Public Charge Point Regulations 2023: What Car Park Operators Must Do

If you let members of the public plug in on your car park — retail, hotel, leisure, a council pay-and-display, a mixed-use estate — the chargers fall under the Public Charge Point Regulations 2023. These are not optional good-practice guidelines. They are law, in force since 24 November 2023, with staged deadlines that have now all landed. This guide is the operator’s checklist: what the rules actually require, which of your bays they cover, and — the part most site owners miss — who is legally on the hook when a third party runs the chargers for you.

What counts as a “public” charge point?

The regulations bite on a charge point that is “available for use by members of the public”, whether or not they pay. The test is access, not ownership. A rapid unit in a supermarket car park anyone can drive up to is public. A hotel charger any guest can use is public. A council car park charger is public.

What is not public: bays behind a barrier reserved for named staff or a known fleet, and genuinely private domestic chargers. This distinction matters because it also drives your funding and your VAT. Workplace-only bays sit outside these regulations and can draw the Workplace Charging Scheme; public bays cannot use WCS and are standard-rated at 20% VAT. If your site mixes both — public front-of-house, staff round the back — the two groups of chargers carry different duties. Get the boundary wrong and you either over-comply on private kit or, worse, leave public units non-compliant. Our note on funded vs owner-operated walks through where that line usually falls.

The six core duties

The regulations impose six substantive obligations. Most applied in stages; the timeline below is now fully live as at 2026.

Duty	What it requires	Applies to	In force
Up-front pricing	Total price shown in pence per kWh before charging starts, no surprise fees	All public charge points	24 Nov 2023
Contactless payment	Accept contactless bank card, no app or account required	New chargers 8kW+; existing chargers 50kW+	24 Nov 2024
24/7 helpline	Free-to-call staffed helpline available at all times	All public charge points	24 Nov 2024
Open data	Publish reference + dynamic data (location, availability, price) in open format	All public charge points	24 Nov 2024
Reliability	99% average reliability across a rapid (50kW+) network, reported annually	Rapid-network operators (50kW+)	24 Nov 2024
Payment roaming	Let drivers pay via at least one roaming provider	All public charge points	24 Nov 2025

A few points that trip operators up:

• Pricing must be a single, clear pence/kWh figure shown before the session. Time-based tariffs and idle fees are allowed, but the headline energy price has to be visible and honest up front. This is where public retail pricing sits today — roughly 61–92p/kWh across UK networks mid-2026 — and where you set yours has a direct line to your payback maths.
• Contactless is scoped by power and by age. A brand-new 7kW AC post is under the 8kW threshold and escapes the hardware mandate — but a new 22kW AC unit or any DC rapid must take a contactless bank card, no app. Existing 50kW+ units had to be retrofitted. Do not read “8kW” as “8kW everywhere”; the existing-kit threshold is 50kW.
• The helpline must be free and genuinely 24/7. A voicemail box is not compliant. Most operators satisfy this through their charge-point operator’s national support desk rather than staffing it in-house.
• Open data means machine-readable, not a page on your website. Location, connector types, live availability and current price have to be published in an open format so map and roaming apps can consume them.
• 99% reliability is a network average, measured annually, and applies to rapid (50kW+) estates. A single site rarely triggers it, but if you run a portfolio of rapids the number is real and reportable.

Who actually carries the duties on a funded site?

This is the question that decides your real exposure. Under the regulations the obligations fall on the charge point operator — the party that operates the units and sets the retail price. On many car parks that is not the landowner.

• Fully-funded model. A CPO installs and owns the kit at £0 capex to you, sets the tariff, runs the payment platform, the helpline, the open-data feed and the reliability reporting, and pays you a revenue share (often cited around 20–40%, always privately negotiated). In this model the CPO is the operator and carries the regulatory duties. Your job is contractual: make sure the agreement names them as the responsible operator and commits them to compliance.
• Owner-operated model. You buy the kit and keep the retail-minus-energy spread — which means you are the charge point operator and every duty above is yours. Pricing display, contactless hardware, the 24/7 helpline, the open-data feed, roaming, reliability reporting: all on you, usually delivered through a back-office/OCPP platform you subscribe to.
• Hybrid/managed. A managed-service provider runs the compliance layer on your behalf while you retain the economics. Here the contract must be explicit about who files what.

The honest summary: funding does not make the rules disappear — it moves the operator label onto someone else. If you sign a fully-funded deal, you are largely buying your way out of the compliance burden. If you go owner-operated for the better margin, you are taking the burden on. Neither is wrong; they are a trade-off, and it is worth pricing the compliance overhead into the owner-operated case before you assume it is the better deal. Our funded vs owner-operated breakdown sets the two side by side.

A practical operator checklist

Whether you run the chargers or oversee a CPO who does, confirm each of these:

• Scope your bays. List which chargers are public and which are private staff/fleet. Different rules, different funding, different VAT.
• Check power ratings against the contactless mandate. Any new 8kW+ or existing 50kW+ public unit must take a contactless bank card with no app.
• Verify the pricing display. A clear pence/kWh figure shown before the session, with any additional fees disclosed.
• Confirm the 24/7 free helpline is live and answered — with the number displayed on the unit.
• Confirm the open-data feed is published and reaching the mapping apps.
• Confirm roaming is enabled through at least one provider.
• For rapid portfolios, confirm reliability reporting is set up for the annual 99% network figure.
• Read your contract. On a funded or managed deal, get it in writing that the CPO is the named operator and holds these duties.

Retail, hotel and leisure sites carry these obligations differently depending on dwell time and driver mix — the same compliance stack lands differently on a retail and shopping-centre car park with high turnover than on a hotel car park where guests charge overnight. And for council-run public car parks, LEVI-funded schemes are procured through the authority, which shapes who ends up wearing the operator label.

The bottom line

The Public Charge Point Regulations 2023 are now fully in force. The six duties — up-front pence/kWh pricing, contactless on new 8kW+ and existing 50kW+, a free 24/7 helpline, open data, 99% rapid-network reliability and payment roaming — are the baseline any public charger on your car park must meet. The single most important decision you make is the commercial model, because that determines whether these duties are yours or your operator’s. Everything else follows from getting the “who is the operator?” question answered clearly and in writing.

If you want a plain read on which chargers on your site would count as public, which duties would land on you versus a funded CPO, and what the numbers look like either way, request a feasibility assessment — it is an online form, no phone call, and you will get a site-specific view back rather than a generic brochure.

Frequently asked questions

Do the Public Charge Point Regulations 2023 apply to my car park?

They apply to any charge point that members of the public can use, paid or free — retail, hotel, leisure and council car parks are all covered. Bays behind a barrier reserved for named staff or a known fleet are not public and fall outside the regulations (and can instead use the Workplace Charging Scheme).

Which chargers need to accept contactless?

From 24 November 2024, new public chargers rated 8kW and above, and existing public chargers rated 50kW and above, must accept a contactless bank card with no app or account required. A new 7kW AC post sits under the 8kW threshold and is exempt from the hardware mandate.

If a funded operator runs my chargers, am I still responsible for compliance?

Generally no — the regulatory duties fall on the charge point operator, which in a fully-funded model is the CPO that owns the kit and sets the price. Make sure your contract names them as the responsible operator. If you go owner-operated, you are the operator and every duty is yours.

What is the 99% reliability rule?

Operators of rapid (50kW and above) networks must maintain a 99% average reliability across the network and report it annually. It is a network-wide average, not a per-site figure, so it mainly affects operators running a portfolio of rapid chargers.

Does public EV charging get charged at 5% or 20% VAT?

HMRC treats public EV charging as standard-rated at 20% (Revenue & Customs Brief 4, 2026). A tribunal decision suggesting 5% is under appeal, so 20% stands. VAT-registered businesses can generally recover input VAT on the installation. Take your own tax advice.

Official sources

• The Public Charge Point Regulations 2023 — guidance (gov.uk)
• The Public Charge Point Regulations 2023 (legislation.gov.uk, SI 2023/1168)