Charging without a charging card: your rights under AFIR

Short answer: since 13 April 2024 the EU regulation on alternative fuels infrastructure, known as AFIR (Regulation (EU) 2023/1804), has applied across the EU. It gives you the right to charge without a charging card or subscription at every publicly accessible charge point, and to know what it costs before you start. New charge points must accept a widely used payment method, and from 1 January 2027 older charge points of 50 kW or more along the TEN-T road network must also have a payment card reader or contactless reader. If you do charge with a charging card, your provider must show you the full price beforehand, including roaming costs and its own fees. There is no specific Dutch AFIR supervisor yet. Until there is, a complaint goes through the provider and ACM ConsuWijzer, the consumer desk of the Netherlands Authority for Consumers and Markets (ACM).

What is AFIR and which charge points does it cover?

AFIR is an EU regulation. It is binding in its entirety and directly applicable in all Member States, including the Netherlands. Under Article 26, AFIR has applied since 13 April 2024.

The rules for charge points are in Article 5 and cover publicly accessible charging points. Those are not just chargers on the street. Under the definition in Art. 2 point 45, infrastructure on private property also counts, as long as the site is open to the general public, such as a public car park. According to the European Commission, the requirements of Article 5 apply to all publicly accessible charging points, not only along motorways, unless a provision says otherwise (Q&A 5.2).

Two parties come up throughout this article:

• The operator (Art. 2 point 39): the company that manages the charge point and provides the charging service. The price the operator charges when you charge without a contract is called the ad hoc price (Art. 2 point 2).
• The charging card provider (in AFIR: mobility service provider, Art. 2 point 36): the company behind your charging card or charging app, which sells charging services to you.

Ad hoc charging: always without a contract (Art. 5(1))

AFIR Art. 5(1) requires operators to offer ad hoc charging at every publicly accessible charging point they operate. Under Art. 2 point 47, ad hoc means you buy the charging session without registering, without a written agreement and without a commercial relationship that goes beyond buying that session. This duty applies to all publicly accessible charging points, older ones included. Only charging points where charging is free are excluded.

In its questions and answers on AFIR, the European Commission has clarified two things:

• An app with an account does not count. If you have to install an operator’s or charging card provider’s app and create an account, you enter into an agreement that goes beyond the charging session. Such an app is therefore not an ad hoc payment option (Q&A 5.9).
• Cash only is not enough. If you can only pay cash for an ad hoc session, the charge point does not meet Art. 5(1) (Q&A 5.7).

The Netherlands already had a similar rule. Article 4 of the Dutch Alternative Fuels Infrastructure Decree (2017) requires a publicly accessible charging point to offer an ad hoc charging service for which you do not need a contract with an electricity supplier or with the operator. That decree still applies; the current version has been in force since 1 January 2026.

How you pay without a charging card: which charge points, since when

Which payment method the operator must accept depends on the charging point’s power output, its location and when it was deployed.

Charging point	Applies since	What the operator must offer
Every publicly accessible charging point where you pay	13 April 2024	Ad hoc charging without registration or a contract. For points deployed before 13 April 2024, AFIR does not prescribe a specific payment method (apart from the 2027 rule below)
Deployed from 13 April 2024, below 50 kW	13 April 2024	A payment instrument widely used in the EU, via a payment card reader, a contactless reader or a secure online payment, for example with a QR code
Deployed from 13 April 2024, 50 kW or more	13 April 2024	A payment card reader or a contactless reader; AFIR only lists the online option for points below 50 kW
50 kW or more along the TEN-T road network or in a safe and secure parking area, including points deployed before 13 April 2024	1 January 2027	A payment card reader or a contactless reader

A few details from the regulation and the Commission’s guidance:

• Deployed means, according to the Commission, installed, connected to the grid and able to charge vehicles (Q&A 5.4).
• One terminal for several points is allowed: a single payment terminal can serve several charging points in a charging pool (Art. 5(1), fourth subparagraph).
• Your phone as a payment card. A contactless reader does not have to read a physical card; a payment card in a mobile wallet is equally sufficient (Q&A 5.9).
• A QR sticker can comply, even a static one, as long as the code is readable and the payment is secure (Q&A 5.10).

What changes on 1 January 2027?

From 1 January 2027, operators must ensure that all their publicly accessible charging points of 50 kW or more along the TEN-T road network or in a safe and secure parking area have a payment card reader or a contactless reader. This includes charging points deployed before 13 April 2024 (Art. 5(1), third subparagraph). For these fast chargers, a QR code alone is then no longer sufficient.

What does not change:

• Charging points of 50 kW or more deployed before 13 April 2024 that are not along the TEN-T road network or in a safe and secure parking area are not covered by this retrofit duty.
• Charging points below 50 kW are not covered either. New points below 50 kW may keep offering ad hoc payment via a secure online payment, such as a QR code.

Could this still change? The European Commission must review AFIR by 31 December 2026 (Art. 24(2)). Among other things, it will assess whether the electronic payment means in Art. 5(1) are still appropriate and whether the price components in Art. 5(4) give consumers clear and sufficient information. According to the NAL, a Commission proposal for a revision is expected at the end of 2026. As of 27 September 2026, Article 5 has not been amended.

Automatic authentication: you can always opt out (Art. 5(2))

Some charge points start automatically as soon as you plug in, for example with plug and charge or autocharge. If an operator offers such automatic authentication, Art. 5(2) gives you the right not to use it at any time. You can then charge ad hoc or use another contract-based option offered at that charging point. The operator must show this option clearly and offer it conveniently at each charging point with automatic authentication.

Price before you charge: 50 kW or more versus below 50 kW (Art. 5(3) and (4))

Art. 5(3) applies to all operators: their prices must be reasonable, easily and clearly comparable, transparent and non-discriminatory. An operator may not use prices to discriminate between end users and charging card providers, or between charging card providers. Price differences are only allowed if they are proportionate and objectively justified. According to recital 33 of AFIR, reasonable means not exceeding the costs incurred plus a reasonable profit margin (Q&A 5.12).

How you see the ad hoc price depends on the power output (Art. 5(4)):

	50 kW or more	Below 50 kW
How the ad hoc price is built	Based on the price per kWh delivered. In addition, only an occupancy fee per minute is allowed, to discourage long occupancy	AFIR does not prescribe a structure; the operator chooses the price components (Q&A 5.16)
How you see the price	Visibly shown at the station, for example on a screen or sticker. A mere reference to a website is not enough (Q&A 5.19)	Clearly and easily available at the station. This may be digital, for example via a QR code or link at the charger (Q&A 5.19)
Order	Price per kWh and any occupancy fee per minute	Price per kWh, per minute, per session, then any other component
Which charging points	Deployed from 13 April 2024	All charging points below 50 kW, existing ones included, since 13 April 2024 (Q&A 5.20)

The Commission adds two points for charging points of 50 kW or more. Per-transaction fees are excluded at these points, because the ad hoc price must be based on kWh and only an occupancy fee may be added (Q&A 5.21). And an occupancy fee that applies from the start of the session does not prima facie appear proportionate, because you would then also pay when you only stay as long as charging takes (Q&A 5.18).

Note: these rules concern the operator’s ad hoc price. If you charge with a charging card, you pay your provider’s price. According to the Commission, the requirement to base the price on kWh only applies to ad hoc charging (Q&A 5.17). The rules below apply to charging cards.

What your charging card provider must show (Art. 5(5))

AFIR Art. 5(5) sets requirements for charging card and charging app providers:

• Reasonable, transparent and non-discriminatory prices, and the same applies to their own fees.
• All price information before the start. Before you start a charging session, the provider must make all price information for that session available through freely available, widely supported electronic means. A free app or a public website can be sufficient, according to the Commission (Q&A 5.28).
• Every price component listed separately, including any e-roaming costs and the fees the provider charges itself. According to the Commission, the aim is that you can compare the ad hoc price with your charging card price beforehand (Q&A 5.27).
• No extra charge for charging in another EU country. Providers may not add extra charges for cross-border e-roaming. According to the Commission, this means you pay the same roaming fees whichever EU country you charge in (Q&A 5.24).

General Dutch consumer rules apply as well. According to the ACM, the charge point or charging card provider must tell you beforehand what you pay per kWh, including taxes and all mandatory costs, and after charging you must be able to see how much electricity you used and what you paid for it. Providers may set their own tariffs, and the tariff can differ per charging card or contract. The NAL also reports that in autumn 2024 the Dutch House of Representatives adopted the Veltman and Bamenga motion to make charging card tariffs available digitally and publicly as well; this is being worked out in 2026.

How a charging card price is built up, with subscription, start fee and surcharge, is explained in What does a charging card really cost?. An independent comparison of charging cards is on compare charging cards.

Open price data: DOT-NL (Art. 20)

Since 14 April 2025, operators must make static and dynamic data on their publicly accessible charging points available free of charge, including the current ad hoc price, availability and whether the point is working (Art. 20(2)). They do so through an interface (API) with free and unrestricted access (Art. 20(3)). Since the amendment by Delegated Regulation (EU) 2025/671, the payment options, such as a payment card reader or contactless reader, are part of these data too.

Member States publish these data through a national access point. In the Netherlands this is DOT-NL, run by the National Road Traffic Data Portal (NDW) on behalf of the Ministry of Infrastructure and Water Management. According to NDW, the data are free for everyone, for example for price comparisons or charging maps. Data quality is ultimately the responsibility of the party supplying the data, according to NDW. The NAL reports that DOT-NL became operational in 2025, that several operators supply current tariff information and that coverage and quality are being improved in 2026. In addition, the Commission must set up a common European access point by 31 December 2026 (Art. 20(5)).

Current, dated price examples per network and per city, with sources, are on our charging prices page. How those prices come about is explained in What does public charging cost in 2026?.

What if a charge point or charging card does not comply?

AFIR applies directly, but Member States must organise supervision themselves. Under Art. 5(6), their authorities must regularly monitor the market, in particular whether operators and charging card providers comply with paragraphs 3 and 5. The Netherlands is preparing the Act implementing EU rules on alternative fuels infrastructure for this. The draft was open for consultation from 24 July to 12 October 2025. It gives the ACM, provincial executives and municipal executives, among others, a role as supervisor, with powers such as an order subject to a penalty and an administrative fine, and for the ACM a binding instruction. According to the Ministry of Infrastructure and Water Management, the plan is for the act to take effect in early 2028. As of 27 September 2026, no specific Dutch AFIR supervisor has therefore been designated by law.

What you can already do:

1. Record it. Take a photo of the charge point with its ID number and of the price information, or its absence. Keep the date, time, your invoice or a screenshot of the app.
2. Complain in writing to the company you paid. ACM ConsuWijzer advises sending an email or letter to the charging card provider, for example if the bill is higher than the price you were given beforehand. If you charged ad hoc, that company is the operator.
3. If you cannot resolve it together, ACM ConsuWijzer says you can seek redress another way.
4. Report it to ACM ConsuWijzer. The ACM supervises consumer law, including for charging. Since 1 December 2020 it has checked whether charge point and charging card providers make the price elements of a session clear beforehand. According to the NAL action plan, the relevant rules are the Dutch Price Indication Decree (Arts. 3 and 4) and the unfair commercial practices rules in the Dutch Civil Code (Art. 6:193d). Your report helps the ACM see which companies break the rules.
5. Can you not charge without a contract at all? Then Article 4 of the Dutch Alternative Fuels Infrastructure Decree is also relevant. According to its 2017 explanatory memorandum, the Netherlands Food and Consumer Product Safety Authority (NVWA) supervises that article. We could not establish from the sources consulted whether that division of tasks is unchanged.

At EU level, the Commission can assess whether a Member State meets its monitoring duty, for example on the basis of a complaint (Q&A 5.30). That concerns the Member State, not an individual operator or charging card provider.

In short

• AFIR has applied directly in the Netherlands since 13 April 2024. Every publicly accessible charging point where you pay must allow ad hoc charging, without registration, a contract or an app with an account (Art. 5(1)).
• New charging points accept a widely used payment method; from 50 kW via a payment card reader or contactless reader. From 1 January 2027 this also applies to older points of 50 kW or more along the TEN-T road network.
• From 50 kW, the kWh price and any occupancy fee are shown visibly at the station; below 50 kW the full price, in a fixed order, may also be made available digitally (Art. 5(4)).
• Charging card providers show every price component beforehand, including roaming costs and their own fees, and charge nothing extra for roaming in another EU country (Art. 5(5)).
• Ad hoc prices are open data via DOT-NL (Art. 20). A specific Dutch AFIR supervisor will follow with the implementing act, planned for early 2028; until then you complain to the provider and report it to ACM ConsuWijzer.