Virginia currently uses the 2020 National Electrical Code as the referenced electrical code under the current Virginia code cycle. NEC 625.54 requires receptacles installed for the connection of electric vehicle charging equipment to have ground-fault circuit-interrupter protection for personnel.
For a new NEMA 14-50 EV charging receptacle, the circuit should therefore be designed with the applicable GFCI protection required for the installation.
This requirement applies because the receptacle is being installed for EV charging—not simply because it happens to be located in a garage.
A hardwired EV charging installation does not use the exact same receptacle and GFCI arrangement. Its protection and circuit design are evaluated as part of that hardwired installation.