Discussion of R.E.3. revision 8 adopted by WP.29 in November 2025, which allows vehicle manufacturers to apply for new approvals for software versions on registered vehicles. The Netherlands raised concerns about compatibility with type approval principles, the 1958 Agreement, and EU law, citing issues with traceability, multiple approvals for one type, approval requirements for non-production vehicles, and product marking. The document proposes distinguishing between ‘live’ approvals for new vehicles using normal type approval procedures and ‘legacy’ approvals for in-service vehicles using an updated revision concept, with updates to Schedule 3 of the 1958 Agreement and R.E.3. revision 9.