Proposal to amend UN R155 and UN R156 to require that Certificates of Compliance for Cyber Security Management Systems and Software Update Management Systems be issued by the same approval authority that grants type approval. Germany reported a case where different authorities issued the certificate and type approval, creating assessment and enforcement issues. The proposal aims to ensure holistic cyber security evaluation and align both regulations.

Proposal to amend UN R13, 13-H, 79, 89, 130, 131, 139, 140, 152, 155, 156, 157, 171, 175, and 178 by introducing provisions on software identification and software updates. Amendments add new paragraphs referring to Software Identification Number definitions in Consolidated Resolution R.E.3, require manufacturers to provide Technical Services with information on hardware and software influencing performance, permit vehicle manufacturers to apply for new approvals differentiating software versions for registered versus new vehicles while avoiding test duplication, and modify production discontinuation provisions to exclude cases where manufacturers seek approval extensions for software updates of registered vehicles.

Germany proposes that the TAA granting UN R155 or UN R156 type approvals shall be obliged to only use CSMS or SUMS certificates signed by the same TAA. Issues identified include that CSMS and SUMS are Management Systems covering entire manufacturers’ organizations, mandating the same TAA will have huge consequences for OEMs using multiple TAAs, and no such obligation exists for ISO 9001 and ISO 14001. A possible way forward in the short term is to keep text unchanged to allow different TAAs for Management Systems CoC and type approval based on voluntary acceptance and implement wording on information exchange and procedure if different TAAs involved.