Electromobility CPO and eMSP: Roles, Interoperability, and the New Market Logic through AFIR

With the AFIR, the market logic in public charging infrastructure is shifting: access to charging points becomes easier, prices more transparent, operator requirements increase, and the roles of CPO and eMSP must be more clearly defined than ever. In practice, misunderstandings often arise due to complex role distributions.

The division of roles between Charge Point Operator (CPO) and E-Mobility Service Provider (eMSP) is fundamental to the e-mobility ecosystem. The CPO is responsible for the physical charging infrastructure, including the installation, operation, and maintenance of charging stations. They ensure that the hardware functions smoothly, disruptions are resolved, and regulatory as well as calibration requirements are met. The Charge Point Operator typically determines the CPO tariff and the commercial base logic for the charging points they operate. However, the actual price perceived by the end customer may be influenced by additional price components, service fees, roaming costs, or eMSP tariffs depending on the marketing channel. Furthermore, the CPO sets the access rules for the stations they operate. In practice, various entities can act as CPOs, including energy providers, property developers, or fleet operators offering charging infrastructure as a value-added service. The CPO does not necessarily have to own the hardware but can also act as a service provider for third parties.

In contrast, the E-Mobility Service Provider focuses on the end customer and access to the charging infrastructure. The eMSP typically does not operate its own hardware but provides the digital interface through which electric vehicle drivers can locate charging stations, initiate charging sessions, and handle billing. This is usually done via mobile applications or RFID cards. The eMSP aggregates the offerings of various CPOs, thereby enabling its customers to access an extensive charging network. In short, the CPO focuses on the technical and operational management of the infrastructure, while the eMSP emphasizes customer relationships and digital services.

In practice, an additional operational layer often exists between the CPO and eMSP: CPMS providers, roaming platforms, and clearing houses. A Charge Point Management System represents the technical operations and marketing layer for the CPO, covering charging point management, tariffs, authorization, transaction data, payment processes, and interfaces with roaming partners. Roaming platforms and clearing houses, in turn, simplify the connection between multiple CPOs and eMSPs by consolidating technical integrations, data exchange, billing information, and in some cases, commercial processes. As a result, the relationship between CPO and eMSP is not a simple linear one but rather a multi-level value creation and billing chain.

Strategic decisions and standards shape expansion

The decision whether a company acts as an integrated provider—both CPO and eMSP—or as a specialized player depends on various strategic criteria. An integrated business model offers the advantage of controlling the entire value chain, from hardware to the end customer. This can be particularly attractive for large energy suppliers or automotive manufacturers aiming to build strong brand presence and occupy the customer interface themselves. At the same time, this increases complexity: those who take on both roles must not only operate charging infrastructure but also professionally manage digital services, roaming, billing, support, and regulatory requirements.

For many players, specialization is a more sensible approach. By focusing on the role of the CPO, they can leverage their strengths in infrastructure development and local network operation without having to fully manage the complex requirements of end-customer apps and Europe-wide billing systems themselves. Collaboration with established eMSPs allows them to make their charging stations accessible to a broad user base. A study by BearingPoint shows that many regional energy providers who entered the market early with a broad range of offerings (CPO and eMSP) are now facing the challenge of lacking profitability. The study recommends leveraging existing customer proximity more effectively, offering specific solutions, and improving efficiency through automation and digitalization.

In addition, market access alone is not enough for CPOs and eMSPs; their offerings must be economically viable. Many CPOs face the challenge of aligning high investment and operating costs with the often still low utilization of charging infrastructure. For eMSPs, the question arises of how to profitably scale customer loyalty, roaming convenience, and digital services. Thus, the strategic choice of roles also becomes an economic question: which services can a company handle itself, which partners does it need, and through which channels can usage, customer value, and margin be sustainably connected?

A crucial factor for the seamless interaction between CPOs and eMSPs is interoperability. Isolated silo solutions hinder the growth of e-mobility by deteriorating the user experience and increasing administrative effort for all parties involved. Standardized communication protocols are therefore essential. The Open Charge Point Protocol (OCPP) enables communication between charging stations from various manufacturers and the backend systems of CPOs. This prevents vendor lock-in and gives operators the flexibility to select hardware suited to their needs. For data exchange between CPOs, eMSPs, and roaming platforms, protocols such as the Open Charge Point Interface (OCPI) play a central role. They standardize the transmission of location data, pricing, availability, authorizations, and billing information. This makes interoperability not only a prerequisite for user convenience but also the foundation for scalable marketing, billing, and pricing logic.

AFIR and the New Market Logic of Charging Infrastructure

The Alternative Fuels Infrastructure Regulation (AFIR) of the European Union, which has been in effect since April 2024, establishes new standards for public charging infrastructure. A key element of AFIR is the obligation for ad-hoc payment at publicly accessible charging points. Users must be able to start and pay for charging sessions without prior registration or contractual commitment with an eMSP, for example, via debit or credit card. This simplifies access to charging and diminishes the previous significance of eMSPs as an almost indispensable access layer.

For CPOs, this means meeting additional requirements for hardware, software, payment systems, and price transparency. At the same time, a strategic opportunity arises: through ad-hoc payment, CPOs move closer to the end customer and can build direct customer relationships. The customer interface is no longer exclusively with app providers or roaming services but increasingly with the operator of the charging infrastructure itself.

The AFIR mandates differentiated payment options for newly installed publicly accessible charging points. For charging technology with a power output of 50 kW or more, electronic payments via payment terminals or devices with contactless payment functionality are required. For charging points below 50 kW, secure internet-based payment solutions, such as via a QR code, can also be used. Along the Trans-European Transport Network (TEN-T), retrofit obligations apply to existing charging points of 50 kW or more. This regulation creates a standardized framework for ad-hoc charging—while simultaneously increasing the investment and implementation pressure on operators.

These requirements promote ad-hoc charging in the medium term while also increasing pressure on existing pricing and roaming models. The base tariff set by the CPO is not necessarily identical to the end customer price across all marketing channels. Depending on the channel, CPMS, roaming, clearing, service, or eMSP surcharges may be added. This makes pricing logic more complex but also more transparent and comparable. For this reason, price differences between ad-hoc payment and contract-based charging must in the future be traceable, transparent, and objectively justified.

For private customers, occasional users, or international users, a simple, transparent, and registration-free access becomes more attractive. However, the business model of eMSPs will not disappear. Rather, their value proposition shifts: mere access to charging infrastructure will no longer suffice. Key services will include fleet billing, roaming convenience, tariff bundling, reporting, cost center management, and digital additional functions. Contract-based models remain particularly relevant for commercial customers and fleets, as they provide consolidated billing, tax documentation, and administrative simplification.

Conclusion: Clarify Roles, Open Systems, Strengthen Customer Benefits

A deep understanding of the roles of CPO, eMSP, and the intermediary technical and commercial layers is essential for the successful expansion of charging infrastructure. Decision-makers in the mobility and energy sectors must carefully evaluate their strategic positioning: Which customer interface do they want to occupy themselves? What role will direct payment play in their future business model? Which tasks are part of their strategic core, and which technical, regulatory, or operational services can specialized partners handle more efficiently through experience and economies of scale? It is precisely this balance that increasingly determines whether charging solutions are not only user-friendly but also economically sustainable.

AFIR does not render eMSPs obsolete but changes their role. The competition shifts from mere access to charging infrastructure to service quality, billing convenience, data value, and integration into operational processes. At the same time, CPOs gain greater visibility at the customer interface through ad-hoc payment but must also meet higher requirements in terms of technology, transparency, and operations.

E-mobility can only reach its full potential if the various players in the ecosystem collaborate efficiently, consistently use technical standards, and focus on user needs. In the new market logic, it is not only about who operates charging points or provides apps, but about who connects access, operation, pricing logic, billing, and user experience in a way that creates not only a good charging experience but also an economically sustainable offering. 

*Philipp Nobis is Head of Product Management at Vaylens

Electromobility

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