The January 8th Wake-Up Call

The January 8, 2026, mandate for ISO 15118-2 on new public AC chargers has officially moved “smart charging” from a roadmap feature to a legal requirement. For many operators, this date marks the end of a frantic compliance sprint. However, forward-thinking CTOs view this not as a finish line, but as the deployment of a critical grid asset.

You have not just installed a “Plug & Charge” feature for driver convenience. You have installed the secure authentication layer necessary to participate in the Network Code on Demand Response (NC DR) markets opening next year. The strategic challenge for 2026 is no longer about installing hardware; it is about building the software architecture that turns this compliance cost into a revenue generator.

The AFIR Data Challenge

While the industry focuses on the hardware rollout, the immediate operational threat lies in data reporting. AFIR demands that dynamic pricing and availability data flow seamlessly to National Access Points to ensure transparency.

This requirement creates a significant “Data Trap” for operators using fragmented systems. Ad-hoc payment terminals, now mandatory for many chargers under Article 5, often generate data that lives in isolation from the backend Charging Station Management System (CSMS). If your payment terminal reports one price while your app reports another, you face a compliance failure.

The pragmatic solution is to treat payment terminals, mobile apps, and roaming partners (via OCPI) as inputs to a single, unified data engine. This architecture ensures that pricing changes are propagated instantly across all channels, satisfying the strict 1-minute dynamic data update requirement without manual intervention.

The Strategic Bridge: Preparing for 2027 Revenue

Looking ahead, the NC DR is set for national enforcement by 2027. This regulation fundamentally changes the market by enabling standardized, market-based procurement of flexibility from distributed assets.

To capture this value, your infrastructure must be bidirectional in both power and data. Starting January 1, 2027, ISO 15118-20 becomes mandatory for all new public and private Mode 3 chargers. This standard supports V2G (Vehicle-to-Grid) capabilities, allowing fleets and CPOs to monetize their capacity.

The missing link for most platforms is the “Protocol Bridge.” You need a translation layer that converts high-level grid signals (via OpenADR) into specific, granular charger commands (via OCPP 2.0.1 and ISO 15118-20).

This is not theoretical. In our work with Flux, we engineered a robust ISO 15118 architecture to successfully execute V2X energy exchange. This real-world validation proves that the technology stack is ready to handle the complex, bidirectional power flows required by the 2027 grid, transforming the vehicle from a passive load into an active energy asset.

The Business Model: Build, Buy, or Own?

As you architect this solution, the commercial model matters as much as the code. SaaS platforms remain a sensible choice for new entrants or smaller networks, offering speed and simplicity.

However, for high-growth tech companies and large-scale CPOs, the traditional SaaS model introduces a “scaling penalty.” Per-charger monthly fees act as a tax on your growth, eroding margins as you deploy thousands of AFIR-compliant units.

The alternative is a Perpetual License model. We demonstrated the model’s viability by building a Scalable OCPP Server for a major North American network. By owning the core IP, the operator successfully managed “heavy-scale” loads—simulating 10,000 connectors—while decoupling their software costs from their hardware growth. This architecture empowers you to deploy custom NC DR logic on your own timeline, free from a vendor’s roadmap constraints.

Compliance as a Competitive Asset

The infrastructure you build for AFIR today is the Virtual Power Plant (VPP) asset of tomorrow. By prioritizing interoperability now, you secure your license to operate in the flexibility markets of 2027.

We recommend auditing your current software stack not just for today’s compliance, but for tomorrow’s connectivity. Ensure your “Protocol Bridge” is ready to translate regulatory mandates into grid revenue.