distinct position in this landscape. Companies like our parking customers Interparking, APCOA and Q-Park, already monetise parking duration, already operate payment systems and customer service infrastructure, and already manage complex access control. Adding charging infrastructure extends an existing business line rather than creating an entirely new one.
For these operators, AFIR compliance requirements align more closely with existing operational capabilities.
The regulatory classification is binary—public or private—but the operational logic spans a spectrum:
Pure CPO business model:
- Charging is the primary revenue source.
- Optimisation for utilisation, throughput, pricing per kWh.
- Operational complexity is core competency.
Commercial parking model:
- Parking is the primary revenue source, charging adds value.
- Operational infrastructure already exists.
- AFIR requirements extend existing systems rather than introduce entirely new ones.
Destination host model:
- Rooms, meals, retail sales are primary revenue.
- Charging increases dwell time and customer satisfaction.
- Success is measured outside of the charging infrastructure itself.
- Operational simplicity is critical—charging should feel like managing any other building amenity, not running a public infrastructure network.
Important to note is that AFIR doesn't distinguish between these models. A 7kW AC charger in a hotel car park and a 350kW DC charger on the motorway both fall under the same public charging infrastructure requirements if the respective car parks are publicly accessible. The regulation treats intent and business model as irrelevant. What matters is access.
How EPBD aggravates destination charging complexity
The EPBD directive aims to ensure buildings are ready for EV adoption, to reduce the cost of retrofitting charging later, and to support the EU's broader decarbonisation goals.
An important article to keep in mind is EPBD Article 14. It introduces binding requirements for EV charging infrastructure in buildings and specific EV charger-to-parking space ratios. The rules scale based on building type, whether the property is new or existing, and the total number of parking spaces.
The specific requirements are structured as follows.
Non-residential buildings
New and undergoing major renovation:
- Threshold: More than 5 or 10 parking spaces (depending on national transposition).
- Charger ratio: At least 1 charger per 5 to 10 parking spaces.
- Pre-cabling: Ducting (pre-cabling infrastructure) must be installed for at least 1 in 5 parking spaces.
Existing buildings:
- Threshold: More than 20 parking spaces.
- Charger ratio: At least 1 charging point is required by law, with requirements scaling to 1 charger per 10 parking spots or pre-cabling for 50% of spaces (depending on EU member state implementation).
Residential Buildings
New and undergoing major renovation:
- Threshold: More than 3 to 10 parking spaces (depending on national regulations).
- Charger Ratio: At least 1 charge point.
- Pre-cabling: Ducting infrastructure must be in place for every single parking space.
What is a major renovation under EPBD?
EPBD considers a renovation 'major', if:
- the total costs of the renovation are higher than 25 % of the value of the building (Art. 2(10)(a)), or
- you have more than 25% of the building's exterior (building shell) rebuilt or enlarged (Art. 2(10)(b)).
Please note! A charging point is not mandatory if the costs of the charging station(s) (design, materials, and installation) amount to more than 7% of the renovation costs (article 8 sub 6.c).
For building owners who had not previously considered EV charging infrastructure, EPBD removes the choice. Hotels planning renovations, shopping centres updating facilities, office buildings upgrading car parks: all must now factor EV charging into their construction or renovation plans.
Many building owners approached this as a building systems question: install charging infrastructure the way you'd install any required building amenity, configure it for primary users (guests, customers, employees), and manage it through existing facilities management. The assumption was that installing chargers mandated by building regulations would be operationally similar to installing fire safety systems or building automation—compliance infrastructure managed as part of the building.
EPBD consequences for destination charging
What EPBD doesn't make explicit, and what many operators discover only after installation, is that AFIR determines how those chargers must be operated. If the building's car park is publicly accessible—which it is for hotels, retail, shopping centres, restaurants, and most other non-residential buildings—AFIR classifies the charging infrastructure as public.
'If the building's car park is publicly accessible—which it is for hotels, retail, shopping centres, restaurants, and most other non-residential buildings—AFIR classifies the charging infrastructure as public. This triggers a full set of operational requirements.'
This is where many operators installing EV charging infrastructure under the EPBD mandate will encounter their first surprise as that classification triggers a full set of operational requirements:
- Ad-hoc payment capability: Users must be able to charge without a prior contract, using widely available payment instruments (for DC ≥50kW, physical card terminals; for AC, QR codes acceptable).
- Price transparency: Pricing must be clearly displayed before charging begins, and must be per kWh for chargers above 50kW.
- Data provision: Static and dynamic charging point data must be provided to National Access Points, making chargers visible in public charging infrastructure databases.
- Interoperability and roaming: Chargers must support open standards to enable access via multiple eMSP platforms.
- ISO 15118 compliance: From 2026 onwards, support for advanced communication protocols enabling Plug & Charge and bidirectional charging.
Time for (re)action is now
For operators whose primary business is hotels, retail, or hospitality, this represents a step-change in operational complexity. What was conceived as a guest amenity or customer service—free charging to increase bookings and dwell time—now carries the same regulatory compliance burden as public fast-charging networks along motorways.
‘EPBD is accelerating a shift we're tracking across the market,’ says Freerik Meeuwes, Director Sales & Operations at GreenFlux. ’Building owners are being mandated to install charging infrastructure, often for the first time, and discovering that AFIR doesn't distinguish between 'amenity charging' and 'commercial charging networks.' If the car park is publicly accessible, AFIR's compliance requirements apply—ad-hoc payment, price transparency, data reporting. The question for many operators becomes: how do you meet those requirements without transforming your organisation into a full-scale CPO?’
The timeline makes this particularly acute. AFIR came into force in April 2024. EPBD's transposition deadline is May 2026, with progressive implementation requirements extending through 2033. Operators planning building projects today need to understand not just EPBD's installation mandates, but AFIR's operational requirements — and how the two interact.
How to deal with EPBD's requirements
EU member states had until May 2026 to transpose EPBD into national law. How individual countries implement the directive—and whether they provide additional guidance on the AFIR interaction—will shape how building owners and operators navigate this in practice.
Germany, for instance, is planning to implement EPBD with additional flexibility through its Building Electromobility Infrastructure Act (GEIG). Under proposals in Germany's draft climate protection programme, building owners would be able to install fewer high-power DC chargers instead of numerous low-power AC chargers at publicly accessible parking spaces in non-residential buildings.
This national-level flexibility affects how EPBD installation mandates are met but doesn't change AFIR's operational requirements. It doesn’t matter whether a building owner installs ten 7kW AC chargers or two 50kW DC chargers, if the car park is publicly accessible, AFIR compliance still applies.
Other member states may clarify the EPBD-AFIR intersection explicitly, offering frameworks that align building compliance with operational realities. Others may leave operators to interpret the overlap themselves, defaulting to strict application of both regulations without additional nuance.
Key insights for starting building projects
For operators planning building projects now, the key insights are:
EPBD makes charging infrastructure non-optional for many new builds and major renovations. If you're a non-residential building owner planning new construction or major renovation, charging infrastructure installation becomes a regulatory requirement, not a strategic choice.
AFIR determines how you operate that infrastructure. If your car park is publicly accessible—which it is for hotels, retail, restaurants, and most commercial buildings—AFIR classifies your chargers as public infrastructure. That classification brings compliance obligations, such as payment capability, price transparency, data reporting, interoperability.
'The question isn't whether to install charging. EPBD answers that. The question is how to operate it under AFIR without transforming your organisation into a full-scale charging network operator.'
CPO or CPMS?
This is where platform architecture and operational design matter. Destination hosts are not obliged to become a charge point operator, but the requirement is to offer AFIR-compliant public charging while preserving the amenity model that made charging infrastructure valuable in the first place. So, the focus remains on guest priority, customer experience, operational simplicity, and business model alignment.
We work with operators across this spectrum: from traditional CPOs like EDP and Eneco eMobility, to commercial parking operators like Q-Park, Interparking and APCOA, and retailers like Aldi Nord, to destination hosts installing charging for the first time under EPBD mandates.
The platform distinction that matters: understanding whether charging is your product or your amenity, and configuring operations accordingly.
For destination hosts, this means:
- AFIR-compliant payment and data reporting (legal requirement);
- Guest or customer priority access management (business requirement); and
- Operational simplicity (you're not a CPO and don't want the complexity of becoming one).
The regulatory classification is binary. The operational reality isn't.
'Destination hosts are not obliged to become a charge point operator, but the requirement is to offer AFIR-compliant public charging.'
Semi-public charging is not gone (yet)
’Semi-public charging’ may have de facto disappeared, but the business model it described—charging infrastructure that supports another commercial purpose rather than being the purpose itself—is more common than ever. AFIR's reclassification didn't eliminate the use case; it redefined the compliance requirements for operating it.
As EPBD requirements take effect across member states over the next several years, thousands more building owners will navigate this regulatory convergence for the first time. The operators who understand the distinction between charging-as-a-product and charging-as-an-amenity—and who configure their infrastructure accordingly—will find the transition significantly less disruptive than those who discover AFIR's implications only after installation is complete.
The regulations are binary. The market isn't. And that gap is where operational strategy matters most.
For more on how GreenFlux supports different charging infrastructure business models, or to discuss EPBD and AFIR compliance for your specific use case, contact our team.
