COMMISSION STAFF WORKING DOCUMENT Guidance on regulatory sandboxes and living labs in the EU for vehicle-to-grid pilots Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE EUROPEAN COUNCIL, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS ELECTRIFICATION ACTION PLAN
Date: 2026-07-17
Institutions: Directorate-General for Energy, European Commission
Subjects: EU energy policy, action programme, electrical energy, energy crisis, energy production, energy supply, energy transition, price of energy, reduction of gas emissions, renewable energy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 17.7.2026  SWD(2026) 595 final  COMMISSION STAFF WORKING DOCUMENT Guidance on regulatory sandboxes and living labs in the EU for vehicle-to-grid pilots Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE EUROPEAN COUNCIL, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS  ELECTRIFICATION ACTION PLAN {COM(2026) 595 final} - {SWD(2026) 596 final}  
 
 
 
 
Contents 

1. 
2. 
3. 

INTRODUCTION .................................................................................................................. 3 
LEGAL AND POLICY CONTEXT FOR EXPERIMENTATION ON V2G ........................ 4 
REGULATORY SANDBOXES FOR V2G PILOTS ............................................................. 6 

3.1.  Background............................................................................................ 6 
3.2.  Existing regulatory sandboxes and national conducive enforcement of 
EU legislation ........................................................................................ 7 
3.3.  Opportunities and possible measures for regulatory sandboxes within 
the EU framework ............................................................................... 10 
4.  ADDITIONAL EXPERIMENTATION TOOLS FOR V2G PILOTS .................................. 17 

Annex: Examples outside the European Union ............................................. 19 

1 

 
 
 
 
 
 
Glossary 

Term or acronym 

CAPEX 

CPO 

DMD 

DSO 

ED 

EMSP 

EV 

EVSE 

GHG 

JRC 

MS 

OEM 

NRA 

PV 

R&D 

R&I 

RES 

SME 

TSO 

V1G 

V2G 

V2X 

Meaning or definition 

Capital expenditure 

Charging point operator 

Dedicated measurement device 

Distribution system operator 

Electricity Directive 

E-mobility service provider 

Electric vehicle 

Electric vehicle supply equipment 

Greenhouse gas 

Joint Research Centre 

Member State 

Original equipment manufacturer 

National regulatory authority 

Photovoltaics 

Research and development 

Research and innovation 

Renewable energy sources 

Small and medium-sized enterprises 

Transmission system operator 

Unidirectional smart charging 

Vehicle-to-grid 

Vehicle-to-X1  

1 X= everything: home, buildings, vehicle, load, grid, … 

2 

 
 
 
 
 
 
 
 
 
1.  Introduction 

The evolution of the EU’s electricity system, with an increasing role of variable renewable 
sources,  is  leading  to  growing  flexibility needs.  These  needs  will  double  in  Europe  by 
20302. 

The Draghi report highlighted the need for closing the innovation gap with the US and 
China,  especially  in  advanced  technologies.  It  also  stressed  the  challenge  of  translating 
innovation  into  commercialisation  and  the  regulatory  hurdles  faced  by  innovative 
companies that want to scale up in Europe. 

To  make  progress  in  that  direction,  the  Industrial  Action  Plan  for  the  European 
Automotive sector, published in March 2025, has announced an initiative for the creation 
of regulatory sandboxes specifically designed for Vehicle-to-Grid (V2G) pilot projects to 
address  regulatory,  technical  and  market  challenges  before  large-scale  deployment.  To 
support Member States progress, this Staff Working Document (SWD) outlines options 
and  examples  for  establishing  regulatory  sandboxes,  by  utilising  effectively  the  current 
Union legislative framework and exploring possibilities for experimentation with testbeds 
and living labs and for regulatory learning.  

To reconcile innovation and regulation, the objective of this SWD is threefold: 

1.  Explain how the current Union legislative framework can be enforced effectively 

by Member States to support and scale up V2G services. 

2.  Explore how Member States could utilise experimentation tools3 such as regulatory 
sandboxes,  testbeds  or  living  labs,  in  order  to  support  the  deployment  of  V2G 
technologies  

3.  Illustrate  how  some  Member  States  have  already  implemented  such  legislative 

frameworks to allow possible replication of best practices. 

Regulatory  sandboxes  mean  structured  frameworks  that  allow  regulatory  sandbox 
participants  to  experiment  with  an  innovation  for  a  limited  time  in  a  controlled 
environment, under the supervision of one or more competent authorities, and that results 
in evidence-based regulatory learning. 

Living labs are another widespread experimentation tool to co-create, prototype, test and 
upscale innovative solutions to (local) needs in real-life settings. 

To prepare the ground for this work, the Commission organised a  consultation meeting 
with Member States and stakeholders on 23 June 2025. The participants underlined4 the 
importance of compliance testing through regulatory sandboxes across Europe. The 2024 
joint  report  of  the  European  Coalition  of  the  Willing  on  bidirectional  charging  led  by 
Germany, which associated around 500 stakeholders, also proposed to “create a sandbox 
environment by enabling and promoting pilot projects that investigate the contribution of 
bidirectional  charging  to  grid  stability,  focusing  on  customer  acceptance  and  grid 

2 ACER-CEER 2024 Market Monitoring Report on Energy Retail and Consumer Protection 
3 As referred to in the ‘Guidance on regulatory sandboxes, testbeds and living labs in the EU’ (SWD(2023) 
277/2 final) 
4 They also commented on the role and definitions of EMSPs and aggregators, the involvement of DSOs and 
TSOs in virtual power plants, and the potential of EVs to support the grid in emergencies. 

3 

 
 
 
serviceability.  This  could  take  the  form  of  a  time-limited  trial  phase,  for  exempting 
temporarily stored electricity from taxes, levies, surcharges, and some grid charges”5. 

Furthermore, on 20 May 2026, the Smart Energy Expert Group (SEEG), the Sustainable 
Transport Forum (STF), and the European Coalition of the Willing (CoW) on bidirectional 
charging  published  a  joint  Report6  identifying  key  roles,  user  scenarios,  use  cases, 
governance  principles,  and  interoperability  requirements  that  should  now  be  tested  and 
implemented across the EU. 

2.  Legal and policy context for experimentation on V2G 

The EU regulatory and policy framework for the automotive sector supports the transition 
to  clean  mobility,  ensuring  that  it  contributes  to  climate  neutrality  and  to  strategic 
independence. This translates into clear incentives and rules on the transition from internal 
combustion engine (ICE) to zero emission vehicles. 

With the growing share of electric vehicles (EVs) in the EU vehicle fleet, smart charging 
(V1G), as well as bidirectional charging and related vehicle-to-grid (V2G) services can 
facilitate  the  absorption  of  renewable  generation  and  the  decarbonisation  of  the  energy 
system,  provide  flexibility  to  the  electricity  system  and  reduce  the  need  for  grid 
investments.  

In particular, V2G has the potential to generate significant cost savings for consumers (both 
private  and  commercial).  By  remunerating  them  for  reinjecting  electricity  from  their 
vehicle batteries into the grid during peak periods or whenever electricity prices are high, 
V2G could offset a substantial share of charging costs, up to the full amount with the right 
conditions.  

The current Union legislative framework provides incentives for tapping on the potential 
of V2G services to alleviate the grid and to save energy and costs for EV users:  

•  The  Renewable  Energy  Directive  (RED)7  allows  Member  States  to  choose 
between a 2030 target of 29% of renewables for the transport sector (all modes), or 
a  reduction  of  14.5%  of  the  GHG  intensity  for  fuels.  Its  Article  20a  on  energy 
system  integration  and  e-mobility  includes  provisions  to  facilitate  bidirectional 
charging.  In  particular,  it  requires  battery-related  data  sharing  at  no  cost  in  real 
time8, or ensuring that private recharging points enable smart charging, and where 
appropriate,  bidirectional  charging. 
requires  non-discriminatory 
participation of mobile assets in electricity markets. 

It  also 

•  The Alternative Fuels Infrastructure Regulation (AFIR)9 foresees assessments 
by  Member  States  every  3  years  on  the  potential  contribution  of  bi-directional 

5 https://www.bundeswirtschaftsministerium.de/Redaktion/DE/Downloads/P-R/coalition-of-the-willing-on-
bidirectional-charging-en.pdf?__blob=publicationFile&v=8 
6https://op.europa.eu/en/publication-detail/-/publication/f56915a6-5582-11f1-b3e2-
01aa75ed71a1/language-en 
7Directive (EU) 2023/2413 of the European Parliament and of the Council of 18 October 2023 amending 
Directive (EU) 2018/2001, Regulation (EU) 2018/1999 and Directive 98/70/EC as regards the promotion of 
energy from renewable sources  
8 A Commission guidance on the application of these requirements was adopted in July 2025 (C/2025/4104) 
9 REGULATION (EU) 2023/1804 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
of  13  September  2023  on  the  deployment  of  alternative  fuels  infrastructure,  and  repealing  Directive 
2014/94/EU 

4 

 
 
 
charging.  Its  Delegated  Act10    requires  that  from  1  January  2027  all  recharging 
points  comply with  the relevant  communication protocol  that enables smart and 
bidirectional services (ISO 15118-20).  

•  The Electricity Directive11 and Electricity Regulation12 support the deployment 
and use of non-fossil flexibility sources, in particular through a specific assessment 
of flexibility needs at Member State level, and an indicative national objective for 
non-fossil flexibility. It provides the basis for non-fossil flexibility support schemes 
as  reflected  in  the  Clean  Industrial  Deal  State  Aid  Framework13.  The  electricity 
market framework also enables time of use tariffs, requests dynamic contracts for 
end  users,  but  also  enables  citizens  to  have  more  than  one  metering  and  billing 
point covered by a single connection point for their premises or the right to request 
the installation of a smart meter within four months. This framework provides for 
the  removal  of  double  charges  for  active  customers  that  own  an  energy  storage 
facility. 

In  the  context  of  the  profound  transformation  of  the  energy  and  transport  systems, 
experimentation is key to enable innovation and bring new technologies to market 
deployment  and  their  integration  in  the  energy  system.  If  enforced  effectively,  the 
existing  Union  legislation  allows  Member  States  to  create  a  conducive  framework  for 
innovative approaches to bidirectional charging. In addition, some Member States have in 
their national legislation provisions enabling the establishment of regulatory sandboxes or 
other forms of experimentation. Based on this national legislation, there are some existing 
regulatory sandboxes that are presented as examples below. 

In  2023,  the  Commission  published  a  Staff  Working  Document  on  ‘Guidance  on 
regulatory sandboxes, testbeds and living labs in the EU’14,  presenting different tools 
enabling experimentation, namely regulatory sandboxes, testbeds and living labs. It also 
provided a specific focus on the energy sector.  

In December 2025, the European Commission proposed amendments to  this framework 
through the Automotive Package, setting out rules for the industry and Member States to 
adapt to clean mobility, while ensuring the competitiveness of the industry. The proposal 
on the Automotive Omnibus15 allows for the introduction of harmonised requirements 
into type-approval that would support the deployment of V2G. 

10 Commission Delegated Regulation (EU) 2025/656 of 2 April 2025 amending Regulation (EU) 2023/1804 
of the European Parliament and of the Council as regards standards for wireless recharging, electric road 
system, vehicle-to-grid communication and hydrogen supply for road transport vehicles 
11 DIRECTIVE (EU) 2024/1711 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
of 13 June 2024 amending Directives (EU) 2018/2001 and (EU) 2019/944 as regards improving the Union’s 
electricity market design 
12 REGULATION (EU) 2024/1747 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
of 13 June 2024 amending Regulations (EU) 2019/942 and (EU) 2019/943 as regards improving the Union’s 
electricity market design 
13 Framework for State Aid measures to support the Clean Industrial Deal (Clean Industrial Deal State Aid 
Framework) 
14 SWD(2023) 277/2 final 
15  COM(2025)  993  final:  “  The  Commission  is  empowered  to  adopt  delegated  acts  aimed  at  setting  out 
technical  requirements  for  pure  electric  vehicles  (PEV)  and  off-vehicle  charging  hybrid  electric  vehicles 
(OVC-HEV), as regards their communication and hardware interface of those vehicles with the recharging 
infrastructure,  the  electricity  grid  and  the  stationary  power  systems  capable  of  supporting  smart  and 
bidirectional charging functionalities”. 

5 

 
 
 
3.  Regulatory Sandboxes for V2G pilots 

3.1.  Background 

Over the past decade, bidirectional charging has developed step by step. Initial progress 
came from small-scale pilot  projects  (such as Parker, GridMotion, and Electric Nation) 
which explored the flexibility potential of EVs, proved that V2G was technically viable, 
and  examined  user  behaviour.  Horizon  Europe,  the  EU’s  key  funding  programme  for 
research and innovation, has funded demonstration projects to accelerate the development 
of V2X16 technologies and smart, interoperable and inclusive EV charging solutions, and 
overcome barriers to large-scale deployment17. 

As these pilots expanded to larger fleets and evolved into operational urban ecosystems, 
the main barriers shifted. As new models were designed and produced, technical feasibility 
was  largely  resolved.  However,  regulatory  barriers  to  deployment  were  identified, 
especially  at  national  level,  preventing  related  business  models  from  emerging:  double 
charges and taxation for storage (during charge and discharge), lack of time-of-use network 
charges, issues with metering, limited market access for aggregators, lack of harmonization 
of grid connection requirements across the EU18, interoperability, etc.  

Several Member States began experimenting with (temporarily) relaxed or adapted rules 
to  trial  new  tariff  designs,  market  access  conditions,  metering  configurations,  and 
interoperability frameworks. This has been done both by adopting regulatory sandboxes or 
by adopting national laws that support bidirectional charging, in line with the EU enabling 
framework (see details in section 3.2 and 3.3). The Netherlands set up both a regulatory 
sandbox and a national-scale "living lab" for smart and bidirectional charging, In France, 
a commercial offer, backed by a regulatory sandbox, has been implemented to enable EV 
drivers to charge and drive at no cost using bi-directional charging. It can notably build on 
new negative network tariffs19 proposed by the national energy regulatory authority. 

This SWD illustrates these good practices, and clarifies relevant use cases for regulatory 
sandboxes for vehicle-to-grid pilots. It aims to support regulators, competent authorities 
and innovators efforts to enhance experimentation and innovation in the EU, and to bring 
solutions closer to market deployment. More generally, de-risking innovation and fostering 
regulatory learning in specific contexts will pave the way towards a long-term regulatory 
framework supporting large-scale V2G roll-out. 

16 V2X=Vehicle-to-everything (eg vehicle-to-buildings, vehicle-to-home, vehicles-to-load, vehicle-to-grid)  
17 See for example the V2X Cluster of projects: https://ev4eu.eu/v2xcluster/. 
18  Smarten  study  “Assessment  of  the  regulatory  framework  of  bidirectional  EV  charging  in  Europe” 
(December 2023) or EY/Eurelectric study “Plugging into potential: unleashing the untapped flexibility of 
EVs” (March 2025) 
19 Notably allowing consumers to be remunerated when they inject electricity into the grid at the right time 
(ie  when  electricity  price  is  high  or  renewables  production  is  low),  with  static  or  dynamic  predefined 
timeslots. 

6 

 
 
 
 
3.2. 

 Existing regulatory sandboxes and national enforcement 
of Union legislation 

3.2.1. Regulatory sandboxes 

There  are  two  national  regulatory  sandboxes  for  V2G  already  being  implemented  and 
others under development, at different levels of maturity.  

•  Utrecht’s  regulatory  sandbox  and  2026  Dutch  Bidirectional  Charging 

Roadmap  

Utrecht in the Netherlands is among the first European cities to have developed a full-scale 
V2G  ecosystem.  The  city  collaborates  closely  with  the  Dutch  DSO  Stedin,  charging 
operators, shared fleet operators and car manufacturers (including We Drive Solar, Renault 
and Hyundai) to integrate bidirectional charging into the local energy system. 

Before national or European standards for V2G existed, Utrecht and Stedin, supported by 
the national government in a subsidy scheme, jointly designated an official experimental 
zone where V2G could be legally tested under controlled conditions. This local regulatory 
sandbox allowed deviations from standard concession rules and technical regulations and 
enabled real-life experimentation with bidirectional charging. 

Key  features  of  this  regulatory  sandbox  included:  (i)  Installation  and  testing  of 
bidirectional chargers in a defined neighbourhood; (ii) Bilateral data exchange between the 
city,  the  DSO  (Stedin)  and  operators;  (iii)  Monitoring  of  technical  performance,  user 
behaviour and local grid impact; (iv) Using the lessons learned to inform later tenders and 
national discussions on flexibility markets and interoperability (ISO 15118, the National 
Charging Infrastructure Agenda – NAL). 

After the regulatory sandbox proved that V2G was technically and operationally feasible, 
Utrecht integrated V2G into its procurement for public recharging stations. The city moved 
step-by-step from incentivising V2G to making it a default requirement in new tenders. 

To complement the main city-wide concession for public charging, Utrecht introduced an 
open market model. This model allows mobility operators to apply for a permit to place a 
shared  station  next  to  their  own  recharging  point,  under  clear  and  non-discriminatory 
conditions. 

This approach ensures that: 

•  Any shared mobility provider can request a permit to install its own charger next 

to a station-based vehicle, under the same rules; 

• 

Innovative V2G solutions can still be deployed even if a specific provider is not 
part of the main concession; 

•  Use  cases  such  as  bidirectional  fleets  from  We  Drive  Solar  and  MyWheels  can 
scale in a way that remains compatible with the broader public charging strategy; 

•  A level playing field is maintained while still giving room for frontrunners and new 

business models. 

7 

 
 
The  Dutch  national  framework  establishes  the  legal  and  regulatory  environment  that 
facilitates  local  experimentation  and  the  gradual  integration  of  Vehicle-to-Grid  (V2G) 
technology into the energy system: 

•  The Electricity Act, along with upcoming Energy Act reforms, provides options 

for DSOs to participate in innovation pilots under specific conditions; 

•  The Experimental Regulation for Energy and Climate Innovation offers a formal 
foundation for municipal and cooperative experiments in the electricity domain; 

•  The  National  Charging  Infrastructure  Agenda  advocates  for  open  standards, 
market-driven procurement and interoperability across various Dutch regions; 

•  Guidance  from  the  Netherlands  Authority  for  Consumers  and  Markets  ensures 
DSO  neutrality  while  permitting  cooperation  in  pilots  fostering  the  energy 
transition. 

Utrecht’s  experience  demonstrates  how  local  regulatory  flexibility,  collaboration  with 
competent authorities and developers, coupled with national legal instruments and an open 
market design framework, can accelerate the deployment of V2G while ensuring equitable 
market access. This combination of a local regulatory sandbox, V2G-centric procurement 
and an open market model presents a viable blueprint for other European cities aspiring to 
develop similar ecosystems.  

On 22 June 2026, the Ministry of Infrastructure and Water Management sent its Roadmap 
on Bidirectional Charging to the Dutch House of Representatives20. It creates the best 
circumstances  for  national  scale  up  from  2030  (“national  action  agenda”).  From  2030-
2035, mass adoption is expected, with any vehicle being able to charge bidirectionally at 
any charging point. By then, bidirectional charging should also be required as a standard 
technology  in  tenders,  and  first  bidirectional  charging  sessions  will  occur  at  public 
charging points. This follows the Utrecht experience. 

•  The French regulatory sandbox facilitating commercial roll out of V2G  for 

citizens  

In  France,  the  Energy  and  Climate  Act  of  8  November  2019  established  a  regulatory 
sandbox in the energy sector. In certain cases, this mechanism enables the administrative 
authority  or  the  Energy  Regulatory  Commission  (CRE)  to  grant  temporary  exemptions 
(lasting  four  years  and  renewable  once)  to  project  developers.  This  allows  them  to  go 
beyond certain provisions of the Energy Code. 

Renault has been developing a V2G AC charging service since 2024. This offers an on-
board  bi-directional  charger,  a  bi-directional  recharging  point,  a  Mobilize  electricity 
contract  supplied  by  its  technology  partner  The  Mobility  House  and  a  smartphone 
application enabling the customer to schedule charging. The project is aimed at domestic 
and  non-domestic  consumers  with  a  low-voltage  connection  to  the  public  distribution 
network in mainland France. The project has successfully commercialised V2G technology 
in France for private customers with the Renault 5, and is offering a viable business model 

20 https://www.tweedekamer.nl/kamerstukken/brieven_regering/detail?id=2026Z14132&did=2026D31669 
8 

 
 
 
where  EV  owners  can  save  money  from  their  car  batteries.  The  V2G  Service  is  now 
extended to all Renault and Alpine Electric Vehicle. 

CRE  has  granted  temporary  exemption  to  The  Mobility  House,  which  will  be  able  to 
choose, for its light-duty  customers, an exemption  tariff option incorporating  signals  to 
encourage  these  users  to  adopt  behaviour  that  reduces  peaks  for  the  networks  and  the 
system.  The  services  have  therefore  developed  tariff  schedules  that  include  a  negative 
coefficient during peak withdrawal periods for injection flows. During the high season, all 
days will include two two-hour peak periods21.  

France is also currently reflecting about: 

• 

testing sub-metering– using recharging point dedicated MID-certified meters - in a 
single-supplier setup and, potentially, in a multi-supplier setup 

•  examining  the  technical  compatibility  between  third-party  metering  (charging 

stations) and metering installed in the houses at the connexion point. 

•  assessing 

in  specific 
the  contractual  possibilities  and  related  obstacles 
configurations: V2G + rooftop PV under a feed-in tariff scheme; V2H with self-
consumption where none of the two energy sources is allowed to feed electricity 
back into the grid. 

•  Dedicated  energy  contract  for  electric  vehicle  (charge  &  discharge  V2X), 

independent from home energy contract. 

3.2.2. National conducive enforcement of EU 

legislation 

Conducive regulatory frameworks can support innovative solutions. 

Double network charges on energy storage have been abolished in the vast majority of 
EU  Member  States22.  However,  this  does  not  mean  that  a  comprehensive  framework 
encompassing all energy storage technologies and establishing a level playing field with 
competitive  technologies  and  market  players  (such  as  generators  or  active  consumers) 
necessarily  exists.  In  some  cases,  inconsistencies  in  the  treatment  of  different  energy 
storage technologies are present; in others, energy storage faces negative discrimination 
compared to generation, while in some instances, it could be argued that efforts to promote 
the  deployment  of  energy  storage  have  led  to  overcompensation  with  positive 
discrimination compared to customers.  

The  Commission  is  adopting  a  legislative  proposal  on  future-proof  electricity  bills 
alongside this plan, which will ensure that network charges incentivise electrification, a 
flexible and system-friendly use of the grid, including treatment of storage installations 
and accelerating smart meter deployment. 

21 These peak periods will be set by the network operator and will occur between 7 a.m. and 10 a.m., and 
between 6 p.m. and 9 p.m. 
22 2026 JRC report on Implementation of Commission Recommendation on Energy Storage in the Member 
States: https://publications.jrc.ec.europa.eu/repository/handle/JRC144586 

9 

 
 
 
Regarding  energy  taxes  and  levies  that  energy  storage  facilities  face  among  the  EU 
Member States, a third of Member Staes imposes double energy taxes and another third 
granting only partial exemptions23.  

In addition to examples quoted in 3.2.1, other Member States have legislated: 

• 

In  Germany,  On  13  November  2025,  the  German  Parliament  adopted  an 
amendment to the Energy Industry Act (EnWG) removing the double charging of 
grid fees for electricity fed back into the grid24. E.ON and BMW then launched 
Germany's first commercial V2G product for citizens in 2026. Ford and Octopus 
Energy also introduced V2G charging for private customers in 2026. 

•  Sweden  proposed  changes  to  the  energy  tax  system  in  2018  to  prevent  double 

taxation on electricity storage25. 

• 

In Denmark, electricity used for EV charging is eligible for refund of electricity tax 
under  specific  conditions26.  Regarding  metering,  the  Dedicated  measurement 
device (DMD) in the wall box will be considered a ”commercial” metering point 
that can have a separate contract. 

• 

In the Netherlands, the initiative GOPACS27 already allows local flexible resources 
to compete in the wider grid market.  

3.3. 

 Opportunities and possible measures for experimentation tools 
within the EU framework  

Objective 

Considering  that  real-world  experience  is  crucial  to  accelerate  the  deployment  of 
bidirectional charging solutions, this SWD introduces how different experimentation tools 
have been utilised recently within this thematical field. In addition, it provides support to 
Member States to address regulatory, market, and technical challenges, thereby facilitating 
the provision of V2G services.  

By providing a structured yet flexible framework, as established in the Net Zero Industrial 
Act  (Regulation  (EU)  2024/1735),  regulatory  sandboxes  may  involve  a  temporary 
loosening  or  suspension  of  applicable  rules  during  the  test  under  certain  conditions. 
Competent  authorities  may  also  provide  participants  with  guidance  to  address  legal 
uncertainty  on  how  legal  rules  and  requirements  apply  to  specific  products  or  services 

23 2026 JRC report on Implementation of Commission Recommendation on Energy Storage in the Member 
States: https://publications.jrc.ec.europa.eu/repository/handle/JRC144586 
24 https://www.mobilityhouse.com/int_en/our-company/newsroom/article/german-parliament-removes-key-
barrier-to-bidirectional-charging-vehicle-to-grid-becomes-possible 
25  https://www.riksdagen.se/sv/dokument-och-lagar/dokument/proposition/vissa-kontrollfragor-och-andra-
fragor-pa_h503294/, 
https://smarten.eu/wp-content/uploads/2023/12/V2X-Enables-and-Barriers-
Study_11-2023_DIGITAL.pdf  
26 https://www.eu.dk/samling/20251/lovforslag/L25/index.htm?utm 
27 https://www.gopacs.eu/en/who-owns-gopacs/  

and 

10 

 
 
 
 
developed in the regulatory sandbox,  and collect insights on possible further regulatory 
action to strike the right balance between facilitating innovation and mitigating risks.  

Operational steps for regulatory sandboxes and other experimentation tools  

Competent authorities of Member States in which regulatory barriers limiting V2G roll-
out  have  been  identified  can,  on  a  voluntary  basis,  create  a  special  regime  within  their 
regulatory framework for a time-limited period, and with a defined scope.  

Following  the  consultation  with  Member  States  and  other  stakeholders,  the  following 
guiding principles for creating and operating these special regimes have been identified: 

-  Customers  and  operators  of  charging  infrastructure  (CPOs)  equipped  with 
bidirectional charging functionality register for a test phase with the DSO via their 
V2G service provider, Flexibility service provider or aggregator.    

-  Customers can register for the test phase of the V2G service beyond initial launch 
of  the  V2G  regulatory  sandbox,  thanks  to  a  permanent  window  or  successive 
rounds of submissions. 

-  Actions  suggested  for  experimentation  may  be  based  on  exemptions  from  the 
national regulatory framework (while always compliant with EU legislation), for a 
limited scope and limited period of time. They can relate to electricity taxation of 
energy stored, electricity network tariffs, remuneration with an incentive effect for 
customers, metering, grid codes, market access rules, local flexibility markets, V2G 
permitting, access to data, etc. All initiatives must comply with relevant legislation 
for example the Energy Taxation Directive. 

-  As relevant, customers, CPOs, DSOs, V2G service providers, Flexibility service 
providers or aggregators that have decided to subscribe to the test phase of the V2G 
service, participate in the relevant projects, and agree to share the necessary data 
for evaluation purposes. 

-  Feedback from stakeholders is published to support knowledge sharing and lesson 

learning for evidence-based decision making.   

A continuous dialogue between Commission services and voluntary Member States will 
allow the sharing of best practices and lessons learnt. This dialogue will happen every 6 
months, using an existing body, such as the current cooperation framework on smart and 
bidirectional  charging 
(D4E)/Sustainable  Transport  Forum 
(STF)/CoW28).  At  the  first  meeting,  Member  States  will  be  encouraged  to  identify  the 
opportunities and drivers for regulatory sandboxes and/or living labs at their level, ie by 
providing a list of concrete projects to be implemented.  

for  Energy 

(Data 

Scope 

Since a critical mass is needed to identify what business cases for V2G are commercially 
viable and scalable,  competent  authorities in  voluntary Member States  could  define the 
scope of the regulatory sandbox on the basis of the obstacles faced by the relevant  use 
cases and target pre-defined pools of private or corporate users, such as: households using 
private or shared charging infrastructure, corporate HDV or LDV fleets charging in depots 
(large lease companies, public car sharing, public transportation, municipalities, …), car 
sharing fleets in cities, etc. 

28 Coalition of the willing on bidirectional charging 

11 

 
 
   
 
 
 
Defining  the  scope  also  requires  reference  to  a  geographical  territory,  which  can  range 
from the whole national territory to e.g. specific regions, cities or islands. 

Moreover, if the measures listed below fit with V2G schemes, most of them would also be 
beneficial to V1G (smart charging). 

Participating  stakeholders  will  take  the  following  considerations  into  account:  Their 
involvement is expected to bring added value to the European mobility and transport value 
chain,  including  automotive  and  related  smart  mobility  sectors,  and  to  help  identify 
strategic domains that help enhance European competitiveness. 

Measures that Member States may take forward to advance V2G deployment 

This  section  shows  indicative  measures  that  Member  States  and  national  competent 
authorities could take to advance V2G deployment, possibly complemented by additional 
measures. This  list  has been shaped  with  stakeholders and Member States, highlighting 
existing provisions of EU legislation that are conducive for bi-directional charging: 

A-  National schemes of taxation and tariffs 

A1 - Prevent double taxation 

       What? The European Commission recommends Member States to take into account 
the  double  role  (generator-consumer)  of  energy  storage  when  defining  the  applicable 
regulatory  framework  and  procedures,  in  particular  when  implementing  the  Union 
legislation  concerning  the  electricity  market,  in  order  to  remove  existing  barriers.  This 
includes  preventing  double  taxation  […].  National  regulatory  authorities  should  also 
consider such a role when setting network charges and tariff schemes, in compliance with 
Union legislation29. 

Who? Member States and NRAs 

Why? To avoid that the same energy is taxed twice and improve the business case for 
V2G. 

A2 – Incentivise grid-friendly behaviours through tariffs 

What? Time-of-use (ToU) tariffs and abolishing double charges, including network 
charges, for consumers with energy storage are part of the EU legislation (Article 1830 

29  COMMISSION  RECOMMENDATION  2023/C  103/01  of  14  March  2023  on  Energy  Storage  – 
-  https://eur-lex.europa.eu/legal-
Underpinning  a  decarbonised  and  secure  EU  energy  system 
content/EN/TXT/PDF/?uri=CELEX:32023H0320(01) 
30 1. Charges applied by network operators for access to networks, including charges for connection to 
the networks, charges for use of networks, and, where applicable, charges for related network reinforcements, 
shall  be  cost-reflective,  transparent,  take  into  account  the  need  for  network  security  and  flexibility  and 
reflect actual costs incurred insofar as they correspond to those of an efficient and structurally comparable 
network operator and are applied in a non-discriminatory manner. 

12 

 
 
 
 
 
of Electricity Regulation 2019/943, and Article 1531 of Electricity Directive 2019/944). 
The network tariff design can be improved: 

-  Option 1a: Via “Time of use” (ToU) and dynamic network charges that are cost 
reflective, possibly integrating a “negative” tariff for injecting energy into the 
grid in peak consumption hours, or for consuming power to alleviate local grid 
stress from usual RES-peaks and returning this power to the grid at a later time; 
close attention should be paid to reflect the actual added value of V2G for the 
grid.  

Example: the customer charges the EV at midday when there is 
excess solar generation and allows the EV to discharge power 
back to the grid in the evening peak. Thanks to the specific 
network charges proposed by the NRA, the customer benefits 
from close to zero or negative network charges for this charging 
behaviour. 

-  Option 1b: Via an hourly injection tariff that gives an implicit signal of grid 

congestion.  

Example: a dynamic injection price possibly indexed to hourly 
prices promotes injection and consumption at the most profitable 
and grid-friendly time. When the grid is congested and energy 
price is high, the injection tariff is high (the customer earns more 
by discharging the EV), and when the energy price is low 
reflecting a period of high renewables infeed, the injection tariff 
is close to zero or even negative (the customer is incentivised to 
charge the EV). 

-  Option 2: Via exemptions from network charges in order to take into account 
the  benefits  of  storage  for  the  grid  and  incentivise  grid-friendly  behaviour. 
Close  attention  should  be  paid  to  avoiding  that  undifferentiated  exemptions 
encourage V2G injections at moments that contribute to increasing the stress of 
the local grid, for example when it is already overburdened by excessive local 
renewables. 

31  Article  15:  Active  customers  “Member  States  shall  ensure  that  active  customers  that own  an  energy 
storage facility are not subject to any double charges, including network charges, for stored electricity 
remaining within their premises or when providing flexibility services to system operators;”  

13 

 
 
 
      
 
 
Example: when the local grid is congested (for instance due to 
high solar PV feed-in), the customer is not encouraged to inject 
electricity into the grid, but to charge at that point in order to 
absorb this excess renewable electricity, thanks to an exemption 
of network charge for this behaviour. On another day, when the 
grid needs more generation, V2G injections may be exempted 
from network charges for certain hours. 

-  Option 3: Via lump sums, or fixed amount of support for V2G use 

Example: the customer receives a monthly or annual payment to 
make the EV battery available for grid services under predefined 
contractual conditions: for instance, 9kW subscription without 
V2G activated: €15/month, and with V2G activated: €12/month, 
with the discount only applied if there has been actual injection 
within the month in times of peak consumption pre-defined by 
the DSO (e.g. evenings from 17.00-20.00). 

Methodologies should be consistent across all system operators in the same Member 
State, within the defined scope of the experimentation. 

Who? NRAs, TSO/DSOs 

Why? Network tariff design is a key tool to create incentives for V2G customers to 
adapt their behaviour to the situation in the grid.  

B-  Market aspects 

B1- Remunerate flexibility through dynamic electricity price contracts 

What? Under Article 1132 of Directive 2019/944, Member States must enable suppliers 
to offer dynamic electricity price contracts. A guidance on flexible retail contracts was 
adopted  on  30  April  202633.  It  provides  practical  guidance  on  promoting  the 

32 Article 11 – Right to a dynamic electricity price contract: “‘1. Member States shall ensure that the national 
regulatory  framework  enables  suppliers  to  offer  fixed-term,  fixed-price  electricity  supply  contracts  and 
dynamic electricity price  contracts. Member States shall ensure that final customers who have a smart 
meter installed can request to conclude a dynamic electricity price contract and that all final customers can 
request to conclude a fixed-term, fixed-price electricity supply contract with a duration of at least one year, 
with at least one supplier and with every supplier that has more than 200 000 final customers.” 
33 https://energy.ec.europa.eu/publications/report-market-based-electricity-supply-prices_en  

14 

 
 
 
 
 
 
 
 
remuneration  of  flexibility  in  retail  contracts,  including  dynamic  price  and  hybrid 
contracts.  

Who? Member States, energy suppliers 

Why? Amongst others, dynamic price contracts can facilitate the integration of EVs, 
by incentivising charging when RES electricity is abundant, providing cost savings for 
both the energy system and the consumers. 

B2 - Allow that flexibility service providers (including EMSP)  act as aggregators on 
behalf of the EV user  

What?  Directive  2019/944,  Art.  17  enables  flexibility  services,  for  instance 
through  aggregation  and  the  development  of  virtual  power  plants,  based  for 
example  on  recharging  points.  To  extend  the  service  to  charging  in  public 
recharging points, CPOs would have to take part to an agreement with aggregators, 
or act as such.  

Who? Member States 

Why?  In  private  (home,  workplace)  and  public  charging  (mostly  AC),  the 
aggregator  plays  a  key  role  in  bridging  the  gap  between  energy/network 
pricing/market mechanisms, user needs and preferences, and EV charging.  

B3 - Bid forward between local markets and national or EU-wide wholesale markets 

What? It refers to the ability of a market participant (e.g., an aggregator) to submit 
energy  or  flexibility  offers  from  local  systems  into  national  or  European  electricity 
markets, so that local  flexible resources  can compete in  and support the wider grid. 
Member States must assess local and system-wide flexibility needs, under Articles 31 
and 32 of ED, and Articles 6, 7 and 57 of Electricity Regulation.  

Who? Member States, NRAs, DSOs & TSOs 

Why?  Close  cooperation  between  DSOs  and  TSOs  is  needed  to  ensure  that  the 
available flexibility is absorbed by the market where it is most needed and to avoid 
conflicting activations, duplicate prequalification and further fragmentation. 

B4 - Reduce minimal requirement for qualifying and participating in ancillary service 
and congestion management markets  

What?  This  action  can  apply  for  instance  to  a  level  of  100kW/market  participant 
(equivalent to 10 cars or 3 trucks in the case of aggregators managing EV charging 
fleets)  instead  of  -  in  some  cases  -  a  magnitude  of  MWs.  The  EU  network  codes 
currently  define  the  highest  minimum  bid  size  but  allow  for  NRAs  and  system 
operators to opt for lower granularities.  

Who? NRAs, TSOs, DSOs and aggregators 

Why?  To  take  into  account  the  specificity  of  vehicles  in  ancillary  service  and 
congestion management markets. 

15 

 
 
B5 – Encourage consumers to self-consume electricity stored in their vehicle battery 
at peak times (V2H) 

What? Without the intervention of any aggregator, consumers can self-consume 
the electricity stored in their battery, possibly together with electricity production 
from PV panels.  

Who? MS, DSOs, energy suppliers and consumers 

Why? Allowing  consumers using  bi-directional  charging to  behave  as  self-
consumers and avoiding the intervention of any aggregator while developing their 
demand  response  capabilities  would enhance the  business  case  for  EV  owners 
and limit grid investment.  

B6  –  Allow consumers  to benefit from renewables self- consumption  regimes  for 
reinjecting electricity from their EVs into the grid 

What? This regime  would  be similar  to the existing framework for  renewables 
self-consumers, established in Article 21 of the Renewable Energy Directive and 
Article  15  of  the  Electricity  Market  Directive. Unlike  the  system  designed 
primarily to encourage the development of renewable energy sources, a potential 
framework for EV owners would focus on incentivising the injection of electricity 
at times that are advantageous to the grid. It would be made possible whenever EV 
owners have access to dynamic retail contracts, real-time prices or variable tariffs 
(notably thanks to dedicated reinjection tariffs – See option 1 of Action A2 above) 
to ensure that they can adequately react to price signals and reinject at the right 
time. In case of PV panels, it would require sub-metering to distinguish between 
energy flows. 

Who? MS, DSOs, energy suppliers and consumers 

Why? By  allowing  consumers using  bi-directional  charging to  behave  as  self-
consumers and avoiding the intervention of an aggregator while developing their 
demand  response  capabilities, this  would enhance the  business  case  for  EV 
owners, incentivise grid-friendly behaviour and  provide flexibility  to  the  energy 
system.  

16 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
C-  Complementary supporting measures 

C1 - Encourage implementation of demand response protocol  

What? In the context of EV charging, a demand response protocol34 allows the DSO 
to communicate grid-related signals, such as congestion alerts, load-reduction requests, 
flexibility events, time-dependent constraints, or dynamic price signals, and the CPO 
or the owner of a vehicle fleet who operates its private recharging points to respond 
with available flexibility, planned load, confirmation of actions taken, and site-level 
operational constraints.  

Who? DSO/CPO and aggregators 

Why?  To  support  smart  charging  and  discharging  based  on  grid  needs,  CPOs  and 
DSOs should synchronize their needs and capabilities in real time. A demand response 
protocol  enables  efficient,  standardized  and  interoperable  communication  between 
EVs, chargers, grid operators and aggregators.  

In California, the OpenADR 2.0b protocol is required for demand-responsive controls 
in non-residential settings, enabling automated load management and integration with 
utility  signals.  IEC  63584  and  ISO  15118-20  are  increasingly  used  for  charger-to-
network and vehicle-to-charger communications, supporting features such as Plug & 
Charge and DC bidirectional operation. 

C2 - Ensure V2G can provide power during emergency situations 

What? Exceptionally, in case of emergency situations such as black-outs, it should be 
possible for the EVSE and the EV to communicate in a minimal, safe-only mode to 
establish secure charging communication without the required charging certificates35. 

ISO 15118-20 allows for the disabling of charging certificates (See Annex H.3 of ISO 
15118-20:2022). This entails that the communication protocol falls back to only the 
safety related parts (e.g. voltage negotiation). 

Who? EVSE and vehicle manufacturers 

Why? To provide for emergency power during blackouts, such as recently seen on the 
Iberian Peninsula. 

34 Such as OpenADR (IEC 62746) that provides a common and interoperable communication protocol for 
Automated Demand Response (ADR) 
35 Both the EVSE and the EV should have a documented switch to a safe-only mode setting that can disable 
these certificates. For security reasons, the EVSEs should only allow the activation of this safe-only mode 
after physically opening the enclosure unit of the system by a trained technician, with simple configuration 
tools. 

17 

 
 
 
 
Japan’s experience highlights the integration of V2X into disaster resilience and 
public benefit, even as mass-market BEV adoption remains limited. The 
government’s guidelines, updated in 2023, explicitly promote V2X solutions and 
provide targeted support for the installation of V2H charging and discharging 
equipment in private homes, public facilities, and disaster centres. Subsidies are 
structured to incentivise installations that can provide backup power during 
outages, and public sector actors such as TEPCO, the largest electricity power 
company in the country, and other regional utilities are actively involved in V2G 
and microgrid pilots. 

C3 – Facilitate and streamline procedures for V2G grid connection  

What?  A  standardized  digital  procedure,  including  necessary  certifications  and 
documents for V2G permitting that DSOs will use and share, would help facilitate and 
streamline procedures for V2G grid connection. 

Who? DSOs, National authorities and aggregators 

Why? DSO input is essential in designing templates and digital platforms. 

4.  Additional experimentation tools for V2G pilots 

On top of the regulatory sandboxes described in section 2, market players may also create 
the conditions for innovative business models, such as living labs, that support V2G thanks 
to specific frameworks as described below: 

D1 –Provide pricing signals in public recharging points 

What?  For  public  AC  charging,  CPOs  can  offer  smart  charging  directly  or  through  an 
EMSP (see example in Amsterdam36). The CPO provides pricing signals to the end user 
directly or through the EMSP, which then results in an optimal charging plan based on the 
user's  departure  time  and  battery  percentage  retrieved  from  the  back-end  server  of  the 
vehicle manufacturer (allowed by RED Art. 20a).  

Who? CPOs, EMSP 

Why? To unlock greater EV flexibility in public charging, CPOs can pass on the price and 
time variations of a network tariff and dynamic electricity price. This would encourage 
off-peak charging, and limit grid reinforcements investments37. 

36  https://alternative-fuels-observatory.ec.europa.eu/general-information/news/amsterdam-launches-smart-
charging-pilot-reduce-grid-load-and-charging  
37  In Italy, the ’Tariffa BTVE’ which applies to public AC recharging points, shifts parts of the fixed costs 
to time-varying, volumetric costs. 

18 

 
 
 
 
 
D2 – Recommend vehicle manufacturers to implement communication standard 
ISO 15118-20 in the EV 

What? From 1 January 2027, publicly accessible recharging points and private recharging 
points are required to implement ISO 15118-20 (both AC and DC charging)38. EVs are 
encouraged to also implement this important standard. 

Who? Vehicle manufacturers 

Why? The implementation of ISO 15118-20 allows multiparty interoperability; it is crucial 
to  carry  out  testing  to  ensure  the  prompt  market  implement  of  this  standard  in  an 
interoperable manner, and thus, avoid the use of proprietary solutions. 

D3 – Enable disaggregation of demand resources through appropriate metering 
arrangements (MID certified submeters and separate accounting in case of PV). 

What?  Utility  meters,  including  MID  compatible  submeters,  and,  where  applicable, 
DMDs39,  can  be  used  as  official  meters,  in  addition  to  the  smart  meter  at  the  grid 
connection point, to distinguish between injected energy source40in line with Art 4 of the 
ED and Art 7b of the Electricity Regulation. Customers can opt for an additional supply 
contract under the same connection to the grid, facilitated by smart meters and submeters. 
Therefore,  the  framework  allows  for  different  ‘accounting  points’  within  consumer’s 
premises, e.g. EV, HP, or other house load. Other provisions, such as Art. 15 of the ED on 
active customers, or the smart metering provisions, also facilitate such services. 

Who? Vehicles manufacturers, suppliers, DSOs and aggregators 

Why?  This  specific  metering  arrangements  would  enable  a  dedicated  V2G  energy 
contract, by facilitating separate metering of charging/discharging flows from other flows 
(i.e. electricity generated by solar panels). 

38 Under AFIR Delegated Act on Standards (OJ L, 2025/656, 18.6.2025) 
39 Dedicated measurement devices, e.g. in the recharging point 
40  ie V2G or PV, as each source can have a different buyer 

19 

 
 
 
 
Annex: Examples outside the European Union 

Across  the  world,  pilot  projects  and  regulations  for  V2G  are  also  flourishing.  These 
initiatives started to provide the basis to understand how V2G can operate in real-world 
regulatory  and  market  environments.  International  studies  reveal  that  successful 
deployment  of bidirectional  charging hinges on strong policy direction  and harmonised 
technical  standards.  Best  practices  emphasise  interoperability,  consumer  value,  and 
integration with broader energy and transport strategies41. 

The United Kingdom’s centralised regulatory approach has mainstreamed smart charging 
and  enabled  high  reliability  and  consumer  protection,  while  bidirectional  charging  is 
advancing through targeted trials. Notable projects include Project Sciurus, which trialled 
over 300 domestic V2G chargers, and recent partnerships between energy suppliers (e.g., 
EDF, Octopus) and automakers (notably Nissan and BYD) to launch V2G-ready vehicles 
and bundled charging solutions. 

California is widely recognised as a global frontrunner in the deployment of smart and 
bidirectional charging. The state’s approach is shaped by a suite of supporting policies that 
include the Vehicle-Grid Integration (VGI) policy track, and the National Electric Vehicle 
Infrastructure (NEVI) standards. California’s regulatory environment also supports open 
access, transparent pricing, and interoperability. The State enforces essential standards42 
for BDC and V2G applications.  

China stands out as the world’s largest and most rapidly evolving market for EVs. China’s 
approach to V2G is particularly ambitious: in 2025, the government launched 30 large-
scale  V2G  pilot  projects  across  nine  major  cities,  requiring  grid  companies  to  provide 
metering  and  dispatch  support  for  EVs  acting  as  distributed  energy  resources.  The 
regulatory framework is highly centralised, with the National Development and Reform 
Commission  (NDRC)  and  the  National  Energy  Administration  setting  clear  targets  and 
technical standards. These standards ensure interoperability, with compulsory certification 
for all new charging equipment. The grid planning explicitly incorporates EV flexibility, 
with virtual power plant targets of 20 GW by 2027 and 50 GW by 2030. All new charging 
infrastructure  must  support  smart  charging,  with  support  for  dynamic  pricing,  demand 
response,  and  aggregator  participation,  and  direct  integration  into  utility  platforms. 
Provinces  such  as  Jiangsu  have  introduced  discharge  tariffs  for  V2G,  with  household 
earnings of up to ¥3,000 per year (around 360€). 

South Korea is also actively piloting bi-directional charging, particularly V2G and V2H 
applications.  South  Korea  runs  a  broad  regulatory  sandbox  system.  Notable  projects 
include the Jeju Island V2G pilot (Hyundai and KEPCO), where EVs are used to stabilise 
the grid during peak demand. South Korea has corporate fleet and public bus initiatives 
exploring virtual power plant (VPP) aggregation. 

Australia has an energy regulatory sandbox toolkit. It is leveraging its high rooftop solar 
penetration  and  national  standards  to  build  a  foundation  for  managed  and  bidirectional 
charging.  The  Australian  Renewable  Energy  Agency  (ARENA)  published  the  National 

41  Analysis  based  on  a  study  made  by  Ramboll  for  the  European  Commission  in  2025-2026: 
https://op.europa.eu/en/publication-detail/-/publication/170d3b45-7753-11f1-bf5e-
01aa75ed71a1/language-en . 
42 IEEE 1547/UL 1741 SB for smart inverters and export-capable EVSE 

20 

 
 
 
Roadmap for Bidirectional EV Charging in February 2025. Major energy retailers such as 
Origin Energy and AGL are actively involved in trials: Origin, in partnership with BYD 
and StarCharge, is running a 12-month pilot with 50 households to test managed charging 
and V2G, while AGL and ARENA are conducting a national trial with 100 EV owners 
from multiple automakers to explore peak shaving and frequency control.  

Figure 1 - Overview of key points in different countries (source: Ramboll study43) 

43https://op.europa.eu/en/publication-detail/-/publication/170d3b45-7753-11f1-bf5e-
01aa75ed71a1/language-en 

21