What’s Going On With NEVI And AFIR, a 2026 Update
Authors: Björn Albertsson | Carla Treviño
Co-authored by Metergram and Irdeto
Published spring 2026. The technical requirements and recommendations described in this article reflect current guidance as of the time of writing.
Introduction
Two major regulatory frameworks are now actively shaping how EV charging networks are built and operated across the US and Europe. In the US, NEVI (the National Electric Vehicle Infrastructure program) has been setting compliance requirements since 2022. In Europe, AFIR (the Alternative Fuels Infrastructure Regulation) came into force in April 2024. The protocols they lean on, OCPP 2.0.1, OCPI 2.2.1, ISO 15118, and smart charging standards, are the same ones CPOs need to get right regardless of which market they operate in.
This article covers what each regulation requires and what it actually takes to implement it.
The Regulatory Picture
NEVI ties federal funding to a specific set of technical requirements. The program has had a turbulent year: the Trump administration froze funding in early 2025, 16 states filed suit, and a federal court ordered the release of funds in June 2025. Congress has since rescinded around $800 million from the program, and a proposal to require 100% domestic manufacturing of funded chargers, a threshold no manufacturer can meet, was floated in February 2026 and eventually dropped. The program is moving again, with $885 million apportioned for FY2026 and multiple states opening new funding rounds, but the political environment remains uncertain.
What hasn’t changed is what the technical requirements actually are. OCPP 2.0.1 for charger-to-network communication, OCPI 2.2.1 for network-to-network communication (while not codified in 23 CFR Part 680 it is effectively required in practice), ISO 15118-2 for charger-to-vehicle communication enabling Plug and Charge, and secure grid communication are all still in place.
AFIR operates differently. It does not tie requirements to funding. It ties them to market access. As an EU regulation it applies directly in all member states without requiring local legislation. CPOs operating publicly accessible stations in Europe are subject to it regardless of whether they receive any public money. The compliance obligations are phased, with the most significant technical deadlines falling between now and 2027.
The practical effect in both cases is the same: CPOs that haven’t modernized their software stack are either out of compliance or locked out of funding and key corridors.
What You Actually Need to Implement
OCPP 2.0.1
This is the foundation. Most CPOs still running older infrastructure are on OCPP 1.6, which doesn’t reliably support the security, device management, and interoperability features expected under NEVI and increasingly required to meet AFIR obligations. The upgrade path isn’t always straightforward. Vendor support varies significantly and some CSMS platforms still implement OCPP selectively. Before committing to a platform, verify which parts of the 2.0.1 specification are actually implemented, not just which version is listed on the datasheet.
AFIR does not explicitly mandate OCPP, but it implicitly depends on its capabilities. Remote operation, price presentation, smart‑charging control, and reliable data exchange with backend systems and National Access Points are all difficult to implement consistently without a modern OCPP stack. In practice, OCPP 2.0.1 has become the de facto technical layer for delivering AFIR‑compliant functionality at scale.
ISO 15118 and Plug and Charge
Both NEVI and AFIR make ISO 15118 support a compliance requirement, effectively elevating Plug & Charge from an optional feature to a baseline capability. Under AFIR, EN ISO 15118‑2 support became mandatory for newly installed or substantially renovated publicly accessible charging points as of January 8, 2026. ISO 15118‑20, which enables bidirectional charging (V2G), becomes mandatory for new charging points from January 2027 and, from the same date, also applies to new private charging infrastructure, including fleet and workplace installations.
Making Plug & Charge work in practice requires more than OCPP 2.0.1 support at the charger. It depends on a functioning PKI layer, with contract certificates issued by or on behalf of the eMSP, exchanged via a trusted certificate ecosystem, and recognized by vehicle OEMs. The CSMS must handle Plug & Charge session logic correctly, and the CPO must be integrated with a certificate pool that can interoperate with both OEM and eMSP PKI domains. Conformance and interoperability testing are critical here, and this is where many Plug & Charge deployments ultimately stall.
Data sharing
AFIR requires CPOs to provide both static and dynamic data on their stations through National Access Points, free of charge. Static data, as location, connector type, and power output, must be updated within 24 hours of any change. Dynamic data, as real-time availability, current pricing, and operational status, must be updated within one minute. From April 14, 2026, all data must be provided in DATEX II format via a compliant API (some NAPs accept OCPI as an ingestion layer and perform DATEX II conversion). This is not optional and it requires CSMS-level support to automate.
OCPI 2.2.1
For NEVI compliance, charging networks must be capable of communicating with other networks, enabling a driver to use a single credential across multiple CPOs. The NEVI rules explicitly rely on OCPI 2.2.1 to enable this interoperability.
AFIR takes a different approach. It does not mandate participation in roaming schemes, even on TEN‑T corridors, but instead requires universal ad‑hoc access without prior registration. In practice, roaming is still widely expected by drivers and commonly required through commercial agreements and public tenders. OCPI has therefore emerged as the de‑facto protocol for delivering cross‑network access and interoperability in Europe.
Implementing it means connecting to one or more roaming hubs or establishing direct peer-to-peer connections with partner networks. Running multiple OCPI versions simultaneously is common, as some partners still run 2.1.1.
Smart charging
AFIR mandates that all publicly accessible stations built after April 13, 2024, or renovated after October 14, 2024, support smart charging, specifically the ability to adjust charging intensity in real time based on external signals. This is the minimum bar. Load management across multiple chargers and grid integration with the local DSO go further but are not required for basic compliance. NEVI similarly requires secure grid communication capability. In both cases, OCPP 2.0.1’s smart charging profiles are the standard implementation path.
Where CPOs Get Stuck
Most implementation challenges come down to three things.
Vendor gaps. OCPP 2.0.1 compliance on paper doesn’t mean full implementation in practice. Push vendors on specific features, e.g. TLS 1.2+, smart charging profiles, PnC transaction flows, and DATEX II data export, before signing contracts.
PKI readiness. ISO 15118 requires a working certificate infrastructure that most CPOs haven’t had to think about before. Connecting to the right certificate pool, ensuring your CSMS handles the full provisioning flow is non-trivial and often underestimated, and validating this end‑to‑end through interoperability testing.
Version fragmentation. Running OCPI 2.1.1 and 2.2.1 simultaneously, or supporting both ISO 15118-2 and legacy RFID authentication in parallel, adds operational complexity that needs to be planned for from the start.
The Bottom Line
NEVI’s funding future is uncertain. AFIR’s requirements are not. But in practice, both regulations converge on the same technical foundation: OCPP 2.0.1, OCPI 2.2.1, ISO 15118-2 with PnC, ISO 15118-20 for smart charging capability, and data infrastructure that can feed National Access Points in real time (a global trend).
CPOs that build to these standards today are compliant in all markets, positioned for ISO 15118-20 and the V2G transition, and far less exposed to the political volatility surrounding individual funding programs.
Metergram specializes in OCPP, OCPI, and OpenADR implementation for CPOs and CSMS vendors. Irdeto provides PKI, certificate management, and cybersecurity solutions for EV charging infrastructure. This article was written jointly.