Why Social Housing Can't Yet Procure EV Charging at Scale: The Concession Gap
Social housing providers across the UK are under growing pressure to deliver EV charging infrastructure for their residents. Resident demand is rising, existing infrastructure is ageing and the policy direction of electrified travel is set. What's far less clear is how a housing provider is actually supposed to buy this infrastructure because the procurement route that would make scale deployment affordable simply doesn't exist yet.
1. Compliant procurement routes exist. But viable ones don’t.
It's worth being clear about what isn't broken. Public procurement law is not, in itself, a barrier to deploying EV charging in social housing. Registered providers have a well-worn toolkit for meeting their obligations under the Public Contracts Regulations without running a full OJEU-style tender for every scheme.
Frameworks such as PfH, LHC's N9, ESPO, Fusion21 and CHIC exist precisely to remove that friction. They pre-qualify suppliers, standardise terms, and let a housing association call off a contract in weeks rather than months, with the compliance risk already engineered out. For a straightforward purchase / Lease contract, this system works well. Any provider wanting to buy chargepoints or engage a contractor to install them has a clear, low-friction, legally sound route to do so.
So if compliance isn't the constraint, what is?
2. Direct purchase and lease models don't scale in social housing (or anywhere else)
Landlords don’t have much spare capital as a rule. Social Housing providers certainly abide by this. With regulated rents, thin margins, and capital programmes that are already stretched across decarbonisation, fire safety remediation, and core stock maintenance adding EV charging as a capital purchase… well it’s largely unthinkable. When competing directly with those other statutory and safety-critical priorities, it rarely wins.
Lease models don't solve this either. A lease still shows up as a liability on the books, still requires revenue cover, and still needs a business case that stacks up against alternative uses of constrained funds.
What does work, in principle, is a concession model: a third party (like Cosmic) designs, funds, installs, owns and operates the infrastructure, taking on the capital risk in exchange for a share of usage revenue, with little or no capital outlay required from the housing provider. This is exactly the model that has allowed EV infrastructure to scale in local authority on-street parking and other public sector contexts. For social housing, given the balance sheet constraints described above, a concession-style route is not just preferable it is, realistically, the only route through which infrastructure can be deployed at the scale the coming years will demand.
3. But no framework actually supports a concession route
Here's the gap. Despite the frameworks above being genuinely well-designed for compliant procurement, none of them are built to carry a concession-style contract for EV infrastructure.
The reason comes down to how these frameworks are typically funded. Framework operators take their management fee as a percentage of contract value at the point of purchase. That model depends on there being a purchase (or Lease) price to take a percentage of. A concession arrangement, by design, doesn't have one. There is no capital sum changing hands between the housing provider and the supplier, because the supplier is the one funding the asset. From the framework's commercial perspective, a concession contract generates little or no fee income, so there's no incentive to build a route that accommodates one.
The practical result is that a housing provider wanting to explore a concession model for EV charging has to step outside the frameworks entirely and run a standalone procurement. For an under-resourced procurement team already stretched across decarbonisation and safety programmes, that's often enough to make the whole idea unworkable, regardless of how sound the underlying business case is.
The result: a structural dead end
Put the three points together and the problem becomes obvious. The only procurement route by which social housing can realistically deploy EV infrastructure at scale is a concession-style model. But every framework built to make procurement fast, safe and low-risk is structurally unable to carry that model, because their fee mechanics assume a purchase price that concessions don't produce.
The consequence isn't a slower rollout; it's very little rollout at all.
There are a small number of providers with the capital headroom to buy outright or the in-house procurement capacity to run a bespoke concession tender themselves. Everyone else is left waiting for a route that, at present, does not exist.
This is a solvable problem. It requires framework operators, or the Government, to design a fee structure for concession-style contracts that doesn't depend on capital value: a fixed listing fee, a small percentage of ongoing revenue share, or a flat annual charge for supplier access to the framework. Until that happens, social housing providers will keep being told that concession funding is the answer to EV charging affordability, without anyone giving them a compliant, low-friction way to actually buy it.
Other barriers
Unfortunately procurement routes aren’t the only challenge faced by Social Housing providers. Lack of grants to support infrastructure capital whilst the market is still early, unclear headline policy around the ZEV mandate, 3p per mile road tax, the cost of energy from typical landlord supplies and building safety also complicate the process significantly. These challenges are progressively being knocked down. Engaging a patient, progressive and data driven strategy alongside a trust charge point operator is vital.
Cosmic Charging works with housing providers, contractors and framework operators on the practical realities of procuring EV infrastructure at scale. Get in touch if you're navigating this gap on a live scheme or organisation wide strategy.
