Transparency by Design: Three Practical Steps to Strengthen EV Charging Credits Under the Canadian Clean Fuel Regulations

Electric vehicle charging is one of the most dynamic and fastest-growing sources of compliance credits under the Clean Fuel Regulations (CFR), and residential charging in particular now represents a substantial share of electricity credit generation. That growth shows the program is working as intended. But the EV charging landscape is also uniquely complex — spanning hardware OEMs, software and network operators, site hosts, installers, utilities, and real-estate owners — and the value of CFR credits has drawn a wide field of participants eager to take part. The combination of complexity plus high stakes is what makes clear rules, good data, and proactive coordination worth prioritizing today.

At FuSE, we work across every clean fuel program in North America, and we’ve seen how a few structural choices separate programs that head off problems from those that adjudicate them after the fact. In that spirit, we want to offer three constructive suggestions for how ECCC could make the CFR’s electricity provision more transparent, more predictable, and easier to administer — for the benefit of registered creators, verification bodies, and ECCC’s own team alike.

1. Publish a non-residential EV charger registry — publicly if possible, and to verifiers at minimum

Here is the encouraging part: ECCC already collects the information needed to do this. Under the CFR’s annual reporting requirements, charging-network operators must report, for each non-residential charging station, the province, GPS coordinates to the fifth decimal place, any name or identifier, the civic address, and the OEM-issued serial number. In other words, the identifying backbone of a national charger registry is already flowing into ECCC through annual reports.

What’s missing is the ability for anyone to cross-reference it. Today, each verification body sees only its own clients’ assets, and each registered creator sees only its own portfolio. No participant can tell whether a charger in their report also appears in someone else’s. That siloing is precisely the condition under which duplicate and overlapping claims go undetected until it’s too late to fix them cleanly.

Other North American clean fuel programs are built the other way around. Across the U.S. West Coast programs, non-residential charging equipment is registered by OEM-issued serial number and manufacturer name, with latitude and longitude, and each unique unit registered separately — and that charger-level information is far more accessible to participants and verifiers than anything currently available under the CFR. The transparency isn’t an administrative afterthought; it’s a load-bearing feature that lets the market police itself.

Our proposal is straightforward. ECCC could publish a registry of reported chargers with their identifying information — serial number, location, and province — and, critically, an indication of which registered creator reported each one. A fully public list (excluding, appropriately, single-family residential addresses for privacy) would match the norm in peer programs. At an absolute minimum, this information should be made available to accredited verification bodies, so they can check chargers and creators in their own portfolios against other verifiers’ clients.

The benefit runs in every direction. Registered creators could identify overlaps and work them out among themselves ahead of annual reporting, rather than discovering months later that two reports collide. Verifiers gain a proactive cross-check that today they have no way to perform. Transparency here is not a burden on ECCC; it’s a way to distribute the integrity work across the people best positioned to do it.

2. Clarify the network-operator role — and give the compliant creator a way to protect their claim

The CFR defines a charging-network operator as a person who operates a communication platform that collects a charging station’s electricity data and who owns that data. Notably, the definition does not require owning, installing, or manufacturing the charger. It is a deliberately broad, low-threshold definition — and in a world of widely accessible telematics and charging-data APIs, that breadth creates a potential problem: more than one party can connect to the same stream of charging data at the same time, and each may, in good faith, believe it qualifies as the network operator for the same stations.

Under the current structure, there is no registration step and no first-in-time process for chargers — the annual report is a retroactive snapshot. That means an entity with the strongest, most legitimate claim, which has reported accurately and paid for third-party verification, can find months later that an overlapping claim has surfaced against the same chargers. And because the Regulations allow the Minister to suspend and ultimately cancel credits where excess credits appear to have been created, the honest, compliant creator can be the one whose credits are put at risk — through no fault of their own and with no due-diligence step available to have prevented it. That outcome is not only unfair to the participant; it’s corrosive to confidence in the program.

Two complementary fixes would help. First, in the context of organizations meeting the charging-network operator definition, ECCC could clarify what “data ownership” is intended to mean in practice — particularly when charging session info is accessed through an open API rather than a one-to-one connection — so that eligibility is not left entirely to interpretation. Second, and more immediately, a transparent registry (as above) or a lightweight registration and priority process would let the strongest claimant establish and defend its position before verification costs are sunk and duplicated credits are potentially issued. Peer programs already do versions of this: the California LCFS, for example, publishes a quarterly list by address of non-residential fuel supply equipment registered in the program, along with the name of the entity claiming the units. This allows new entrants the opportunity to better understand the reporting landscape prior to reporting chargers, and gives them a chance to reach out directly to a group that may contest their claim.

3. Build dedicated, fuel-specific expertise and clearer channels for engagement

Finally, the EV charging space moves quickly and behaves differently from other fuel streams. Asking one generalist to be the expert across biofuels, RNG, hydrogen, and electricity underserves all of them, because each carries its own distinct problems. We’d encourage ECCC to develop — or, if it already exists, to make clearly identifiable — dedicated staff or points of contact specializing by fuel type, with genuine depth on the EV charging ecosystem: the software layer, site-host dynamics, telematics, and the full cast of installers, OEMs, network operators, and developers involved.

Alongside that, more proactive public engagement would go a long way. Industry wants to be collaborative. A named point of contact for electricity — rather than a general inbox — would let participants share lessons learned, flag emerging risks early, and help ECCC stay ahead of a landscape that is still taking shape. That kind of two-way channel is one of the most effective, lowest-cost integrity tools a regulator has.

A shared interest in getting this right

None of these suggestions is adversarial, and none requires reinventing the program. The tools already exist in other jurisdictions, the identifying data already flows into ECCC, and the participants most affected are eager to help. Publishing a charger registry, clarifying the network-operator role, and building fuel-specific expertise would foster exactly the kind of cooperation the CFR needs as its EV segment matures — letting registered creators resolve overlaps among themselves, lightening ECCC’s adjudication load, and keeping the integrity of the program strong. Everyone benefits from a program that participants and the public can trust.

We also recognize that, within any government agency, competing priorities contend for limited staff time, budget, and resources. That is part of what makes these particular suggestions so encouraging: to the best of our understanding, none is necessarily confined to a formal amendment cycle. Each could instead be designed and delivered through the guidance documents and datasets ECCC already develops and posts as part of normal program administration — meaning they could be put in place sooner rather than later, ideally ahead of reporting for the 2026 compliance period in April 2027. Industry is ready to provide feedback and to collaborate on implementation, and FuSE would welcome the opportunity to share what we have learned and to work alongside ECCC toward that shared goal.