The Post-Compliance Reality

The grace period for the electric vehicle (EV) charging industry has officially expired. With the April 2025 deadline for the EU’s Alternative Fuels Infrastructure Regulation (AFIR) now passed, and the U.S. National Electric Vehicle Infrastructure (NEVI) funds fully allocated, the market has shifted from a phase of rapid deployment to one of enforced utilization.

The primary threat facing Charge Point Operators (CPOs) and fleet managers has evolved beyond “range anxiety” or hardware availability. The new danger is the risk of “Zombie Infrastructure”—assets that are physically functional but digitally obsolete because they fail to meet strict new data reporting standards (like DATEX II in Europe) or federally mandated uptime requirements (97% in the U.S.).

For technical leaders, the mandate is clear: interoperability has transformed from a convenience feature into the essential “Operating System” of a compliant, profitable network. This paper argues that natively integrating global standards—specifically OCPI 2.2.1, ISO 15118, and SAE J3400—remains the only viable defense against regulatory penalties and the singular path to accessing “Smart Charging” revenue streams that protect long-term ROI.

From Planting Flags to Making Them Work

For the last decade, the industry measured success by the number of plugs in the ground. The market now operates in a “Post-Compliance” reality where the quality of the connection outweighs the quantity of connectors.

In Europe, the activation of AFIR’s data provision mandates has turned “dumb” chargers into a legal liability. Operators who cannot stream real-time dynamic data to National Access Points face immediate regulatory exposure. In the United States, the convergence of NEVI funding rules and the hardware shift to the North American Charging Standard (NACS/J3400) has created a similar “quality wall.” Networks must now transparently report the specific cause of any charging failure—down to the exact error code—to maintain access to millions in federal funding.

While Europe prioritizes “Data Sovereignty” and the U.S. focuses on “Reliability,” both markets demand the same technical foundation: a robust, standardized software layer capable of managing complex, bi-directional data flows. The winners of the next cycle will be the operators who build the most resilient, interoperable networks.

The European Landscape: The Data Floodgates Open

With the April 2025 deadline for AFIR now in the rearview mirror, the regulatory conversation in Europe has fundamentally changed. The initial focus on ad-hoc payment compliance has ceded ground to the far more complex reality of data sovereignty and standardized reporting.

The New “Data Provision” Reality

Under the active provisions of AFIR (specifically Article 20), Charge Point Operators (CPOs) have expanded their role from energy providers to mandated data publishers. The mandate requires dynamic data—availability status, pricing, and ad-hoc costs—to be made accessible to National Access Points (NAPs) without cost or barrier.

The technical challenge is significant. To ensure a unified digital map of Europe’s charging infrastructure, regulators increasingly require this data in the complex DATEX II standard (or compatible OCPI implementations). For internal engineering teams, this creates a heavy maintenance burden: building and sustaining a live, compliant reporting engine that translates proprietary internal data structures into the rigid schemas required by EU regulators. Maintaining this data stream is now a condition of operation.

The Hardware Cliff: ISO 15118

Looking ahead to 2026, the technical bar rises again with the move toward mandatory support for ISO 15118 (the protocol underpinning “Plug & Charge” and Vehicle-to-Grid communication).

While currently a competitive differentiator, ISO 15118 support is rapidly becoming a prerequisite for new hardware deployments. The standard enables secure, automated authentication and serves as the foundational layer for smart energy services. Infrastructure deployed today without a software stack capable of handling ISO 15118’s complex certificate handling and bi-directional communication risks becoming the “stranded asset” of tomorrow—physically capable of charging, but digitally excluded from the automated, secure ecosystem that corporate fleets and premium automakers demand.

The Interoperability Imperative

This regulatory environment creates a binary outcome for CPOs. Operators attempting to patch together legacy systems or rely on basic “dumb” charging protocols face exclusion from the premium market and increasing regulatory scrutiny. The sustainable path requires implementing a certified, standards-based software layer—specifically OCPI 2.2.1 for roaming and data provision and ISO 15118 for vehicle communication—to serve as a regulatory shield, automating compliance and insulating the core business from the complexity of evolving mandates.

The US Landscape: NEVI, NACS, and the Quality Wars

While Europe focuses on data sovereignty, the United States prioritizes uptime. The rollout of the National Electric Vehicle Infrastructure (NEVI) formula program has fundamentally altered the compliance landscape. Federal funding has shifted from a grant to a strict performance-based contract, enforceable through specific digital reporting requirements.

NEVI’s Digital Strings: OCPI as a Requirement

Title 23 CFR 680 requires digital capability to match physical infrastructure. To ensure the “long-term stewardship” of federally funded assets, the regulation requires chargers to communicate effectively with the charging network to enable remote monitoring and secure payment. Crucially, the guidance points directly to OCPI 2.2.1 as the required standard for charger-to-network communication.

This distinction is critical. NEVI funds are contingent on a 97% uptime guarantee, verifiable through data. A proprietary, “black-box” backend that cannot transparently report session data or granular error logs will fail to meet these reporting standards. The interoperability layer—specifically the ability to share standardized uptime data—defines the difference between a compliant, funded site and a non-compliant liability.

The “J3400” Revolution: A Software Challenge

The industry-wide shift to the North American Charging Standard (NACS), now formalized as SAE J3400, represents a sophisticated software challenge rather than a purely physical change.

The NACS ecosystem relies heavily on the “Plug & Charge” experience pioneered by Tesla. To replicate this seamless experience on non-Tesla hardware—especially when using NACS adapters on CCS vehicles—the underlying software stack must support ISO 15118. While the physical adapter connects the power, ISO 15118 manages the critical handshake, authentication, and billing. A software platform capable of handling these complex, encrypted communications converts a “NACS-compatible” charger from a piece of hardware into a fully functional part of the ecosystem.

The Quality Mandate: The ChargeX Effect

Compounding these pressures is the push from the ChargeX Consortium to standardize error reporting. With US charger failure rates historically hovering near 25%, the market demands granular visibility into the specific cause of session failures. Leading CPOs must now implement the “Minimum Required Error Codes” taxonomies to rapidly diagnose issues—whether they stem from the vehicle, the grid, or the payment terminal. This level of diagnostic precision requires a modern, standardized OCPI implementation designed for deep observability.

Requirement European Union (AFIR) United States (NEVI)
Primary Goal Data Sovereignty: Transparent pricing & dynamic data availability. Reliability: Verifiable network uptime & long-term stewardship.
Critical Deadline April 14, 2025 (Data Provision Start) FY 2024-2025 (Funding Allocation & Compliance)
Data Standard DATEX II (Mandated for National Access Points) OCPI 2.2.1 (Mandated for Charger-to-Network)
Uptime Mandate Not explicitly defined in AFIR (varies by member state). 97% Uptime (Strictly enforced for funding eligibility).
Penalty Risk Direct fines & non-compliance notices from EU member states. Loss of Federal funding & “clawback” of allocated grants.
Key Retrofit Need Software Layer: Must translate legacy data to DATEX II schemas. Diagnostics: Must report granular error codes (ChargeX) to prove uptime.

The Universal Business Case: Turning Volts into Value

Whether operating a logistics hub in Arizona or a retail network in Germany, the fundamental economics of EV infrastructure remain consistent. While selling electrons often yields low margins, managing power offers a high-value strategy. The true ROI of interoperability lies in the ability to control when and how that energy is delivered.

Smart Charging: The Financial Firewall

For fleet operators, the “Demand Charge”—a utility fee based on the highest peak power usage within a billing cycle—remains the primary threat to profitability. In many commercial contexts, a single unmanaged charging session where multiple high-power trucks plug in simultaneously can spike peak demand, triggering fees that account for 30-70% of the total monthly energy bill.

Interoperability serves as a financial firewall against these costs. By utilizing OCPI 2.2.1, operators can implement standardized Smart Charging (V1G) profiles. This allows the central Charging Station Management System (CSMS) to dynamically throttle charging speeds across the network based on real-time grid signals or pre-set tariff schedules. The charging infrastructure transforms from a “dumb” load into an intelligent asset that aligns consumption with the lowest cost of energy.

The Unified Depot: Integrating On-Site Generation

Asset value increases further by breaking down the silos between the vehicle and the building. For large-scale depots, relying solely on grid capacity often proves physically impossible or financially prohibitive. The solution is the “Unified Depot”—a site where EV charging is balanced against on-site solar generation and Battery Energy Storage Systems (BESS).

This architecture requires a CSMS that can fluently speak OCPI to the fleet and integrate with an Energy Management System (EMS) monitoring the solar arrays. When these systems communicate, a fleet can prioritize charging from “free” solar electrons during the day or discharge from battery storage during peak evening windows. This integration transforms the depot from a massive energy consumer into a self-balancing microgrid, drastically reducing OpEx.

From Closed Loop to Open Market

Finally, interoperability enables the “Mixed-Use” revenue model. Many private fleet hubs sit idle for 10-12 hours a day. By implementing secure roaming protocols, asset owners can open these private chargers to the public or third-party fleets during off-hours. This strategy turns a dormant cost center into a revenue-generating public asset, maximizing the Revenue Per Available Resource (RevPAR) without additional hardware investment. This flexibility requires a backend capable of handling complex, multi-party roaming reconciliations—a capability that proprietary, closed-loop systems fail to provide.

The Build vs. Buy Reality: The Engineering Trap

For many technology-driven companies, the instinct is to build. While many perceive building proprietary software as a strength, in the post-2025 landscape, building a compliant interoperability layer from scratch has become a speed-to-market liability rather than a core competency.

The “Hidden” Maintenance Burden

The complexity of modern interoperability resides in the ongoing maintenance of evolving standards rather than the initial connection. Building a proprietary OCPI 2.2.1 node today means committing a dedicated engineering team to update it for OCPI 3.0 tomorrow, while simultaneously building separate modules for NEVI reporting logs and DATEX II schema conversions.

Internal teams frequently underestimate this scope. A “home-grown” solution typically takes 12 to 18 months to reach the maturity required for commercial certification. In a market where competitors are already live with AFIR-compliant data streams and NACS integration, a year-long development cycle represents a strategic risk that few CPOs can afford.

The Accelerator Advantage: Speed Without Lock-In

Operators seeking to avoid the risks of internal builds often evaluate SaaS platforms. While SaaS solutions are often the right choice for smaller networks or those requiring immediate, standard functionality, they can become restrictive for large-scale enterprises. The traditional rental model—paying per-connector or per-transaction fees—can erode margins as a network expands, while the “black-box” nature may limit deep asset control.

A third path exists: the Accelerator Model. This approach provides a pre-certified, white-label software foundation deployed into the client’s own cloud environment, combining the speed of SaaS with the ownership of a custom build.

  • Financial Strategy: The model shifts software investment from a scaling Operating Expenditure (OPEX) to a fixed Capital Expenditure (CAPEX). By securing the core technology via a one-time license, operators convert what would be a perpetual, variable rental cost into a capitalized asset on their balance sheet. This structure eliminates “scaling penalties,” ensuring that software costs remain flat even as the network grows from 100 to 10,000 chargers.
  • Speed: Deployment time drops from 18 months to as little as two months, enabling immediate compliance with AFIR and NEVI deadlines.
  • Control: Clients receive the source code under a perpetual license. This ensures complete independence; the model eliminates vendor lock-in, removes per-charger scaling penalties, and grants full freedom to customize the IP.
  • Reliability: The underlying architecture is proven to scale to over 10,000 simultaneous connections, eliminating the “scaling jitters” that plague early-stage internal builds.
Feature Traditional SaaS (Rental) Codibly Accelerator (Ownership)
Financial Model OPEX (Recurring): Perpetual monthly fees per charger. Costs rise as you scale. CAPEX (One-Time): Fixed license fee. Costs remain flat regardless of network size.
Asset Ownership Vendor Owned: You rent the capability. “Black Box” architecture. Client Owned: You own the Source Code. Complete independence.
Customization Low: Limited to vendor roadmap & standard API config. Unlimited: Full freedom to build custom IP & features on top.
Data Privacy Shared: Data resides on vendor’s cloud/multi-tenant env. Sovereign: Deployed in your own cloud (AWS/Azure).
Speed to Market Fast (1-2 Months): Plug-and-play standard features. Fast (2-3 Months): Pre-certified core with custom deployment.
Best For… Small-to-Mid networks (<500 chargers) prioritizing simplicity. Scaling Enterprises (>500 chargers) prioritizing control & margin.

The “Global Operating System”

The global e-mobility market has bifurcated into two high-pressure environments. Europe emphasizes Data Sovereignty—the ability to fluently report complex grid and pricing data to regulators. The United States prioritizes Reliability—the mandate to maintain 97% uptime and support the new NACS hardware ecosystem.

While the regulations differ, the solution is singular. Success in the next decade of the energy transition belongs to the operators who build their networks on a robust, interoperable “Global Operating System”—one capable of handling the heavy lifting of compliance so that the business can focus on innovation.

The era of planting flags has ended. The era of the intelligent, profitable asset has begun.