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.

Proposal to amend UN R155 by clarifying its scope to exclude certain equipment. The proposal amends paragraph 5.3.2. to require approval authorities to notify others of assessment methods and criteria. New paragraphs 8.2. and 8.3. establish that vehicle manufacturer installation of equipment with negligible intrinsic cyber security risk, or standard domestic, business or industrial equipment connected only for power, shall not require further assessment under paragraph 7, provided specified criteria are justified. Annex I is amended to include any equipment excluded from assessment pursuant to paragraphs 8.2. and 8.3.

Proposal to provide guidance on application of UN R155 to transformed vehicles. Transformations require new approval unless clear evidence shows original approval remains valid. Cyber-relevant modifications include addition of electrical/electronic systems, inappropriate interface connections, and wiring protection modifications. The approval authority determines whether transformation is cyber-relevant by assessing impact on original vehicle architecture, connection risks, cybersecurity management systems, and whether non-automotive equipment complies with relevant regulations. Manufacturers must provide documentary evidence including functional descriptions, connection details, software modifications, and compliance with original manufacturer instructions.

Questions concerning cyber security amendments for approvals of STU submitted by the expert from Japan that address timing of working document submission to GRVA, whether Part II components may include certificated base vehicle equipment under UN R155 multi-stage categorization, whether STU definition includes ECUs within base vehicle E/E architecture, examination of use cases and implementation challenges, consistency of applicant terminology between Section 3.3.1 and Section 7.6, whether approval authorities for Parts I, II, and III must be identical, clarification of end of support period requirements in para. 2.7(b), installation agreement requirements in para. 5.1.2.1(d), and whether total Cyber Security Risk Assessment Process for whole vehicle with other equipment than ESAs is necessary after ESA installation under para. 7.4.10.

This document presents an initial concept for approvals of devices as components or separate technical units according to UN R155, and the installation of such devices on vehicles already holding UN R155 approval, based on Supplement 3 to the original series. The regulation applies to vehicles of categories L₁–L₇, M₁–M₃, N₁–N₃, and O₁–O₄ with electronic control units, and to approval of components and separate technical units with regard to their cyber security. Approval authorities shall grant type approval only to vehicle or electrical/electronic sub-assembly types that satisfy the regulation’s requirements through document checks and testing. Manufacturers must demonstrate cyber security management systems covering development, production, and post-production phases, including risk assessment, mitigation implementation, monitoring, and response to cyber-attacks. Certificates of Compliance for Cyber Security Management Systems remain valid for three years.

TFCS-37-08 presents proposals to amend UN R155 to establish approval routes for electrical/electronic sub-assemblies and separate technical units. The regulation introduces three parts: Part I covers vehicle cyber security approval; Part II covers component and separate technical unit approval; Part III covers installation approval of approved components and separate technical units in vehicles. Updates include new definitions, application procedures by manufacturers or their representatives, approval conditions specifying connection limitations, and cyber security management system requirements. The proposal requests colleague review and feedback.

Proposal to amend Table A1 of Annex 5 to include high level and sub-level descriptions of vulnerability and threat including spoofing of messages, Sybil attacks, communication channels permitting code injection, manipulation, overwrite and erasure of vehicle held data and code, denial of service attacks, unauthorized access to vehicle systems, viruses in communication media, and malicious messages, and amend Table B1 of Annex 5 to provide corresponding mitigation measures. This proposal is a further elaboration of TFCS-35-07.

UN R155 addresses operator risks in automated driving systems. The ADS Regulation enables operators to offer services using automation and permits remote termination of the ADS. UN R155 mandates that supplier-related risks are managed, but operators are customers, not suppliers, creating downstream risks. An automated vehicle could be susceptible to unauthorised requests from an operator experiencing cyber attack. UN R155 does not define how downstream organisational risks are managed. Manufacturers should identify risks posed by operators and inform Third Party Operators of risks involved and expected minimum-security controls for workstations interfacing with an ADS. This could be achieved via Annex 5.

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.