Tax Alert: AFIR came into force

For light-duty vehicles, the AFIR provides for establishment of a network of recharging pools deployed in each direction of travel with a maximum distance of 60 km between them, where

a)     along the TEN-T core road network:

• by 31 December 2025, each recharging pool offers a power output of at least 400 kW and includes at least one recharging point with an individual power output of at least 150 kW;
• by 31 December 2027, each recharging pool offers a power output of at least 600 kW and includes at least two recharging points with an individual power output of at least 150 kW;

b)      along the TEN-T comprehensive road network:

• by 31 December 2027, along at least 50% of the length of the TEN-T comprehensive road network, each recharging pool offers a power output of at least 300 kW and includes at least one recharging point with an individual power output of at least 150 kW;
• by 31 December 2030, each recharging pool offers a power output of at least 300 kW and includes at least one recharging point with an individual power output of at least 150 kW;
• by 31 December 2035, each recharging pool offers a power output of at least 600 kW and includes at least two recharging points with an individual power output of at least 150 kW.

Furthermore, Member States must ensure that, at the end of each year, starting from 2024, the following power output targets are met cumulatively through publicly accessible recharging stations:

a)     for each light-duty battery electric vehicle registered in the territory of the given Member State – a total power output of at least 1,3 kW and

b)     for each light-duty plug-in hybrid vehicle registered in the territory of the given Member State – a total power output of at least 0.80 kW.

For heavy-duty vehicles, the AFIR provides for establishment of a network of recharging pools deployed across the entire EU, where:

a) by 31 December 2025, along at least 15% of the length of the TEN-T road network, publicly accessible recharging pools dedicated to heavy-duty electric vehicles are deployed in each direction of travel and each recharging pool offers a power output of at least 1 400 kW and includes at least one recharging point with an individual power output of at least 350 kW;

b) by 31 December 2027, along at least 50% of the length of the TEN-T road network, publicly accessible recharging pools dedicated to heavy-duty electric vehicles are deployed in each direction of travel and each recharging pool:

• along the TEN-T core road network, offers a power output of at least 2 800 kW and includes at least two recharging points with an individual power output of at least 350 kW;
• along the TEN-T comprehensive road network, offers a power output of at least 1 400 kW and includes at least one recharging point with an individual power output of at least 350 kW;

c) by 31 December 2030:

• along the TEN-T core road network, publicly accessible recharging pools dedicated to heavy-duty electric vehicles are deployed with a maximum distance of 60 km between them and that each recharging pool offers a power output of at least 3 600 kW and includes at least two recharging points with an individual power output of at least 350 kW;
• along the TEN-T comprehensive road network, publicly accessible recharging pools dedicated to heavy-duty electric vehicles are deployed with a maximum distance of 100 km between them and each recharging pool offers a power output of at least 1 500 kW and includes at least one recharging point with an individual power output of at least 350 kW;
  

Moreover, by 31 December 2027, in each safe and secure parking area at least two, and by 31 December 2030 at least four, publicly accessible recharging stations dedicated to heavy-duty electric vehicles with an individual power output of at least 100 kW are to be deployed.

In practice, the requirements presented above mean that in the coming years Poland will be faced with the task of building considerably more recharging points compared to the current state of affairs, as well as significantly accelerating the process. 

Importantly, the AFIR imposes on recharging station operators the requirement to provide payment terminals. This means that payments for recharging will be effectuated by payment cards, without the need to register in the system in the first place.

The material Regulation can be found at: L_2023234PL.01000101.xml (europa.eu)

Given the current state of electric vehicle recharging infrastructure in Poland and the forecasts as to the growing numbers of new registrations of eclectic vehicles, implementation of requirements imposed by the AFIR translates into the need of enabling an important number of new high-output recharging stations and incurring significant financial outlays for this purpose in the coming years. To accommodate these needs, a raft of calls for proposals has been announced for 2024, enabling both European and national funding.

KPMG supports companies in obtaining grants and incentives for investments in publicly accessible recharging infrastructure, in particular within the frames of the CEF facility (more information thereon can be found in KPMG’s Tax Alert - Calls for tenders under the Connecting Europe Facility (CEF) - KPMG Poland) and under a new priority aid scheme “Support of the construction and/or expansion of publicly available recharging stations for heavy duty transport” managed by the National Fund for Environmental Protection and Water Management (more information thereon can be found in KPMG’s Tax Alert - Consultation on the new priority aid scheme of the National Fund for Environmental Protection and Water Management - KPMG Poland).

The KPMG Team remains at your disposal for any further information you might require.