Proposal to amend Paragraph B to insert new requirement 5.1.3 establishing that the Approval Authority or Technical Service shall refuse to grant type approval regarding cyber security where the vehicle manufacturer has not fulfilled requirements in paragraph 7.3., notably that the Certificate of Compliance for the Cyber Security Management System has not been issued by the same Approval Authority granting the type approval, add explanatory text clarifying that this ensures Article 2(2) of the 1958 Agreement compliance while permitting cooperation between Approval Authorities and acceptance of prior documentation, amend Paragraph K to remove existing guidance text in paragraphs 6.1 and 7.1 regarding Certificate of Compliance issuance and inter-Authority arrangements, and insert statement that no guidance is included regarding paragraph 6 requirements. These changes support proposal GRVA/2026/30.

This document presents a concept for approvals of electrical/electronic sub-assemblies (ESAs) as components according to UN R155, and the installation of such approved components on vehicles already holding UN R155 approval. The proposal removes the possibility of separate technical unit (STU) approvals as a first step, limiting coverage to components connected only to power and/or reading data through approved existing interfaces. The document restructures UN R155 into three parts: Part I covers vehicle type approvals; Part II covers ESA component approvals with cybersecurity requirements; Part III covers vehicle type approvals regarding installation of approved ESAs. Requirements include cybersecurity management systems, risk assessments, threat mitigations, and reporting provisions for development, production, and post-production phases.

Proposed changes to align RxSWIN provisions with the RxSWIN template adopted through WP.29-197-06, remove the proposed requirement to comply with UN R156/01 or later from R157 and R171, remove amendments to UN R155 as decided by the IWG CS/OTA, apply the RxSWIN amendments also to earlier series of amendments in R13, R13-H, R79, R131, R152, R157, and R171, update references to the latest version of R.E.3, ECE/TRANS/WP.29/78/Rev.8, in earlier series, and correct paragraph references and improve structure in R89, R139, R140, R155, R156, and R171.

Proposal to amend GRVA/2026/27, which proposes amendments to UN R13, UN R13-H, UN R79, UN R89, UN R130, UN R131, UN R139, UN R140, UN R152, UN R156, UN R157, UN R171, UN R175, and UN R178:

• Throughout these regulations, amend references to the Consolidated Resolution on the Construction of Vehicles (R.E.3) as document ECE/TRANS/WP.29/78/Rev.8,
• insert new definitions for Software Identification Numbers referring to R.E.3 Annex 7 para. 2,
• amend requirements for software identification to require manufacturers provide necessary information allowing Technical Services to uniquely identify hardware and software configurations,
• insert new provisions allowing vehicle manufacturers to apply for new approvals differentiating software versions for vehicles already registered in the market from new vehicles,
• amend production discontinuation provisions to clarify production is not considered definitively discontinued if manufacturer intends to obtain subsequent extensions of approval for software updates of registered vehicles,
• insert new items in annexes regarding additional information on software identification and software updates including R_xSWIN identification, whether held on vehicle, how to read if not held on vehicle, and relevant parameters for vehicle identification.

OICA, CLEPA, and CLCCR oppose the requirement in GRVA/2026/30 for a single Approval Authority to issue the Certificate of Compliance for CSMS/SUMS and vehicle type approval. They contend the approach would create multiple approvals of the same Management System, imposing administrative burden and creating unresolved legal consequences if a CoC is challenged. The organizations propose adding a new paragraph 5.1.5. instead of paragraph 5.1.3. e) to permit mutual agreement between Approval Authorities, allowing usage of a CoC issued by another Approval Authority, with such agreement documented in type approval documentation.

Proposal to insert new paras. 27 and 28 in Part C Guidance for the application of UN Regulation No. 155 to transformed vehicles. Para. 27 states the requirement that the Certificate of Compliance and type approval are issued by the same Approval Authority applies only within the scope of the type approval granted to the manufacturer concerned. Para. 28 states where a vehicle manufacturer modifies a vehicle with existing type approval and applies for new type approval covering the modification, they need not use the same type approval authority as was used by the original vehicle manufacturer.

Proposal to amend para. 7.2.1.2.2. to delete, in cases where RXSWINs are not held on the vehicle, the requirement that the manufacturer shall declare the software version(s) of the vehicle or single ECUs with the connection to the relevant type approvals to the Approval Authority and that this declaration shall be updated each time the declared software version(s) is updated, and add that the link between the software version(s) and the RXSWINs shall be declared.

Japan submitted comments on RXSWIN assignment at the 38th CS/OTA IWG. Q.1 asks whether, when a type approval is extended from UN R156-00 to UN R156-01, RXSWIN may be assigned at extension time, and if a UN Regulation refers to RE.3 Annex 7 through a supplementary amendment after UN R156-01 transitional provisions become applicable, whether RXSWIN is assigned at that time. Q.2 asks whether Approval Authorities other than the Authority granting approval are expected to have access to the OEM’s Auditable Register, as access information appears provided only to the Approval Authority concerned through paragraph 9.5.2. Q.3 asks whether software updates affecting type approval can be performed under Regulations that do not reference RE.3 Annex 7.