MID-Meter Compliance for UK Holiday Let EV Chargers: What You Legally Need

TL;DR

If you bill guests for EV charging, the meter you use is governed by UK law - and most holiday let owners don't know this until it's too late. Here's what you need to know:

• Your meter must comply with the Measuring Instruments Regulations 2016 (MIR) - the UK implementation of the EU MID 2014/32/EU. No compliance, no enforceable bill.
• Look for Class B or Class C accuracy under EN 50470 - and confirm your meter carries a CE mark, an "M" + year (e.g. M24), and a 4-digit notified-body number.
• A guest can legally refuse to pay any bill based on a non-compliant meter. Trading Standards and OPSS can also take enforcement action against you.
• Most consumer-grade chargers don't meet the standard - MID compliance is a specific certification, not a feature every smart charger includes by default.
• The rules tighten from late 2027 - the SSES Programme is targeting end-2027 enforcement for all new EV smart charge points to include an MIR Class B compliant device meter.

Read on for the full legal framework, how to verify your charger, and what the SSES changes mean for existing installations.

Why this matters for holiday let owners

If you charge a guest for EV charging at your property and the bill is based on a meter reading, that meter must legally be approved for billing under UK law. Most UK holiday let owners don't realise this - and the chargers they have installed often don't meet the standard.

The consequences of getting this wrong are not theoretical:

• A guest can legally refuse to pay any meter-based bill where the meter isn't approved.
• You have no legal evidence to defend the bill in a Trading Standards complaint or small claims dispute.
• OPSS can take enforcement action against businesses placing or using non-compliant meters for trade, including civil penalties.
• From late 2027, the rules tighten further - the new SSES regulations are targeting full enforcement at the end of 2027 for all new EV smart charge points to include MIR-compliant Class B device meters.

This is the article that explains, in plain English, what you need to know.

The UK regulatory framework - what the law actually says

The UK has three overlapping pieces of legislation that govern billing meters at holiday lets. Knowing which one applies to you matters.

1. The Measuring Instruments Regulations 2016 (MIR)

The MIR (SI 2016/1153) is the UK domestic implementation of the EU Measuring Instruments Directive 2014/32/EU. It came into force on 30 October 2016, replacing fifteen separate measurement regulations with a single harmonised regime.

What it covers: Active electrical energy meters used "for trade" - which OPSS defines as use "in connection with a transaction where the meter's measurement determines how much money is charged or rewarded to the customer."

This explicitly includes EV smart charge points (EVSCPs) that are signed up to flexibility services or used to bill end users for charging.

Scope rule for electricity meters: The MIR applies where:

• Maximum quantity of electricity supplied is less than 100 kW, AND
• The meter does not provide measurement on a half-hourly basis

For UK holiday lets, this is exactly the relevant range. A typical home/commercial AC charge point is 7 kW (single phase) or 22 kW (three phase) - both well under the 100 kW threshold and not half-hourly. All UK holiday let chargers fall squarely within MIR scope.

2. The Electricity Act 1989, Schedule 7

Schedule 7 of the Electricity Act 1989 requires that all meters used for billing purposes - primary (supplier-to-customer) and secondary (landlord-to-tenant or owner-to-guest) - must be of an approved pattern or construction and installed in an approved manner.

In effect, this is the older legal framework that MIR has now largely superseded for new meters, though pre-2016 approved meters can remain in service until end-of-life.

3. The Electric Vehicles (Smart Charge Points) Regulations 2021 (EVSCP Regs)

The Electric Vehicles (Smart Charge Points) Regulations 2021 came into force on 30 June 2022 and primarily govern the smart functionality, cyber security, and demand-side response capability of UK domestic charge points. They apply to private (non-public) charge points marketed for use by occupiers of domestic premises and their visitors - which includes holiday lets.

These regulations don't directly mandate MIR-grade billing metering yet, but they're being amended in 2026/27 to do exactly that under the SSES Programme (see below).

What "MID-approved" actually looks like

When people say "MID-approved" or "MID-compliant" in the UK in 2026, they mean the meter complies with the Measuring Instruments Regulations 2016 (which implemented MID 2014/32/EU). The terminology overlaps because the underlying technical standards are the same.

A compliant meter must have all three of these markings:

1. CE marking - denotes general conformity with EU/UK product law
2. MID marking - the letter "M" followed by the two-digit year of manufacture (e.g. M24 for a meter manufactured in 2024)
3. Notified body identification number - a 4-digit code that identifies the body that approved the meter (e.g. NMI-NL 0122)

For a practical reference on the markings, MID compliance guidance is a useful checklist.

You should also see one of these accuracy class designations:

For an AC holiday let charger (7-22 kW), Class B is the standard you need. If you see a meter rated only Class A, it cannot lawfully be used for billing. If you see Class B or Class C - and the M-mark and 4-digit notified-body code are present - you're compliant.

What chargers UK holiday let owners typically use - and where they stand on MIR compliance

Here's a clear, honest assessment of how the most common UK holiday let chargers compare on billing-meter compliance as of May 2026.

⚠️ Important - read before relying on this table. The information below reflects publicly available specifications and manufacturer guidance as of May 2026. Product variants, firmware versions, and accessory configurations change frequently. The same product name may be sold in different specifications across markets and time periods. Before installing or relying on any specific charger for billing your guests:

1. Request written confirmation from the manufacturer (not the installer) that the meter installed with your specific charger model and serial number is MID Class B (or higher) compliant under the Measuring Instruments Regulations 2016 for billing applications.
2. Keep that confirmation on file as your evidence in any future dispute.
3. If in doubt, add an external MID Class B sub-meter on the supply circuit to the charger - this is the most reliable way to be billing-compliant regardless of what the charger itself contains.

This article is not legal or technical advice. The authors are not affiliated with any of the named charger manufacturers and have no commercial relationship with them.

The single most important question to ask any installer or vendor:

"Does this charger include an MIR-compliant Class B active electrical energy meter, or do I need to add an external sub-meter for billing?"

If the answer isn't a clear yes - or doesn't include a clear path to compliance via an add-on - choose a different charger or a different installer.

Who enforces this - and what happens if you don't comply

This is where there's widespread confusion. Different bodies handle different aspects.

OPSS (Office for Product Safety and Standards)

OPSS, part of the Department for Business and Trade, is the UK national regulator for legal metrology. It enforces the Measuring Instruments Regulations 2016 in relation to:

• Active electrical energy meters
• Gas meters
• Electric Vehicle Smart Charge Points (under the EVSCP Regulations 2021 and the upcoming SSES regulations)

OPSS has powers to:

• Serve Compliance Notices requiring a business to address non-compliance
• Serve Enforcement Notices where compliance has not been delivered
• Impose Civil Penalties (financial penalties without going to criminal court)
• Refer matters for criminal prosecution where appropriate

In 2025/26, OPSS specifically commissioned testing of up to 15 UK EV charge points against the EVSCP Regulations, with an annual budget of £80,000. This signals active, not passive, market surveillance.

Local Trading Standards

Trading Standards officers handle MIR enforcement for most other measuring instruments (weighbridges, fuel dispensers, scales) but not for electricity meters - those sit with OPSS. However, Trading Standards remain the practical first port of call for a guest who believes they've been overcharged on a non-compliant meter, and they will escalate to OPSS where appropriate.

What enforcement looks like in practice

In our experience and based on public OPSS guidance, the enforcement ladder for a non-compliant holiday let billing meter typically looks like:

1. Guest disputes a bill with the owner (most cases stop here - owner refunds and replaces the meter)
2. Guest contacts Trading Standards with the unpaid bill and a photograph showing a non-compliant or damaged meter
3. Trading Standards investigates and either resolves locally or refers to OPSS
4. OPSS may serve a Compliance Notice requiring the owner to remove or replace the meter and stop billing on that basis
5. Failure to comply can lead to Civil Penalties or criminal prosecution

The realistic risk for a small holiday let owner with one non-compliant meter is low to moderate - OPSS prioritises higher-impact non-compliance - but the reputational risk from a single TripAdvisor or Airbnb review citing "they overcharged me using an illegal meter" is significant. Add to this the simple fact that the guest has a clear legal right to refuse to pay.

The big change coming in 2027: SSES regulations

If you're installing a charger in 2026, you should know what's coming.

In December 2025, the Department for Energy Security and Net Zero (DESNZ) opened a consultation on the Smart Secure Electricity Systems (SSES) Programme Phase 1 regulations. The key provision relevant to holiday let owners:

All Energy Smart Appliances in scope - including Electric Vehicle Smart Charge Points (EVSCPs), smart heating appliances, and battery energy storage systems with smart capability - must include a device meter, and that device meter must comply with MIR Class B requirements for active electrical energy meters.

Timeline:

• Q1/Q2 2026: Government plans to lay the first-phase regulations before Parliament
• 6 months after regulations made (likely Q4 2026): Minor and incremental changes to EVSCP regime come into force
• End of 2027 (target): Full enforcement targeted for end of 2027, subject to the consultation outcome and the regulations being laid before Parliament in 2026.

What this means for holiday let owners:

• Any charger you install in 2026 should already include a Class B MID/MIR-compliant meter, or be straightforwardly upgradeable to one. Otherwise you'll be replacing it within 18-24 months.
• Buying the cheapest available charger in 2026 to "save money" is increasingly likely to be a false economy.
• The regulatory direction is clear: tighter, not looser.

One related consultation worth knowing about: OPSS consulted on whether to permit remote-only displays (i.e. via smartphone app) as an alternative to built-in physical displays on EVSCPs. In its February 2026 response, the Government confirmed it will amend MIR to allow remote-only displays for Energy Smart Appliances, with changes coming into force at the end of 2027. This lowers compliance costs but does not weaken the underlying meter accuracy requirements.

How to verify your charger is compliant - a practical checklist

If you already have a charger installed and want to know whether it's MIR-compliant for billing purposes, here's what to do:

Step 1: Locate the meter

Find the kWh meter - it may be inside the charger housing itself, in a separate enclosure nearby, or in your consumer unit. If you cannot identify a dedicated kWh meter, you almost certainly do not have a billing-compliant setup.

Step 2: Check for the three required markings

• ✅ CE mark
• ✅ "M" followed by year (e.g. M22, M23, M24)
• ✅ 4-digit notified-body number

If any of these are missing, the meter is not approved for billing.

Step 3: Check the accuracy class

Look for "Class A", "Class B", or "Class C". You need Class B as a minimum for billing residential or light commercial use. Class A is not sufficient.

Step 4: Confirm with the manufacturer

If the markings are unclear or you cannot find them, contact the charger manufacturer (or the original installer) and ask in writing:

"Does the meter installed with [charger model + serial number] comply with the Measuring Instruments Regulations 2016 (Class B or higher) for billing purposes?"

Keep the response on file. If you ever need to defend a billing dispute, this is your evidence.

Step 5: If it's not compliant, your options are:

1. Add an external MID Class B sub-meter (typically £80–£200 plus installation by a qualified electrician). This is often the cheapest fix.
2. Upgrade the charger to one with a built-in MIR-compliant meter (Easee Charge Max for single-property installs, or Easee Charge Pro for multi-unit sites, are common choices).
3. Stop billing per-kWh and use a different model (such as flat-fee or included-in-rate). Note: flat-fee billing carries its own Ofgem Maximum Resale Price compliance risks - see our guide to billing holiday let guests for EV charging.

What about software billing platforms - does GuestCharge cover this?

A reasonable question, and one we get often.

Billing platforms (including GuestCharge, OK2Charge, Voltshare and Monta) do not change whether your physical meter is MIR-compliant. Compliance lives with the hardware. A platform reads from the meter; it cannot upgrade the meter itself.

What a good billing platform does provide:

• An audit log of every kWh value reported by the charger, with timestamp and session ID - useful evidence if a guest disputes a bill
• Tariff transparency to the guest at the point of payment (showing rate, kWh used, total charge)
• Owner-stay exclusion (separating non-billable owner sessions from billable guest sessions)
• Guidance and warnings when the host is configuring rates that may breach Ofgem Maximum Resale Price rules

The platform's role is to make compliance easy where the underlying hardware allows it. You - the owner - remain responsible for ensuring your charger meets MIR standards before connecting it to any billing system.

This is why it's worth getting the hardware right at the point of installation. Replacing a non-compliant meter post-install is an avoidable expense.

The forgotten complication: Northern Ireland

Northern Ireland sits outside the Ofgem-regulated GB energy market - energy regulation there falls under the Utility Regulator (UREGNI). For metering specifically, the regulatory framework is closely aligned with GB but enforcement and reporting routes differ.

If you operate a holiday let in Northern Ireland:

• The MIR still applies (it covers the whole UK, including NI)
• OPSS has enforcement powers under the regulations
• Ofgem Maximum Resale Price rules do not apply in the same form - the equivalent rules sit with the Utility Regulator
• The Department for the Economy holds general weights and measures jurisdiction

For most holiday lets in NI, the practical effect is minor - install an MIR-compliant meter, charge your guest at or below your supplier rate, document everything. But if you're unsure, contact the Utility Regulator or a qualified Northern Ireland solicitor.

Frequently asked questions

Is "MID-approved" the same as "MIR-compliant"?

For practical purposes, yes. MID is the EU directive (2014/32/EU); MIR is the UK domestic implementation (SI 2016/1153). The technical standards are aligned. UK suppliers and installers commonly use both terms interchangeably.

My charger has an in-built kWh display. Is that enough?

Not necessarily. A kWh display is a useful operational feature, but it doesn't automatically mean the meter behind it is MIR-compliant. Look for the M-mark, year, 4-digit code and Class B (or higher) accuracy rating. If those aren't present, the display is for monitoring, not legal billing.

My charger was installed before October 2016 - am I OK?

Pre-2016 meters approved under the Electricity Act 1989 may remain in service until end-of-life. However, any replacement meter installed after 30 October 2016 must be MIR-compliant. If you upgrade or replace the existing meter, the new one must meet the current standard.

What's the penalty for using a non-compliant meter?

OPSS enforcement is graduated. A single low-impact case typically results in a Compliance Notice requiring you to fix the issue. Persistent or large-scale non-compliance can lead to Civil Penalties and, in severe cases, criminal prosecution. Practically, the bigger immediate risk for most owners is reputational (a guest dispute) rather than direct enforcement.

My charger is OCPP-compatible - does that mean it's MID-compliant?

No. OCPP (Open Charge Point Protocol) is a communication standard for talking to charging infrastructure - it has nothing to do with metering accuracy or legal billing approval. A charger can be OCPP-compatible and not MIR-compliant for billing, or vice versa. Check both separately.

Can I just add an external MID kWh sub-meter alongside my existing charger?

Yes - and for most non-Easee-Charge-Max / non-Easee-Charge-Pro chargers in the UK consumer market, this is the most reliable route to compliance. Expect £80–200 for the meter itself, plus installation by a qualified electrician. The sub-meter is wired to the charger's supply circuit and provides the legal record of energy used. Your billing platform reads from the sub-meter, not the charger's internal display. This approach is hardware-agnostic and works with effectively any OCPP-compatible charger.

Which UK chargers come with built-in MID-certified billing meters out of the box?

Based on manufacturer specifications as of May 2026, the most clearly MID-certified options in the UK market are Easee Charge Max (residential, built-in MID Class B, ±1% accuracy per EN 50470-3) and Easee Charge Pro (multi-unit). Other popular UK chargers - including MyEnergi Zappi, Easee One, Wallbox Pulsar Plus, and Pod Point Solo 3 in their standard variants - generally require an external MID-certified sub-meter for billing-compliant installations. Product specifications change frequently; always verify directly with the manufacturer before assuming compliance for billing.

Does the guest need any documentation from me about the meter?

No specific document is required by law, but providing transparent billing - clearly showing the kWh used, the rate per kWh, and the total - is best practice and helps avoid disputes. Most billing platforms produce this automatically.

Will my insurance cover me if I have a billing dispute?

Most standard holiday let insurance policies cover legal expenses for tenant or guest disputes up to a defined limit. Check your policy. Some specialist policies (Schofields, Boshers, Towergate) include specific provisions for short-term rental disputes including billing.

What about VAT?

For a holiday let owner not VAT-registered, charging guests for electricity at cost is not a taxable supply requiring VAT. If you are VAT-registered, electricity for domestic use generally falls within the reduced 5% rate - speak to your accountant.

Are there any grants for installing a compliant charger?

Unfortunately, most UK holiday lets do not qualify for the OZEV chargepoint grant. The OZEV residential landlord grant (up to £500 per socket, 75% of cost) explicitly excludes properties "only used for holiday accommodation" - see the eligibility criteria on the OZEV landlord grant page. The grant closes on 31 March 2027. Mixed-use properties (e.g. a property primarily let on a residential tenancy that is occasionally let short-term) may qualify, but the rules are strict - always check directly with OZEV before assuming eligibility. For pure holiday lets, plan your hardware budget on the basis that no OZEV grant will be available. For background on this exclusion: the trade bodies for the UK short-term let sector (PASC UK and the Association of Scotland's Self-Caterers) have argued that the holiday let exclusion is inconsistent with wider government policy on EV adoption. This may change in future schemes, but it applies as of May 2026.

A summary for owners who don't want to read the whole thing

If you take only one thing from this article, it's this:

Before you install or upgrade an EV charger at your holiday let, ask the installer in writing: "Does this charger include an MIR-compliant Class B (or higher) active electrical energy meter for billing purposes?"

If the answer is yes, with the markings to back it up, you're compliant. If the answer is no, either choose a different charger or add an external MID sub-meter at the time of installation. The cost difference is small. The cost of getting it wrong - replacing the meter later, refunding disputed bills, or carrying reputational damage from a guest complaint - is much larger.

Where to go next

• EV Charging for UK Holiday Lets: The Complete 2026 Guide
• How to Bill Holiday Let Guests for EV Charging Without Estimating

Coming soon:

• Best EV Chargers for UK Holiday Lets: Zappi vs Easee vs Wallbox vs Pod Point
• How Much Does It Cost to Install an EV Charger at a UK Holiday Let?
• Ofgem Rules on Reselling Electricity to Guests