Securing Approval to Bill by Kilowatt-Hour for EV-Charging in Canada

Canada's federal measurement rules now allow EV charger owners to apply for approval to bill drivers by the kilowatt-hour.

Key Dates at a Glance

	AC (L1/L2)	DC (L3+)
Application deadline	December 31, 2027	December 31, 2029
Program end date	January 1, 2030	January 1, 2030

Time-based and flat-rate billing remain available without dispensation until December 31, 2029.

Understanding the Regulation

In Canada, commercial electricity measurement — including kWh-billed EV charging — must meet federal accuracy standards under the Electricity and Gas Inspection Act (EGIA). Devices used for this purpose require formal approval through a process called type approval, administered by Measurement Canada (MC), the federal agency responsible for measurement accuracy in trade.

Because the type approval process for EVSE was still being developed, MC introduced the Temporary Dispensation Program in 2022. This gives EV charger owners a time-limited, opt-in permission to bill by kWh today under specific conditions, while manufacturers work through the type approval process for their individual devices. Dispensation is not an exemption — it is a structured compliance pathway with real obligations.

The program covers Level 1, Level 2 (AC), and Level 3+ (DC) chargers in both commercial and non-commercial (multi-family residential, workplace, and fleet) settings. Each charger type and setting has a separate terms and conditions document on MC's website — make sure you review the right one. Billing by kWh is entirely opt-in: EV charger owners who prefer time-based billing or flat session fees have no action required.

Key points to understand:

• Dispensation is granted per device and per location, not by manufacturer or model — each EV chargerowner must apply for their own devices
• Dispensation expires January 1, 2030, after which devices must have formal MC type approval or cease kWh billing

ChargePoint Products Listed in Appendix C

Before you can apply for dispensation, your charger must appear in Appendix C of MC's official guidance — this is MC's list of devices that have been evaluated and are eligible for the program. If your device isn't listed, you cannot enroll it.

ChargePoint has submitted attestations of accuracy to MC for all products, listed in Appendix C of MC's official guidance. You do not need to independently test your equipment.

Product	Charging Level
CT4000	Level 2 AC
CP6000	Level 2 AC
CPX 25-50	Level 2 AC
CPE250	Level 3+ DC Fast
CPE280	Level 3+ DC Fast
CPPL0002	Level 3+ DC Fast

When submitting your dispensation application, MC may ask you to provide documentation confirming your charger is listed in Appendix C. ChargePoint can supply this - for official approval letters, contact Suzanne.goldberg@chargepoint.com

Responsibilities: ChargePoint vs. EV charger Owner

What ChargePoint is Responsible For

• Submitting attestations of accuracy to MC for all ChargePoint hardware so you don't need to test or attest equipment individually
• Maintaining our hardware listing in Appendix C of MC's official guidance
• Providing network software features compliant with MC's requirements for fee display, receipting, station messaging for the required dispensation disclaimer, and transaction traceability (Sections 2, 3, 5, and 6 of the dispensation terms)
• network softwarePursuing MC type approval for current and future product lines ahead of the 2030 deadline
• 24/7 driver support to address billing questions and notify hosts of driver identified station issues

What the EV charger Owner is Responsible For

• If you wish to bill by kWh, submit your Application for Temporary Dispensation to Measurement Canada by the deadline: December 31, 2027 for AC; December 31, 2029 for DC
• Reviewing and accepting Measurement Canada's terms and conditions for your station type (AC, non-commercial AC, and DC each have a separate terms and conditions)
• Posting the required dispensation disclaimer on each enrolled station within 30 days of receiving Measurement Canada approval, using the network software Station Messages feature (see FAQ for exact language)
• Setting up kWh pricing rules in the ChargePoint network software once your approval letter is received
• Establishing a simple, clear, documented complaint resolution process for driver accuracy concerns, as required by Measurement Canada. ChargePoint's existing driver support channels may form part of this process, but the EV chargerowner remains responsible for ensuring complaints are appropriately addressed and documented.
• Providing Measurement Canada with site access for random validation testing and resolving any compliance issues within 60 days
• Notifying Measurement Canada in writing within 30 business days if any enrolled device is replaced, relocated, or removed from service, or if ownership changes. Dispensation does not transfer to new owners, who must submit their own application.

How to Enable kWh Billing: Step-by-Step

Step 1 — Review MC's requirements for your station type

Three separate T&C documents apply depending on your use case: public/commercial AC, private/non-commercial AC, or DC fast charging. All are available at ised-isde.canada.ca.

Step 2 — Submit your application

Download and complete the Application for Temporary Dispensation from MC's website, then email it to mcdispensation-dispensemc@ised-isde.gc.ca. Because ChargePoint hardware is in Appendix C, you do not need to include a manufacturer attestation — reference the Appendix C listing instead.For full submission instructions, visit MC's program page here — we recommend checking there for the most current guidance, as submission requirements may be updated over time.

Step 3 — Receive your approval letter

MC processes applications within 30 business days (up to 50 devices) or 60 business days (more than 50). You will receive an approval letter from the Office of the President of MC. A contractor registration number under the EGIA is issued automatically — no separate action needed (“contractor” is MC's term for any entity authorized to sell electricity by measurement).

Step 4 — Post the dispensation disclaimer

Within 30 days of approval, add the required notice to each enrolled station via network software Station Messages:

• English: "This device has been granted temporary dispensation from the requirements of Electricity and Gas Inspection Act 9(1)."
• French (required for Quebec): "Cet appareil est temporairement autorisé à être utilisé dans le but d'obtenir la base d'une charge d'électricité, sous conditions établies par Mesures Canada."

Always verify exact wording against the current MC guidance document before posting. The notice must remain in place for the full duration of the dispensation.

Step 5 — Set up kWh pricing in the network software

Create kWh pricing rules in the ChargePoint network software. Our platform supports energy-based, time-based, and hybrid structures — all meeting MC's display requirements. Contact ChargePoint Customer Support, visit our station owner support FAQ for assistance.

Driver Support and Complaint Handling

Measurement Canada requires EV chargerowners participating in the temporary dispensation program to maintain a complaint investigation process that is simple, clear, documented, and capable of supporting inquiries related to measurement accuracy. Owners may administer the process directly or work with their network operator, provided records are available when requested by Measurement Canada.

ChargePoint has several tools that can support this requirement:

• 24/7 Driver Support: Drivers can contact ChargePoint support using the phone number displayed in the ChargePoint app and on supported charging stations.
• In-App Issue Reporting: Drivers can use the Report a Problem feature in the ChargePoint app to create a support ticket and track its status.
• Billing Assistance: ChargePoint support can assist with billing-related inquiries and transaction reviews.
• Station Notifications: When an issue appears related to station hardware or meter functionality, ChargePoint notifies the station owner.
• Assure Customers: Where applicable, issues may be handled through ChargePoint Assure service procedures.
• Non-Assure Customers: The station owner remains responsible for arranging any required repairs or corrective actions.

Important: Participation in ChargePoint support programs does not replace the EV chargerowner's obligations under Measurement Canada's temporary dispensation program. The owner remains ultimately responsible for maintaining a documented complaint process and responding to Measurement Canada requests.

Frequently Asked Questions

Do I have to bill by kWh?

No. It is entirely opt-in. EV chargerowners billing by time or flat rate have no action required. Only those who want to offer kWh billing need to apply.

Can ChargePoint submit the application for me?

No. MC requires the EV chargerowner to apply. ChargePoint cannot submit on your behalf. However, because our hardware is listed in Appendix C, you don't need to provide any manufacturer attestations.

Does ChargePoint's hardware and software meet MC's requirements?

Yes on both counts. All eligible ChargePoint products meet MC's ±3% accuracy requirement and are listed in Appendix C — no independent testing required. Our network software meets MC's requirements for fee display, receipting, and transaction traceability, and the station messaging feature supports the required user-defined dispensation disclaimer.

What if I add new chargers after my application is approved?

You must submit a separate new application for newly installed devices, still within the applicable deadline. Amendments to an existing application must be received by MC within the standard processing window (30 or 60 business days) — do not leave additions to the last minute.

What happens if my property or equipment changes hands?

Dispensation does not transfer. The new owner must submit their own application. You must notify MC in writing within 30 business days of any ownership change and return any certificate of registration to a local MC office.

What does "conditionally type approved" mean for CP6000?

It means CP6000 has passed MC's formal evaluation process and complies with all applicable legal requirements — a stronger status than dispensation. For your dispensation application, CP6000 is listed in Appendix C and the process is the same as other products. For questions about how this affects your specific obligations, contact MC directly.

Will MC test my stations?

Yes. MC conducts random on-site validation testing. If a station is found outside the ±3% accuracy limit, you have 60 days to resolve it. Continued non-compliance can result in removal from the dispensation program. ChargePoint hardware is designed to operate well within this limit.

What if a driver complains about an inaccurate bill?

Please reference the “Driver Support and Complaint Handling” section above.

What complaint process do I need for Measurement Canada compliance?

Measurement Canada requires EV chargerowners participating in the temporary dispensation program to maintain a complaint investigation process that is simple, clear, and documented. The process may be administered either by the EV chargerowner or by the network operator. Records must be available to Measurement Canada upon request.

ChargePoint's 24/7 driver support line and in-app reporting tools can help support this requirement by documenting customer concerns and providing issue tracking. However, the EV chargerowner remains responsible for compliance with all Measurement Canada requirements.

My vehicle display shows fewer kWh than I was billed. Why?

This is normal. Energy is lost to heat and conversion between the charger and the battery — the charger measures what it delivers, the vehicle measures what reaches the battery. MC has confirmed vehicle displays are not approved measurement devices. The charger's reading, within ±3%, is the legally recognized figure.

What happens after January 1, 2030?

All dispensations expire. Devices used for kWh billing must hold MC type approval or be removed from service. MC has confirmed no plans to extend the program. ChargePoint is actively working toward type approval and will keep customers informed well ahead of the deadline.

Disclaimer: This document is for informational purposes only and does not constitute legal advice. ChargePoint has the right to make changes to the information on this page at any time. EV chargerowners are responsible for complying with all applicable MC requirements. For official guidance visit ised-isde.canada.ca or contact MC directly at mcdispensation-dispensemc@ised-isde.gc.ca.