What equipment and installation requirements?

European and French regulations have steadily tightened the requirements for equipping buildings, whether residential or commercial, and company vehicle fleets, to support the transition to electric mobility.

Here we take a closer look at these obligations, both current and future, and try to make them as clear as possible.

It is important to keep in mind that there are two types of obligation:

• -that of pre-equipping parking spaces with electrical infrastructure, so as to simplify the subsequent installation of charging points;

• -the obligation to equip parking spaces with charging points.

These obligations then vary depending on:

• -whether the building is new or old ;
• -the main use of the building: offices, housing, mixed use, etc.

 

Pre-equipment obligations

This obligation is designed to facilitate the subsequent installation of charging points. It mainly involves installing conduits for electrical cables and power supply and safety devices.

To supply these charging stations, electricity must be supplied :

• -either via a low-voltage main switchboard from the building’s internal electrical installation – this is what we prefer with Wattsy for an initial installation ;
• –or via a public electricity network structure located on the building’s site.

For pre-equipment, the LOM requires the installation of conduits whose size allows a square passage of at least 100 mm on each side to carry the energy to the charging point.

In each of these options, the size of the main LV board must enable at least 20% of the car park’s total capacity to be supplied, with a minimum of one space equipped with a charging point. The power required will vary according to the number of spaces available (see IV).

Another change has also been announced: from 2027, once it has been transposed into French law, the European Directive on the Energy Performance of Buildings (EPB) 2024/1275 will increase the obligation to install charging points in car parks on non-residential sites.

	Spaces to be pre-equipped for parking lots with more than 10 spaces		Additional obligations PEB directive
	Between11 and 20	> 20
New or substantially renovated residential buildings	100%.
New non-residential buildings or those undergoing major renovation (1/4 of the building’s value)	20% of spaces including 2% accessible to PRM		By January 1, 2027 – Parkings >20 spaces : 10% of spaces equipped or 50% pre-connection
New or substantially renovated mixed-use buildings with predominantly residential use	100%	In proportion to the use of spaces
New mixed-use buildings or those undergoing major renovation, with predominantly non-residential use	20% of spaces 2% for PRMs

 

The LOM also distinguishes obligations for existing buildings

The criterion here is the date on which the building permit was filed. The legislator’s logic was twofold: the newer the building and the larger the parking area, the more pre-equipped it should be.

Date of building permit	Car park capacity	Pre-equipment required	Capacity to be reserved at the main LV board	Charging stations to be installed from January 1, 2025
After March 11, 2021	Parking > 10 spots	20%	20%	1 charge point for every 20 parking spaces, including at least 1 point accessible to PRMs
Between January 1, 2017 and March 11, 2021	Parking < 40 spots	10%.	10%
	parking > 40 spots	20%	20%
Between 1 January 2012 and 1 January 2017	All car parks	10%
Before January 1, 2012	Parking 20 spots & urban area > 50 000 inhabitants	10%
	parking 40 spots & urban area< 50 000 inhabitants	5%

Obligations to install charging points

For buildings that are not for residential use, such as offices, shops or public services, the obligations set out in the LOM will change from 1 January 2025.

For the implementation of this obligation in 2025, if the work required to adapt the electrical network is considered to be significant (i.e. the cost of resizing the building’s connection to the electrical network upstream of the main LV board exceeds the cost of work on the downstream part), the number of charge points is limited so that the work upstream of the main LV board (including the main LV board) does not exceed the total cost of work downstream of the main LV board.

The French “Climat et Résilience” law of August 22, 2021 also requires local authorities to provide similar facilities by January 1, 2025 (parking lots with more than 20 spaces managed by a public service delegation, a public authority, or via a public contract).

In addition to the 2025 deadline, the implementation of the EPB directive is further away, with obligations starting at smaller parking lot sizes, from 5 spaces upwards.

	Until December 31, 2024	From January 1, 2025	From 2026/2027 (PEB)
New parking lot or major renovation, up to 10 spots	1 charging point (with access to PRMs), ie. 10%		New parkings > 5 spots : 50% of spots equipped; only for office buildings 20% of spots equipped for non-residential buildings 1 charging point in residential buildings (if the parking >>3 spots)
New parking lot or major renovation of more than 200 spaces	2, including 1 with access to PRM; ie. 1%	1 charging point for every 20 spaces, i.e. 5%. At least 1 spot for PRM. For parking lots with more than 200 spaces: at least 2 PRMs, including 1 for exclusive use.
Existing parking lots with more than 20 spaces			On 01/27 – Car parks >20 spaces: 10% of spaces equipped or 50% pre-connected

 

Beyond infrastructure, obligations for greening the company fleet?

The LOM also imposes obligations on companies with fleets of more than 100 vehicles to reduce their environmental impact according to the following timetable:

1. From January 2022: 10% of new vehicles must be low-emission (electric, plug-in hybrid, CNG, hydrogen, etc.).
2. From 2024: this threshold rises to 20% for fleets of over 100 vehicles.
3. From 2027: the obligation for low-emission vehicles rises to 40% of new vehicles purchased.
4. By 2030: companies must aim for 70% low-emission vehicles in their new vehicle purchases.

Companies must therefore incorporate this transition into their fleet renewal plans in order to comply with the legislation, which also makes the pre-equipment and equipment obligations in commercial buildings less theoretical.

 

Power requirements to meet equipment obligations

In addition to these general equipment obligations, under French law there is also an obligation to size electrical installations in order to avoid having to reinvest in the infrastructure several times over. This obligation is broken down as follows:

Number of parking spaces	Charging points in parking lots (for commercial or public service vehicles)	Charging points in parking lots for other vehicles
10 ≤ N ≤ 20	15 kVA	22 kVA
21 ≤ N ≤ 40	22 kVA	33 kVA
41 ≤ N ≤ 100	30 kVA + 6 kVA (for every 10 pitches over 50)	44 kVA + 8 kVA (for every 10 pitches over 50)
101 ≤ N < 200	60 kVA + 3.6 kVA (for every 10 slots over 100)	84 kVA + 5 kVA (for every 10 slots over 100)
N > 200	96 kVA + 0,2 kVA x (N-200)	134 kVA + 0,28 kVA x (N-200)

(article R111-14-3 of the Code de la construction et de l’habitation).

What about 2-wheelers on the company premises?

The LOM extends the obligation to provide cycle parking facilities when work is carried out on car parking facilities. The resulting regulations specify the security features, standardize the application to different types of construction and set a minimum surface area per space and a minimum number of spaces for all cycle parking areas.

% Places to be provided	Today with the LOM	From 2026/2027 (PEB)
New tertiary or industrial buildings	15% of the total number of employees simultaneously accommodated in the building	The EPB Directive requires the presence of bicycle parking spaces of at least 15% of the average capacity or 10% of the total capacity of use of non-residential buildings, taking into account the space also required for bicycles larger than standard bicycles.
Tertiary or industrial buildings with parking > 10 spaces under construction	The space reserved for secure parking includes a minimum number of spaces for employees or agents set at 10% of the total number of people accommodated simultaneously in the buildings.
Existing tertiary buildings, mainly used as workplaces, parking > 10 spaces	The space reserved for secure bicycle parking must include a minimum number of spaces for employees or agents, set at 10% of the total number of people simultaneously accommodated in the buildings. The obligation also applies to any co-owner whose co-ownership lot or lots include at least 10 employee parking spaces. In this case, the co-owner’s lot(s) must include a minimum number of spaces for employees or agents, set at 10% of the total number of people accommodated simultaneously on these premises.

(Source : see the full text of the EU directive here)

 

What are the key takeaways ?

Obligations linked to the energy transition in companies are becoming more stringent, particularly for office car parks.. With the LOM already in place, and the forthcoming EPB 2024/1275 directive, companies will not only have to anticipate the need for charging stations for their employees’ electric vehicles, but also provide additional infrastructure to enable these installations to be scaled up.

These measures are designed to support the growth of the electric vehicle fleet and encourage more sustainable mobility in companies, if only because they are not accompanied by a clearly defined penalty system.

However, this could soon change because, unlike the LOM, the EPB Directive requires States to introduce a system of effective and dissuasive penalties for infringements of the national provisions deriving from the Directive:

“Member States shall lay down the rules on penalties applicable to infringements of the national provisions adopted pursuant to this Directive and shall take all measures necessary to ensure that they are implemented. These penalties must be effective, proportionate and dissuasive.” (Article 34).

This means that States must not only transpose the directive, but also provide for penalties in the event of non-compliance.which was not an obligation in texts such as the LOM. It is therefore in your interest, as companies or property managers, to anticipate these deadlines by working now on the conditions for electrifying your fleets and car parks.