Written evidence submitted by ChargeUK (SEV0075)

Executive summary

ChargeUK is the voice of the UK's electric vehicle charging industry. Our 40+ members are the companies that install and operate the UK's charging infrastructure – from on-street chargers to rapid hubs on the strategic road network. Together, they committed in 2023 to invest £6 billion in charging infrastructure through to 2030 and have more than doubled the public charging network in under three years, from around 40,000 devices in 2023 to nearly 88,000 today.

We welcome the opportunity to contribute to this inquiry. While there are myriad charging issues of high relevance to the transition – grid connections, planning, signage and delays to the LEVI fund to name a few – our submission focuses on the relationship between charging infrastructure, affordability, and the conditions needed to meet the ZEV mandate. These are the first-order issues that sit at the heart of the UK’s ability to supercharge the EV transition.

The transition to electric vehicles is working: manufacturers are meeting their targets; drivers are switching; the charging network is growing. But the benefits are not yet reaching everyone equally. The majority of the UK’s drivers can access highly affordable home charging, ensuring that EV running costs are lower than for petrol and diesel cars. But a third of households lack off-street parking, meaning there is a risk that they may miss out on one of the key benefits of EVs – affordability. And while the public charging network is growing rapidly, concerns are regularly voiced regarding availability in regional and rural areas.

Behind the issues of availability and affordability sit two root causes. The first is that policy-driven operator costs are keeping public charging prices higher than they need to be, as well as limiting the areas where it is commercially viable to deploy new sites at this stage in the adoption cycle.

The second is ongoing policy uncertainty. Despite the fact that ZEV mandate targets have, to date, been met, the Government faces pressure to weaken those targets. We believe that would be the wrong response. The right response is to fix the costs – and unlock the benefits of electrification for everyone.

This submission sets out the case for electrification, explains how policy certainty has enabled the charging sector to invest and deliver, identifies the cost barriers that remain, and recommends actions the Government can take to supercharge the transition through the Cost of Charging Review and the forthcoming review of the ZEV Mandate.

The case for electrification

The case for electrification rests on three priorities central to the Government's agenda: reducing costs for households, strengthening energy security, and driving jobs and growth.

For drivers, electric vehicles offer lower running costs. Recent analysis found that 80% of new EV buyers will save money over the period of ownership compared to an equivalent petrol or diesel vehicle[1].

The transition reduces the UK's dependence on imported oil and gas, shoring up the country’s energy security. Whereas petrol and diesel prices are subject to fluctuation in global crude oil prices, an increasing share of UK electricity will come from domestic renewable generation. While gas continues to influence power prices today, the shift towards renewables will reduce the UK’s exposure to global volatility.

The transition is attracting significant private investment, building supply chains and creating skilled jobs across the country. One report – from the consultancy Roland Berger - suggests that the sector currently employs around 4,000 people directly, with projections of more than 10,000 by 2030. The electrification of transport more broadly – which is not possible without billions of private investment in a fit-for-purpose charging network – has further impact. CBI Economics estimates that the transition will add £16.1 billion to the economy and 167,000 jobs by 2035 if the automotive sector scales up electrification to meet consumer demand[2].

These benefits are already being realised for many, as shown in consistently positive surveys of drivers. The question before the Committee is not whether electrification is the right option for the vast majority of transport decarbonisation – that case is well established. It is whether the conditions are in place to ensure the transition continues at the pace required to meet the UK’s Carbon Budgets, while delivering for everyone who stands to benefit from it.

A virtuous cycle in action

We have already seen what is possible when policy, investment and infrastructure align.

When ChargeUK formed in 2023, our members committed £6 billion in private investment through to 2030. This was made possible by the incoming ZEV mandate, which gave the sector confidence that demand for charging would follow. That confidence has borne fruit: the public charging network has grown from around 40,000 public charge points in spring 2023[3] to nearly 88,000 today[4], more than doubling in under three years and deploying hundreds of millions of pounds of that private investment. Driver satisfaction has grown with it: Zapmap surveys consistently show that most EV drivers believe the charging experience is improving year on year[5].

This growing network has, in turn, enabled automotive manufacturers to sell 1.8 million battery electric vehicles onto UK roads – more than 5% of the vehicle parc, with 500,000 of those sold in 2025 alone[6]. December 2025, the most recent month for which we have data, set a new record: nearly a third of vehicles sold were battery electric. Despite media headlines suggesting otherwise, this has meant the automotive sector keeping pace with the annual targets set for them as part of the ZEV mandate – the sector delivered on its 2024 target, and independent analysis suggests that they will have done so again in 2025[7].

The Government has consistently stated its expectation that “the certainty of the ZEV mandate will give industry renewed confidence to invest in our infrastructure”[8]. That expectation has been met in practice through a virtuous cycle of certainty bringing investment, investment building the network, and a growing network giving customers the confidence to make the switch to an electric vehicle, while expanding a high-growth sector that employs people across the country. The idea of this virtuous cycle has been tested and proven. But sustaining it requires that certainty to remain in place.

Finishing the job

The Government has already recognised its role in supporting the EV transition and last year took meaningful action on several fronts.

In July 2025, it introduced the Electric Car Grant to reduce upfront costs, responding to concerns from the automotive sector that demand needed a boost. In the Autumn Budget, it raised the threshold for the Expensive Car Supplement and delayed changes to the Employee Car Ownership Scheme. And it reduced home energy costs by ending the Energy Company Obligation scheme and shifting a proportion of renewable energy levies from bills to general taxation, cutting household bills by £150 per year and making home charging even more affordable.

These were the right calls. Early signs suggest they have worked: more than 50,000 drivers have used the Electric Car Grant[9], and December 2025 set a new record for electric vehicle sales. For many drivers, the case for switching is now extraordinarily strong: for most, EV ownership is convenient, extremely affordable, and 98% of EV drivers say they would never turn back to an ICE equivalent[10].

The remaining EV driver cost which requires addressing is that of public charging. Fixing this link in the virtuous cycle would make driving an EV more affordable for all, including the third of UK households – and two-thirds of households in urban areas – who lack off-street parking and cannot charge at home.

The average cost of public charging is now 38% higher than in 2021. Earlier in the decade, all EV drivers could expect to save on running costs compared to petrol or diesel, regardless of how they charged. That is no longer true for everyone. EVA England's 2025 survey found that 87% of EV drivers with driveways say their car is cheaper to run than their previous petrol or diesel vehicle[11]. Ensuring drivers who rely on public charging see the same savings is the clear next step – and would bring a significant new group of consumers into the market, supporting BEV sales and the ZEV Mandate targets, and ensuring the transition is fair.

The commercial case for deployment is also weaker in some areas than it could be. The charging network continues to grow quickly – operators deployed over 14,000 new charge points last year, including nearly 4,000 rapid and ultra-rapid devices, representing year-on-year growth of 20% and 41% respectively. But, at a stage in the market’s development where operators are pre-profit, growth is concentrating in locations where utilisation is expected to be highest. Areas where EV adoption is lower – often outside the South East and in rural communities – are harder to justify commercially. The Public Accounts Committee reported in March 2025 that only 15% of public charge points had been installed in rural areas – reflecting commercial viability challenges in low-utilisation regions[12]. While other factors are highly relevant – ongoing grid connection challenges and the Government’s LEVI fund taking much longer to deliver than expected[13] have both played a major role in the pace and location of deployment – improving the economics of deployment is central to the sector’s ability to grow the network where it is most needed to bring new drivers into the transition.

ChargeUK’s White Paper, Delivering Affordable Charging for All[14], published in September 2025, found that both symptoms, affordability and availability, stem from the same cause: policy-driven cost burdens that are outside of operators’ control. While rising energy costs affect businesses across the economy, our analysis found that some of these costs create a unique challenge for the charging sector – one that flows directly through to drivers in the form of higher prices or more selective deployment:

• Standing charges have risen by as much as 462% since 2021, following Ofgem’s Targeted Charging Review and now represent approximately 70% of operators’ total electricity costs at many sites. These charges are now calculated based on connection capacity, not actual usage – meaning operators who build ahead of demand, as the transition requires, are penalised for doing so. These charges are set to rise again in April 2026, as part of broader increases to network charges for energy users.
• Policy levies add around 6p/kWh to operators’ costs, with increases to above 10p/kWh expected by 2030. Unlike households and a growing number of energy-intensive industries which benefit from 100% exemption from renewable electricity subsidies, charge point operators receive no relief from these levies. In fact, CPOs must pay the levy that funds relief for other sectors, despite being heavily exposed to high electricity costs themselves.
• Wholesale costs remain 66% above pre-energy crisis levels, with the charging sector similarly receiving no protection from these rises as domestic consumers do under the energy price cap.

At many sites, these increases mean that operators’ costs are up to 60% higher than driver-facing prices, meaning they are running at a loss on a per-kWh basis. The sector is investing ahead of demand and profitability, as the transition requires – but unnecessary policy costs are making that investment harder to sustain.

Two further policy disparities compound the disadvantage for drivers depending on public charging. VAT on public charging is 20%, compared to 5% on home charging – a disparity that disadvantages precisely those drivers with the fewest charging options. And UK CPOs are excluded from generating renewable credits through the Renewable Transport Fuels Obligation, denying them a revenue stream worth 2.5-8.5p/kWh to their European counterparts. In the EU, this revenue has been used by operators to expand deployment in marginally viable areas and to keep prices competitive.

With the exception of wholesale energy prices, these cost burdens are not market forces beyond Government's reach – they are the product of policy choices the Government has the power to change. Addressing them would make the ZEV mandate easier to meet by ensuring more potential buyers can see how switching makes practical and financial sense for them.

The Government’s Cost of Charging Review, due to report in Q3 2026, is the opportunity to close this gap and finish the job.

The choice ahead

Addressing these cost disadvantages would make the transition affordable for more people – and make the ZEV mandate easier to meet. But the Government faces competing pressures – and risks pulling the wrong lever.

The European Union recently proposed tweaks to its own approach, intended to ease the compliance burden on carmakers – changes that largely catch up with flexibilities the UK introduced in April 2025. There is growing pressure on the UK Government to go further still – to weaken the ZEV mandate to ease short-term pressure on manufacturers.

This would be a mistake.

The charging sector has invested billions on the understanding that demand will follow. That capital is patient – deployed years ahead of profitability – but it is conditional, rather than guaranteed, and is predicated on a stable regulatory framework. Months of speculation about whether the Government would weaken the mandate, followed by significantly expanded flexibilities in April 2025, have already created uncertainty. Further weakening would slow deployment precisely when it needs to accelerate, leaving the drivers who most need a comprehensive network with a weaker proposition.

The impact would extend beyond the charging sector: it would send a damaging signal to every long-term infrastructure investor that UK policy commitments – even those embedded in law – cannot be relied upon. At a time when the Government is seeking to attract investment, drive growth and demonstrate that the UK is open for business, this would undermine that message.

The Government has an alternative: the virtuous cycle. Rather than weakening the targets, it can fix the costs that are making them harder to meet. Addressing the cost disadvantages we have set out would relieve the upward pressure on prices and improve the commercial case for deployment across the UK. A comprehensive public charging network that is affordable for all, not just most drivers, would give more drivers the confidence to switch – addressing one of the key perception barriers that holds back demand. Higher demand would mean higher utilisation, driving stronger returns and continued or even increased investment. The mandate becomes easier to meet, not by lowering the bar but by removing some of the key barriers to meeting the bar.

Our recommendations

The Cost of Public Charging Review, currently underway and reporting in Q3 2026, is the Government's opportunity to finish the job and relieve pressure on the ZEV mandate. The mandate itself will be reviewed later in 2026, with the outcome announced in 2027.

We urge the Committee to press for action on the following:

1. Maintain the ZEV mandate without dilution. The mandate is the foundation of investment confidence in the charging sector. It is what enabled £6 billion to be committed years ahead of profitability. Any signal that the mandate may be further weakened – or actual weakening – would undermine that confidence, slow deployment, deter drivers from making the switch, and ultimately would make the transition harder, not easier.

2. Reform electricity standing charges. The Targeted Charging Review has created a system in which fixed network charges represent up to 70% of some operators' energy costs. These costs bear no relationship to the electricity actually consumed and add 20-30p/kWh to the cost of rapid charging at typical utilisation levels. Government should rapidly identify and implement a way to address these charges – whether through establishing a relief fund or by accelerating regulatory proposals to reverse changes made under the Targeted Charging Review.

3. Equalise VAT between home and public charging. Drivers who charge at home pay 5% VAT. Drivers who charge on the public network pay 20%. This disparity disadvantages precisely those drivers who have the fewest alternatives – and who are often least able to absorb additional costs. We call on the Government to reduce VAT on public charging to 5%, matching the rate for home charging.

4. Extend policy levy relief to public charging. Households and energy-intensive industries benefit from relief on the policy levies applied to electricity bills, with additional support rolling out soon as part of the British Industrial Competitiveness Scheme. Charge point operators receive no such protection from these levies, despite playing an essential role in decarbonising transport. These currently add around 6p/kWh to operators' costs, and are expected to rise further to 10p/kWh by 2030. Extending or replicating existing relief mechanisms to public EV charging would reduce costs for operators and drivers alike, without requiring new policy architecture.

5. Include public EV charging in the Renewable Transport Fuel Obligation. The RTFO is described as the UK's main policy tool for decarbonising transport, yet it excludes renewable electricity – the principal sustainable fuel driving this transition. Equivalent schemes in the EU include electricity and generate additional revenue for charge point operators worth 2.5–8.5p per kWh. Including public charging in the RTFO would create a revenue stream that operators could use to reduce prices or accelerate deployment, without cost to the taxpayer.

Beyond specific reforms, the sector needs confidence that the policy environment will remain stable. The charging sector plans and invests over multi-year horizons and is currently on a high-growth trajectory. Repeated uncertainty about the direction of policy – on the mandate, on our costs, on the transition itself – makes investment harder to justify and slows deployment. Clear, consistent signals enable the private sector to do what it does best: invest, build, and deliver.

Conclusion

The electric vehicle transition is working. We have shown what the industry can deliver when conditions are right: £6 billion in committed private investment, nearly 88,000 chargers built across the country (a doubling of the network in three years), and a charging provision that offers drivers the confidence that manufacturers need to meet their ZEV mandate targets. And the transition has demonstrated that EVs can be the cost-effective option, if policy supports it.

The charging sector responds to signals. If the Government acts decisively to send positive ones – on costs, on commitment, and on the mandate – we can keep and even accelerate the virtuous cycle: a growing network, the conditions for competitive pricing and a transition that is more affordable for all.

We would welcome the opportunity to discuss these issues with the Committee in oral evidence and to provide any further information that would assist the inquiry.

January 2026

Endnotes