On January 1, 2027, the EU's charging rules move from asking chargers to speak an older version of the ISO 15118 charger-to-car protocol to requiring the newer one. Under Commission Delegated Regulation (EU) 2025/656, which supplements the Alternative Fuels Infrastructure Regulation (AFIR), ISO 15118-20 becomes mandatory from that date. About ten weeks before the deadline, the charging industry's main standards group says the rule can't yet be met in a verifiable way and has asked the European Commission to push it back a year.
The sources reviewed for this article show no change to the date. They do show the Commission has opened a process to explain how compliance will be shown, checked and enforced, and that guidance is not due for endorsement until late November.
What the regulation requires, and when
CharIN's position paper, Clarifying ISO 15118 Implementation under AFIR (version 2, dated August 3, 2026), sets out the timeline in two steps:
- From 2026: new or upgraded publicly accessible charging equipment (EVSE) must implement ISO 15118 parts 1, 2, 3, 4 and 5. This is the established protocol family behind features such as Plug & Charge.
- From January 2027: ISO 15118-20 becomes mandatory. According to CharIN's paper, this applies to both private and public EVSE.
ISO 15118-20 is the newer version of the standard. CharIN wants a phased rollout that puts three items first: TLS 1.3 (the encryption layer), Plug & Charge (automatic authentication and billing once the cable is connected) and the Megawatt Charging System (MCS). It would leave more complex functions, including bidirectional charging and certain private charging scenarios, for later.
Why CharIN says the date doesn't work
The position paper gives three main reasons.
There is no defined way to prove compliance. According to CharIN, the delegated regulation does not say how conformity is to be assessed. A manufacturer or operator can claim ISO 15118-20 support, but the regulation does not say who checks that claim or how.
AC charging has no certification scheme. CharIN says no dedicated certification scheme currently exists for AC EVSE, which makes it hard to demonstrate compliance for that equipment.
Fully compliant hardware isn't shipping at scale. CharIN says fully compliant EVSE solutions are not yet available at scale, partly because of dependencies on complementary IEC standards that are still under development.
The paper also mentions a related timing problem. IEC 61851-23 Edition 3, a companion standard for DC charging, is not expected before the end of 2027. CharIN strongly recommends ISO/PAS 15118-202:2025 be implemented alongside ISO 15118-2 and ISO 15118-20.
Based on all this, CharIN recommends postponing the ISO 15118-20 software-implementation mandate from January 1, 2027 to January 1, 2028. The paper cites CharIN's April 22, 2026 response to the Commission's AFIR review for this recommendation.
The testing bottleneck, by the numbers
An analysis by Chargalytics describes a CharIN position paper published April 28, 2026, on test-lab capacity. According to Chargalytics' summary of that paper:
- Fewer than ten labs worldwide are accredited for full ISO 15118-20 conformance testing.
- Lead times at those labs run six to nine months.
- Formal AC conformance test cases are not expected before late 2027.
Those figures are CharIN's, as reported by Chargalytics; the April 28 paper itself was not among the documents reviewed. If they are accurate, a manufacturer that booked a lab slot in the spring of 2026 could still be waiting for results close to the deadline. For AC equipment, the formal test cases would not exist until about a year after the mandate starts.
What Brussels is doing about it
According to a September 25, 2026 policy update from AMPECO, a charging-software vendor, the Commission's transport directorate (DG MOVE) convened an ad hoc working group under the Sustainable Transport Forum (STF) on September 2. Its job is to produce Q&A guidance on how compliance with ISO 15118-20 is demonstrated, verified and enforced, including whether manufacturer self-declarations will suffice.
AMPECO describes the schedule this way:
- Working rounds through mid-October
- Then a consultation with Member States
- Final Q&A due for endorsement at the STF Plenary on November 25
AMPECO also reports that an amendment to ISO 15118-20 was published in July, which it says settled the standard's content. Separately, AMPECO calls it an open question under AFIR whether Autocharge, a simpler method that identifies a car by an identifier rather than by Plug & Charge's certificate-based authentication, can run alongside Plug & Charge at new charging points. It says industry opinion is split, and that it is following the question through the STF working group.
AMPECO is a vendor, not a regulator, and the timeline above is its account. The sources reviewed for this article do not say whether the Commission plans to change the January 2027 date. As of this writing, the date in the delegated regulation stands in those sources, and the guidance meant to clarify compliance is due about five weeks before it takes effect.
Mandated isn't the same as used
The Chargalytics analysis points out that the regulation mandates the protocol, not the use case: chargers must implement these protocols, but drivers and networks are not required to use them. Germany's federal charging registry shows how big that gap is.
According to Chargalytics, the registry lists 31,865 public charging sites, and 1,018 of them declare Plug & Charge support. That is 3.2%. The analysis, which Chargalytics corrected on August 19, 2026, does not give an exact snapshot date for these totals. They are site-level declarations in the registry as reported by Chargalytics. They are not counts of individual connectors and not audited measurements of whether Plug & Charge works at each site. Chargalytics itself says the figure measures which operators filled in the form, not where Plug & Charge works.
Plug & Charge is part of the ISO 15118 family that has been required on new and upgraded public chargers since 2026. A low share of declared sites is therefore not evidence that anyone is breaking the rules: the mandate applies to newly installed or upgraded equipment, not to the whole installed base.
What It Means for Drivers
Nothing in these sources changes how a driver starts a session today. The regulation sets rules for the charging equipment. It does not set rules for drivers or for which payment method a driver has to use.
- Before January 1, 2027: new or upgraded public chargers in the EU must implement ISO 15118 parts 1–5, according to CharIN's reading of the regulation. That family includes Plug & Charge. Whether a specific charger offers it to you also depends on your car, your contract or app, and the operator.
- From January 1, 2027 (unless the date changes): ISO 15118-20 becomes mandatory for EVSE, according to CharIN's paper. CharIN has asked for the software requirement to start on January 1, 2028 instead. No decision on that request appears in the sources reviewed here.
- Finding Plug & Charge: in Germany, Plug & Charge was declared at 3.2% of public sites in the federal registry, according to Chargalytics' 2026 analysis. Most drivers will likely keep using a card or app at most locations for now.
- What to watch: the Sustainable Transport Forum plenary on November 25, where the Q&A guidance on compliance is due for endorsement, according to AMPECO. Whether Autocharge can be offered alongside Plug & Charge at new points is an open question AMPECO is tracking through that group.
Home and workplace charger owners should be aware that CharIN's paper describes the 2027 ISO 15118-20 requirement as covering private as well as public EVSE. Questions about a specific unit should go to the manufacturer. Any installation or electrical work should be done by a licensed electrician following the manufacturer's instructions.
