FCE Contribution to the Upcoming Review of AFIR

Fleet Cards Europe (FCE) welcomes the opportunity to contribute to the upcoming review of the Alternative Fuels Infrastructure Regulation (AFIR). As a complement to its response to the public consultation questionnaire, FCE submits this paper to provide additional context, evidence and rationale underpinning the positions expressed in its contribution.

As trusted partners to fleet operators across Europe, serving businesses of all sizes and vehicle types, FCE members are uniquely positioned to represent the operational realities, challenges and priorities of commercial fleets. As e-Mobility Service Providers (eMSPs) and providers of access to a broad range of energy types, fleet card companies have first-hand experience of the opportunities and challenges associated with enabling the transition to lower-emission transport, including pricing, customer access, interoperability, roaming and digital services. As intermediaries between fleet managers and energy providers, fleet card companies play a key role in connecting supply and demand across the mobility ecosystem. Through their daily interactions with all stakeholders, FCE members have a comprehensive understanding of the practical constraints faced by infrastructure and energy providers, as well as fleet operators, and are therefore well placed to ensure that these perspectives are effectively reflected in the policymaking process.

FCE and its members are fully committed to supporting the decarbonisation of road transport, in line with the objectives of the European Green Deal. A successful transition requires a regulatory framework that enables investment, supports market development and recognises the diversity of operational needs across different segments of road transport.

Against this background, FCE would like to highlight the following key considerations and recommendations for the AFIR review:

• Recognise the distinct roles of Charging Point Operators (CPOs) and e-Mobility Service Providers (eMSPs) within the charging value chain, including the value added services provided by eMSPs to commercial fleet operators.

• Preserve commercial flexibility by allowing market participants to develop and negotiate pricing models and contractual arrangements in a competitive environment.

• Maintain the existing EV charging targets for light-duty vehicles (LDVs) to preserve regulatory certainty and support continued market-driven infrastructure deployment.

• Complement the existing framework for heavy-duty vehicle (HDV) charging infrastructure with a stronger focus on operationally relevant infrastructure deployment, particularly widespread open-access depot charging, while preserving flexibility and a demand-driven, market-led approach to infrastructure rollout beyond the TEN-T network.

• Address the underlying barriers to hydrogen deployment by strengthening the hydrogen value chain, increasing supply availability, reducing costs and stimulating demand for heavy-duty transport, rather than relying on revised infrastructure targets .

• Ensure a technology-neutral approach under AFIR by recognising the role of renewable fuels alongside electricity and hydrogen, providing consistent regulatory treatment and equal access to incentives and funding across decarbonisation pathways.

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