Charging is now a payments business. Most operators are not staffed for that.
The payment layer of an EV charging estate decides whether a site is compliant, whether it is defensible against fraud, and whether the margin on a kWh survives contact with scheme fees.
The obligation
Under Regulation (EU) 2023/1804 — the Alternative Fuels Infrastructure Regulation, in application since 13 April 2024 — operators of publicly accessible recharging points must allow drivers to recharge on an ad-hoc basis: no app, no account, no prior contract.
The obligation itself is not power-gated. What the power rating changes is how you may accept the payment:
- 50 kW and above — a payment card reader or a contactless device capable of reading payment cards.
- Below 50 kW — the above, or a secure internet-based method such as a QR code linking to a payment page.
A retrofit deadline follows on 1 January 2027: publicly accessible points of at least 50 kW along the TEN-T network and at safe and secure parking areas must support the required electronic payment options, including points installed before April 2024.
Location, accessibility and power rating all bear on which obligations attach to a given point, so estates need assessing site by site rather than as a single fleet.
Why it bites
Done badly, the payment layer quietly eats the margin on every kWh you sell — or fails the compliance test at exactly the wrong moment.
That single ad-hoc requirement drags a charging operator into acquirer selection, terminal certification, offline authorisation, pre-auth and capture logic, chargeback exposure, PCI scope, and per-transaction economics on low-value sessions. None of it is adjacent to the skills that build and energise a charging site.
Where I help
- Acquiring and PSP selection
- Commercial terms, pricing structure, what to negotiate and what not to concede. Output: a selection paper with a recommendation and the reasoning behind it.
- Payment architecture for unattended terminals
- Pre-authorisation strategy, offline handling, deferred capture, refund and dispute flows. Output: an architecture recommendation your vendors can build to.
- Unit economics
- The true cost per session across scheme fees, acquiring, hardware, connectivity and failed transactions. Output: a session-level economic model you keep.
- Compliance mapping
- The ad-hoc payment obligation, SCA treatment, and PCI DSS scope reduction across the estate. Output: a gap assessment against the obligations that apply to your specific sites.
- Fraud and abuse
- The patterns unattended outdoor terminals attract, and the controls that stop them without killing conversion. Output: a control design with the conversion cost of each measure stated.
Advisory only. Delvant does not perform certification, audit or penetration testing.
Who for
Charging point operators, e-mobility service providers, site hosts with charging estates, PSPs entering the vertical, and investors doing commercial diligence on any of the above.
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