Opening a company car park to guests: when does charging become publicly accessible?
A charge point in a company car park can be publicly accessible even when the land is privately owned. What matters is who is actually allowed to use the site. A clearly defined group of individually identifiable authorised users is different from an offering for any customer or other driver. Before opening access, decide whether you want to provide controlled guest charging or a public charging service. Access, payment, technical requirements and ongoing responsibilities all depend on that decision.
This classification relates to Germany and the applicable European rules, with the legal position current as of 24 September 2026. For mixed models, clarify the specific access arrangements with the competent authorities before implementation.
Private land, a barrier and a charging card do not settle the question on their own
Germany's Federal Network Agency (Bundesnetzagentur) identifies generally accessible customer car parks as typical public locations. By contrast, areas restricted to specific employees or individually identifiable authorised users may be non-public. General conditions of access do not automatically rule out public accessibility either. A barrier, registration or payment is therefore not a sufficient distinguishing factor on its own. Federal Network Agency: public accessibility and company car parks.
Apply these criteria to your actual operating process. Allowing any passing driver to scan a QR code and charge is different from admitting a visitor with a pre-approved appointment whose access is limited to that visit. Conversely, a label saying “guests only” proves little if practically any driver is accepted as a guest.
The map in an app should describe access in the same way as the signs on site. Otherwise, conflicting information leads to unnecessary journeys and support requests, regardless of the legal classification.
Start by defining the purpose of opening access
There are various business reasons for guest charging: supporting customers during appointments, supplying partners' vehicles or offering spare capacity for a fee. These aims do not necessarily require the same model. Higher utilisation is only helpful if your own fleet can still charge in time and the additional revenue justifies the operational effort.
Write down the problem that opening access is intended to solve. “Our charge points sit idle at weekends” is an observation, but not yet a business model. Expected demand, achievable prices, access hours and the costs of payment, support and billing are still missing. Enabling public charging technically does not, by itself, make a charge point economically viable.
The existing article on charging strategy for businesses covers the needs of your own vehicles. Use this as a firm starting point before additional users draw on the same infrastructure.
Compare three clearly defined usage models
Model | Practical arrangements | Check before deciding |
|---|---|---|
Employees and your own fleet only | Defined authorised users, clearly indicated restrictions | User administration and operational charging targets |
Individually invited visitors | Access tied to the visit, limited authorisation, documented process | Whether the group can genuinely be distinguished and how the specific case is classified |
General customer or charging service | Use by a group of people that is not individually restricted | Public operation, payment and further requirements |
This table provides a planning structure, not automatic legal clearance. If usage varies, specify the charge points and time periods involved. A single unclear rule for the entire site makes subsequent management harder.
With separate areas, for example, you can reserve one section for company vehicles and another for visitors. Then check access to each independently: a publicly advertised charging bay should not be accessible only through a zone that outsiders are not allowed to drive through.
Check obligations before choosing hardware
For publicly accessible charge points, AFIR regulates options for ad hoc charging as well as payment and price information requirements, among other things. The specific implementation depends on factors such as power output and the date of commissioning. Neither “every station needs the same card terminal” nor “a QR code is always enough” is therefore a reliable procurement rule. Have the provider explicitly identify the requirements for your model. Regulation (EU) 2023/1804, in particular Article 5.
Also clarify notification duties, technical requirements and the designated operator. Record in writing who is responsible for notifications and changes, and who checks that they are complete. Appointing a service provider should not lead to the assumption that nobody within your company remains responsible.
German measurement and calibration law requires a separate assessment. It can also be relevant to non-public charging where measured quantities are billed to other people. Deciding on public accessibility therefore does not replace a metering and billing concept.
Organise the visit from the gate to the invoice
Walk through the entire process with someone who knows neither the app nor the premises. They must be able to find the right entrance, reach a suitable bay, understand the costs and use the intended authorisation method. After charging, a receipt and, where applicable, an invoice must be accessible.
Define how authorisation ends. An invited visitor may collect their vehicle earlier or stay longer than planned. Reception staff should know who can help with a locked cable or expired authorisation. Provide clear information on permitted parking times; the end of charging is not automatically the end of a visit, or vice versa.
Test the process outside office hours as well if you offer access at those times. A telephone number on the charge point is of little use if nobody answers it then. Define which faults can be resolved technically and which require the bay to be closed.
Protect the operational readiness of your own fleet
Set out operational priorities in advance: how much energy do your own vehicles need, and by which departure time? What capacity is then left for other users? A public service with variable power must be consistent with its published terms and the power actually available.
Do not project revenue for every theoretically idle hour. Maintenance, company events, seasonal peaks and future fleet expansion can limit the service. Also allow for support, transaction costs, cleaning, markings and signs. Higher electricity sales alone do not demonstrate a positive contribution margin.
Document a threshold for reviewing the model: for example, if your own vehicles repeatedly miss their charging targets or visitors regularly cannot find a usable bay. This makes a later adjustment a deliberate operational decision.
Prepare a specific decision for the site
For approval, you need a site plan, a description of the user group, opening hours, charging priorities and a payment model. Add responsibilities for operator duties, notifications and technical faults. Only when these points fit together can you choose appropriate hardware and software.
StromNow Fleet describes charging infrastructure for employees, pool vehicles and guests. During a site assessment, explicitly discuss whether charging is intended only for invited individuals or for a general customer base. This allows the scope of services to match your actual access model, instead of treating a later opening to the public as a setting without consequences.
Frequently asked questions
Is a charge point behind a company barrier automatically non-public?
No. What matters is the group of people who actually receive access. A generally available customer car park can be publicly accessible even on private land and behind a barrier. Registration or payment alone is not enough to distinguish it. Document the actual access rules, rather than just the owners of the land. The Federal Network Agency explains the criteria for public accessibility; have unclear mixed models assessed before opening access.
Can individual invited visitors charge at a non-public company charge point?
That may fit a non-public model if access genuinely remains restricted to a clearly defined group of individually identifiable authorised users. A visitor with a pre-approved appointment differs from a service that accepts any driver as a guest. The label alone does not decide the matter. Describe authorisation, its connection to the visit and when access ends, then assess the model against the Federal Network Agency's criteria.
Is a QR code always sufficient for payment for public guest charging?
No. AFIR differentiates requirements according to factors including power output and the commissioning date. A QR code is therefore not a universal procurement rule, nor is an identical card terminal for every station. Ask for written confirmation of the payment options and price information required for your planned charge points. The basis is Article 5 of Regulation (EU) 2023/1804. Check the complete process, including access to receipts.
How do I prevent guest charging from jeopardising my fleet's departures?
First establish the energy requirements and charging windows of your own vehicles. Release only compatible capacity for guests, and plan accessible bays and clear usage times. Test high visitor occupancy occurring at the same time as operational peaks. Calculate revenue only for realistically available capacity, and include support and billing. Repeatedly missed fleet targets or a lack of guest spaces are specific triggers for adapting the model.