What CPMS providers must know about RKSV for EV charging stations

By 2035, electric vehicles (EVs) are expected to make up half of all vehicles in major European markets. As a result, Europe’s public EV charging infrastructure is rapidly expanding to meet this rising demand. To ensure a compliant network for charging point operators, providers of charge point management systems (CPMS) need to be aware of the applicable fiscalization regulations.

Fiscalization requirements for EV charging stations and the European AFIR directive

The Alternative Fuels Infrastructure Regulation (AFIR), Regulation (EU) 2023/1804, replaces Directive 2014/94/EU and has been in effect since April 13, 2024. It is part of the EU's ‘Fit for 55’ package aimed at reducing emissions by 55% by 2030. The regulation sets out mandatory targets for deploying alternative fuels infrastructure across the EU to ensure the uptake of alternative fuel vehicles and contribute to achieving climate goals.

The objectives outlined in the regulation are to ensure the minimum infrastructure with full interoperability to support the required uptake of alternative fuel vehicles, while providing comprehensive information and adequate payment options for users:

Users of alternative fuel vehicles should be able to recharge or refuel on an ad hoc basis and pay easily and conveniently at all publicly accessible recharging and refuelling points, without the need to enter into a contract with the operator of the recharging or refuelling point or a mobility service provider. Therefore, for recharging or refuelling on an ad hoc basis, all publicly accessible recharging and refuelling points should accept payment instruments that are widely used in the Union, and in particular electronic payments through terminals and devices used for payment services. (...) That ad hoc payment method should always be available to consumers, even when contract-based payments are offered at the recharging or refuelling point.

– Regulation (EU) 2023/1804

In some European countries, e.g. Spain, EV charging points are already included in fiscal regulations. In Austria, the requirements outlined in the AFIR means that charging points for electric vehicles are subject to the RKSV (Cash Register Security Ordinance) requiring businesses to securely record and sign each transaction in an electronic cash register.

The RKSV in Austria

The Cash Register Security Ordinance (Registrierkassensicherheitsverordnung, or RKSV) in Austria has been in effect since 2017 and aims to ensure transparency, reduce tax evasion, and standardize financial transactions. To be compliant with Austria's regulations, businesses must implement the mandatory individual recording obligation, cash register obligation, and the obligation to provide receipts.

EV charging points

EV charging stations are considered vending machines for goods and services and are therefore subject to RKSV requirements as a POS if the individual sales exceeds 20€. If an EV charging station accepts ad-hoc payments made directly at the charging point via methods deemed equivalent to cash (e.g. credit or debit cards) the transactions must be recorded in compliance with RKSV. Non-compliance leads to penalties up to 5,000€. Transactions conducted through methods not considered cash-equivalent, such as RFID cards, are generally exempt from RKSV requirements.

What CPMS providers and charge point operators need to cover

• Individual recording obligation (Einzelaufzeichnungspflicht): Each transaction must be recorded individually, using an electronic cash register system that meets RKSV standards.
• Cash register obligation (Registrierkassenpflicht): Operators must use an electronic recording system and secure each transaction with an automatic signature using a security device (SE) or a signature creation unit (SEE)
• Receipt obligation (Belegerteilungspflicht): A receipt must be issued for every cash transaction, either in paper or digital format, to ensure all transactions are accurately recorded, processed through a compliant cash system, and properly documented.

What information needs to be included on an RKSV-compliant receipt?

When issuing receipts in compliance with Austria’s RKSV, it’s essential to include specific details to meet legal requirements. These standards help to verify the authenticity of each receipt and protect against fraud:

• A clear identification of the taxable person supplying or performing the service (company name)
• A unique, sequential receipt number assigned to identify the business transaction
• The date and time the receipt was issued
• The quantity and detailed description of the service provided
• Payment amount (broken down by net amount, tax amount and total amount)
• Cash register identification number
• Machine-readable signature (QR code containing the transaction data generated by the security device)