PIN pad requirement at charging stations? Why an exception for eCars makes sense.

From July 2023, drivers of e-cars are expected to be able to pay contactlessly and spontaneously (ad hoc) at all charging stations using an EC card or credit card. This was decided by the German Federal Government in September 2021 as part of a new version of the ordinance on charging stations (LSV).

What does the new regulation entail?

It provides for a uniform payment system for the use of charging stations for electric vehicles. All charging stations put into operation from July 2023 must have a card reader with NFC function and a PIN pad for users to enter their PIN.

The Payment Services Directive II (PSD II), which is already in force across Europe, stipulates that card terminal users must enter their PIN on every fifth payment or for amounts in excess of 50 euros. This specification was decided upon from the perspective of Strong Customer Authentication (SCA) and serves to improve security in payment transactions and to increase consumer protection.

What are the consequences for eMobility?

The spread of eMobility must be supported with simple, user-friendly solutions — this is continually being emphasized by politicians. This is because it is only with easy-to-use charging solutions like this that maximum usability and a nationwide charging network can be achieved.

In this context, it should be noted that a PIN pad on charging stations for e-cars is usually superfluous. Under normal circumstances, only small amounts of money are involved when charging electric cars. A full charge (up to 80 percent of the total capacity) costs around 8 euros, which is well under the German limit of 50 euros for contactless transactions.

A role model for the lifting of the PIN pad requirement is the payment of parking and public transport fees: card terminals provided for this purpose are exempted from SCA due to the small amounts involved. Users do not have to enter their PIN during the payment process.

The PIN requirement is not only disadvantageous for the users, but also for the operators of charging infrastructure: the costs of a terminal with an integrated PIN pad that is only relevant for 1-2% of all transactions would make the charging infrastructure many times more expensive. This creates additional financial hurdles when setting up charging infrastructure.

What does the new regulation mean in the long term?

As a last point, the PIN pad requirement is currently a hotly debated topic. It is certainly intended to increase the protection of consumers when making online payments — however, it remains questionable whether this requirement is the right way to go to achieve the stated political goals. It clearly goes against the requirements for user-friendly charging facilities.

At the same time, the obligation to install PIN pads is providing new hurdles when it comes to the expansion of charging infrastructure across Germany. This, in turn, has an effect on the ability to achieve German climate protection goals — something in which eMobility plays a very important role.

That’s why a coalition of various manufacturers and operators of charging infrastructure solutions is calling for an exception to the PIN pad requirement when it comes to paying for charging electric cars. Read the full statement here.


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