Navigating the gap: Australia's experience in regulating electric vehicle supply equipment ahead of an OIML Recommendation

Abstract

As the deployment of electric vehicle supply equipment (EVSE) accelerates globally, ensuring accurate and transparent measurement of electrical energy supplied for charging is an emerging regulatory requirement. In Australia, electric vehicles and subsequently EVSE entered widespread use before the availability of an OIML Recommendation specific to these instruments.

Australia has developed an interim regulatory framework for EVSE to ensure accurate measurement of electrical energy supplied to or from an electric vehicle for billing purposes, pending the finalisation of an international OIML Recommendation. This approach balances national legislative requirements with international alignment during rapid market growth.

This article outlines Australia’s interim approach, developed to meet national legislative obligations while maintaining international alignment. It provides insight into stakeholder consultation, the development of a principles-based General Certificate of Approval (NMI 14/4/0), transitional arrangements, and Australia’s participation in the development of a future OIML Recommendation. The case study may assist other economies currently regulating EVSE in the absence of a finalised international standard.

1. Introduction

When Australia began examining how electric vehicle supply equipment (EVSE) was being used in the marketplace, we faced a regulatory challenge faced by regulators around the world. This new technology was advancing rapidly, but an international standard to support consistent regulatory treatment had not yet been finalised.

Australia therefore required an interim framework that could provide ensure consumers ‘get what they pay for’ while giving industry the confidence to deploy EVSE into Australia. This meant there was a need for a consultative and flexible approach that would allow business to adapt to international requirements as they become available.

2. Recognising EVSE as instruments used for trade

Under Australian law, any measuring instrument in ‘use for trade' needs to be pattern (type) approved and verified unless a formal exemption applies.

As a result, the trigger for regulatory action was straightforward. EVSE was in use for trade when it measured the amount of active electrical energy supplied to or from an electric vehicle and people were being billed accordingly. For EVSE, the concept of ‘supply’ is similar to that for a fuel dispenser: it resets to zero for each transaction and measures the quantity delivered to the customer. This differs fundamentally from electricity (utility) meters, which continuously measure and accumulate consumption over time.

This operational distinction, combined with the absence of an international standard, created the need for a regulatory approach tailored specifically to EVSE.

3. Consultation and the need for an OIML Recommendation

From the outset, engagement with stakeholders has been central to the development of EVSE regulatory policy in Australia. The process started with consultations on trade measurement options for EVSE (referred to as electric vehicle charging stations (EVCS) as that time) between 2021 and 2022.

One issue stood out: the absence of an OIML Recommendation created uncertainty and risk.

Manufacturers expressed concern that, without an international standard, they could face different requirements in different economies. Variations in design expectations, test procedures, and maximum permissible errors (MPEs) would result in increased compliance complexity and market fragmentation.

An internationally harmonised recommendation would allow manufacturers to design to a single set of requirements, improving efficiency and reducing the compliance burden across economies. It ultimately ensures everyone is manufacturing to the same standard and the same rules.

4. Developing an interim national framework

With ‘thousands and thousands’ of EVSE being installed, some regulation was (and still is) needed to provide certainty for consumers and industry.

In the absence of an OIML Recommendation, Australia implemented a General Certificate of Approval (NMI 14/4/0) to establish principles-based requirements and enable EVSE compliant with the certificate to be considered as pattern approved.

This approach prioritised outcomes over prescriptive design provisions, enabling:

• the continued use of existing EVSE installations
• flexibility for manufacturers during a period of significant technological evolution
• alignment with key international concepts without pre-empting the final OIML Recommendation

The General Certificate of Approval incorporates three core requirements based on the OIML Guide, OIML G 22:

• Marking requirements, enabling transparency for users.
• Sealing requirements, preventing unauthorised adjustment.
• Maximum permissible errors, ensuring the accuracy and reliability of measurement.

OIML G 22 is used as the guide for technical support as consultation indicated that OIML G 22 was not ready to become "regulation" in Australia. The approach was to align with OIML G 22 and wait for the OIML Recommendation before pushing forward with more comprehensive metrological and technical requirements.

OIML G 22 is referenced in relation to MPEs and accuracy testing. The General Certificate of Approval does not require testing or verification but enables it where necessary.

This approach allowed Australia to balance the first mover advantage of aligning with OIML G 22 against not stranding Australian industry with national requirements that may soon become outdated.

5. Stakeholder concerns about retrospectivity and accuracy

Two issues dominated the industry feedback about regulatory changes. Would existing EVSE be expected to comply with any new requirements, what would the MPEs be, and what would be the requirements for EV’s manufactured before 1 April 2026?

5.1 Transitional arrangements calm fears of retrospective regulation

The chance of new requirements applying to devices ‘already installed’ was the most consistent concern because of the likely financial and operational burdens on industry. In response, Australia implemented transitional arrangements with a long runway:

• interim requirements commencing 1 April 2026, and
• a 10-year transition period to 2036.

The 10-year window was based on industry advice about the typical life of an EVSE. The intention was to support reasonable investment cycles rather than impose sudden replacement costs. This approach ensures that older equipment can continue operating while providing a clear pathway to future compliance.

5.2 Internationally aligned maximum permissible errors

The requirement for MPEs was a second concern. The MPE specified was seen as not generally suitable, particularly for existing EVSE. In response to consultation, industry suggested a range of options, ranging from no MPE to an additional accuracy class with a larger MPE to align with regulatory requirements in other economies.

Following this feedback, Australia revised its approach so that MPE requirements apply to future EVSE, rather than retrospectively; existing EVSE manufactured before 1 April 2026 will not be subject to new accuracy obligations.

This approach recognises that existing EVSE were designed, manufactured and installed prior to the development of OIML G 22 and Australia’s national regulations. It also recognises the importance of MPEs that align with international requirements as they are developed.

6. Industry and consumer engagement

Industry engagement during consultation was extensive. Manufacturers and peak bodies contributed to shaping the interim framework, reflecting a cooperative approach to emerging regulatory challenges. We will continue to consult as international work progresses.

Milestones include: 

• 2021–2022: Consultation on trade measurement policy options, with a decision that EVSE are not to be classified as electricity meters. The intent was to develop EVSE requirements based on OIML G 22. 

• 2024: Consultation on and publication of the draft general certificate of approval for EVSE and MPEs. The certificate set MPEs in line with OIML G 22:2022. 

• 2025: The OIML Technical Committee met in March to develop the OIML Recommendation for EVSE, with Australia submitting feedback from national consultations on the first committee draft later that year. 

• 2026: Consultation on accuracy classes and MPEs specified in the general certificate of approval. Accuracy classes and MPEs will be maintained in line with OIML G 22 but apply to EVSE manufactured on or after 1 April 2026.
• Ongoing:  The development of a broader control framework including verification, licensing, and implementation timeframes after the development of the OIML Recommendation. 

Interestingly, Australia received “almost no consumer interest” during consultation. The most likely reason is that a primary consumer concern is “range anxiety” associated with the need for long‑distance travel in a geographically dispersed country such as Australia, and whether sufficient charging infrastructure would be available to support this. NMI expects that consumers will start to become more concerned about regulating measurement accuracy and reliability of EVSE (in the same way they do for fuel dispensers) as the technology becomes widely available, coupled with increased charging costs, and the very high price of electricity across Australia. "Getting what you pay for" will become key consumer concerns.

Balancing support for investment and uptake of EVSE technology, with confidence in measurement accuracy has been, and will continue to be a key consideration for NMI throughout this journey.

7. Australia’s contribution to the OIML drafting process

Australia continues to participate actively in the international drafting process of OIML guidance and recommendations.

We recently concluded national consultation on the first Committee Draft of the OIML Recommendation for EVSE. Comments have been provided to the OIML Technical Committee for consideration. As with any international drafting process, timelines depend on the resolution of technical issues and consensus across participating economies.

The General Certificate of Approval provides certainty until the OIML Recommendation is finalised and adopted domestically.

8. Lessons for Other Economies

Australia’s journey offers several insights for countries facing similar regulatory gaps:

• interim national requirements are often necessary where instruments are already in use for trade
• principles-based frameworks provide flexibility during periods of technological development
• sustained engagement with industry improves regulatory clarity and acceptance
• long transitional periods are appropriate where infrastructure lifecycles are extended
• transparency, particularly in relation to accuracy classes, is critical for building user and consumer confidence

Regulators do not need to wait for an international standard to begin building a system that protects consumers and supports industry by aligning with international metrological principles.

9. Conclusion

Australia’s interim regulation of EVSE demonstrates how national authorities can uphold metrological integrity while contributing constructively to the development of an international standard. The General Certificate of Approval provides a workable and adaptable framework ensuring accurate measurement during a period of rapid market expansion. As work continues in the OIML Technical Committee, Australia will maintain its commitment to harmonisation, transparency, and collaboration with industry and international counterparts.