A Fair EV Transition: Shared Core (v1.0)

Date: 28 November 2025
Author: EV Groups Nexus (Rob Vowles), with EVA England insights and public sources
Purpose: Provide a concise, evidence‑based foundation to argue for a fair, affordable, and accessible EV transition—particularly for drivers without home charging—while engaging constructively with government and industry on eVED, VAT, accessibility, and public charging costs.

1) Executive Summary

EV adoption and charging infrastructure are growing rapidly, but cost and access are increasingly unequal. Drivers who rely on public charging face higher prices and a 20% VAT penalty, while accessibility for disabled drivers remains limited on the ground. With the government’s eVED (3p/mile for EVs, 1.5p/mile for PHEVs from April 2028) now under consultation, the policy must be introduced alongside measures that fix these inequities—otherwise we risk a two‑tier system that undermines confidence and fairness.
Key facts: Public network +22% YoY to 86,798 charge points; rapid prices average 76p/kWh; only ~2.2% of on‑street chargers are accessible; eVED will be collected via DVLA, reconciled at MOT, with no trackers. [bing.com], [chargeuk.org], [gov.uk]

2) The State of Play

2.1 Adoption is spreading via the used market

• Used BEVs surged in Q3 2025: transactions up 44.4% to 80,614, taking a record 4.0% market share (≈one in 25 buyers). This shows that affordability gains are reaching mainstream buyers through the second‑hand channel. [heycar.com]
• The used car market is near pre‑pandemic levels; Q2 2025 used BEV transactions were up 40% (68,721 units), underlining growing demand beyond early adopters. [rossmartin.co.uk], [assets.pub…ice.gov.uk]

2.2 Infrastructure growth is strong, but costs bite

• The UK public network hit 86,798 charge points across 44,142 locations in Oct 2025—+22% YoY. Ultra‑rapid (150kW+) devices grew 51% YoY to 9,290, improving en‑route viability. [bing.com], [bsigroup.com]
• Average PAYG prices: 53p/kWh for slow/fast and 76p/kWh for rapid/ultra‑rapid (Oct 2025). High per‑kWh costs on the public network are the biggest barrier for driveway‑less households. [chargeuk.org]

2.3 Accessibility remains a critical gap

• Government now has powers to mandate PAS 1899 accessible‑charging standard if voluntary progress remains slow; an estimated 1.35 million disabled drivers will rely on public charging by 2035. [evinfrastr…eguide.com]
• A recent BSI review confirms significant barriers—heavy cables, reach and layout issues—and recommends updates (split on/off‑street, clearer technical clauses, open data flags for accessible points). [motability…ion.org.uk]
• FOI research shows 38% of councils have no adapted or PAS‑compliant on‑street chargers; accessible on‑street units remain ~2.2% despite network growth. [gov.uk]

2.4 Policy context: eVED and PCPR 2023

• eVED (consultation published Nov 26, 2025): 3p/mile (EV), 1.5p/mile (PHEV) from April 2028; no trackers, mileage reconciled at MOT; administered by DVLA, indexed to CPI after 2029–30. 
• Public Charge Point Regulations 2023: require contactless payment, roaming (by Nov 2025), price transparency, open data, and 99% reliability for rapid charge points—vital for drivers dependent on public charging. [independent.co.uk], [gov.uk]

3) The Fairness Gap

3.1 Driveway Divide (price & VAT)

• Public‑reliant drivers pay more per kWh and 20% VAT on public charging, compared to 5% VAT at home—a structural unfairness for the ~30–40% of households without off‑street parking. [chargeuk.org], [independent.co.uk]
• With rapid PAYG at ~76p/kWh, total running costs can approach (or exceed) efficient petrol/diesel for frequent public charging users—especially when adding future eVED rates. [chargeuk.org],

3.2 Accessibility Divide

• Even as the network grows, accessible provision is not keeping pace. With 1.35m disabled drivers expected to rely on public charging by 2035, slow PAS 1899 uptake risks exclusion and costly retrofits later. [evinfrastr…eguide.com], [gov.uk]

4) Recommendations (Policy & Practice)

These are the core asks we will put to HM Treasury, DfT/OZEV, Ofgem, local authorities, CPOs, and industry partners.

4.1 Align VAT for fairness

Reduce VAT on public EV charging to 5% for on‑street/kerbside/community chargers to match domestic electricity—directly addressing the driveway divide and making eVED workable for all. ChargeUK’s affordability plan and EVA England’s survey evidence both highlight the cost pressure from commercial tariffs and VAT. [accessible…ity.org.uk], [evpowered.co.uk]

4.2 Introduce eVED guardrails

• Fair mileage allowance (e.g., banding for essential commuting/work miles) or tiered eVED rates to avoid disproportionate impact on high‑mileage workers without home charging.
• In‑year adjustments and soft tolerance bands for estimation errors, mirroring HMT’s stated approach to reconciliation via MOT readings. [Steering C…2025 Rev 2 | PDF]

4.3 Mandate PAS 1899 on a timetable

• Require PAS 1899 compliance for all new public chargepoints by a target date, supported by a transitional retrofit fund where feasible.
• Implement BSI recommendations: split on‑street/off‑street requirements; clarify component heights/cable weights; and add open data flags so drivers can easily find accessible chargers. [motability…ion.org.uk], [evinfrastr…eguide.com]

4.4 Accelerate workplace & cross‑pavement solutions

• Expand workplace charging programmes (beyond schools/NHS) to large public and private employers and local anchor institutions.
• Scale cross‑pavement technologies (gullies, safe cable management) via streamlined licensing/planning and grants—reduce known costs/delays and give driveway‑less households access to cheaper home tariffs. (EVA England and sector coverage have repeatedly called for this.) [evpowered.co.uk]

4.5 Enforce PCPR 2023 & encourage dynamic pricing

• Monitor and publish PCPR compliance dashboards (contactless, roaming, uptime, pricing).
• Encourage dynamic off‑peak pricing on public AC to mirror home tariff savings where grid conditions allow. [independent.co.uk]

4.6 Strengthen the used EV market

• Introduce standardised battery health reports for used EVs; explore low‑cost consumer loans and residual‑value measures to stabilise pricing and confidence—accelerating mainstream adoption via second‑hand channels highlighted by SMMT. [heycar.com]

5) Implementation Enablers

5.1 Tech‑friendly, privacy‑safe mileage capture (opt‑in)

• Offer OBD‑II / secure Bluetooth odometer capture as opt‑in (no location data) with photo fallback; add anomaly prompts (e.g., mileage lower than last MOT). This reduces admin for drivers/garages and aligns with HMT’s no tracker position.

5.2 PCPR monitoring toolkit

• Work with DfT/OZEV to publish quarterly PCPR scorecards by region/network (contactless, roaming, uptime, pricing transparency), leveraging open data provisions. [independent.co.uk]

6) “Driver Voice” Annex (for Public Brief)

Summarise sentiment—fairness for working drivers; driveway‑less households facing 20% VAT; desire for essential‑travel allowances; trust in the transition. (We’ll include edited, civil quotes from the petition and EVA England’s survey to ground the narrative.)
(Examples to be inserted after you approve selections.)

7) Calls to Action

• To HM Treasury: Implement VAT alignment for public charging; embed fair mileage allowances within eVED; publish modelling of distributional impacts on driveway‑less and high‑mileage workers.
• To DfT/OZEV & Local Authorities: Set a PAS 1899 mandate date; fund retrofits where viable; accelerate workplace chargingand cross‑pavement installations; track PCPR compliance. [independent.co.uk], [evinfrastr…eguide.com]
• To Ofgem: Explore tariff/regulatory measures that support dynamic pricing and reduce standing charge pressures on CPOs (reflecting ChargeUK concerns), so savings can be passed through to drivers. [accessible…ity.org.uk]
• To CPOs & Landlords: Ensure contactless + roaming, publish transparent off‑peak tariffs, and prioritise PAS 1899‑ready site designs.

8) Appendices to build (for the Internal Pack)

• Appendix A: Charts (SMMT used EV surge; Zapmap devices growth; Zapmap price index bands). [heycar.com], [bing.com], [chargeuk.org]
• Appendix B: PCPR 2023 compliance checklist (contactless, roaming by Nov 2025, uptime, pricing, open data). [independent.co.uk]
• Appendix C: Draft letters/templates to HMT/DfT/OZEV/Ofgem/LAs (VAT alignment, eVED guardrails, PAS 1899 mandate, workplace/cross‑pavement programmes).
• Appendix D: Battery health report proposal & used‑EV loan concept (with references to SMMT market data). [heycar.com]

9) Notes on Citations (for publication & stakeholder use)

• SMMT used EV market: Q3 2025 used BEVs +44.4% to 80,614; 4% share. [heycar.com]
• Zapmap infrastructure: 86,798 devices; +22% YoY; ultra‑rapid +51% YoY. [bing.com], [bsigroup.com]
• Zapmap price index (Oct 2025): 53p/kWh slow/fast; 76p/kWh rapid/ultra‑rapid. [chargeuk.org]
• Motability/PAS 1899: mandate powers & 1.35m disabled drivers relying on public by 2035; BSI review recommendations; council accessibility FOI. [evinfrastr…eguide.com], [motability…ion.org.uk], [gov.uk]
• eVED consultation: 3p/mile EV, 1.5p/mile PHEV; DVLA/DVSA process; no trackers; CPI indexation. [Steering C…2025 Rev 2 | PDF]
• PCPR 2023: contactless, roaming (Nov 2025), uptime, transparency, open data. [independent.co.uk], [gov.uk]