UN R79 mandates verification that appropriate warning signals are provided to the driver based on the timing of a system intervention (e.g., in the case of a Risk Mitigation Function). This proposal aims to clarify the moment of initiation of the signals to facilitate the verification of driver warnings, hazard lights, and other indicators in relation to this objectively determined initiation point. The proposal requires manufacturers to define a clear and accessible method for objectively determining the moment of initiation.

Proposal to set clear criteria for manufacturers of transformed vehicles to determine when a given transformed vehicle needs or needs not undergo a more detailed cyber security review according to the processes for transformed vehicles currently being discussed by the GRVA workshop on cybers ecurity and software updates.

The document presents a non-exhaustive list of automotive use cases of AI aligned with WP.29/1182, incorporating contributions from AI-02-04 and AI-02-05. It focuses on use cases regarding the use of artificial intelligence in regulated automotive safety systems. The list is split between driving functions (perception, planning and motion-control) and non-driving functions (driver occupant monitoring systems and monitoring systems for vehicle components or functions), following a risk-based approach.

Proposal to amend UN Regulation No. 39 (Speedometer and odometer) to introduce software update references and identification. New provisions add definitions regarding Software Identification Number, refer to Consolidated Resolution on the Construction of Vehicles (R.E.3), Annex 7, paragraph 2. Modifications address production definitively discontinued, software updates for registered vehicles, hardware and software information provision, vehicle approval for differentiating software versions, and additional information regarding software identification. The proposal references ECE/TRANS/WP.29/1175, paragraph 37, and incorporates provisions from R.E.3 Annex 7 to define R39SWIN as dedicated identifier representing type-approval relevant software information.

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 add work lamp definitions and requirements to UN R48, minimum height of 250 mm above ground, downward orientation, and automatic deactivation within 1 second if vehicle speed exceeds 15 km/h. Work lamps require independent manual controls and a mandatory visual operating tell-tale. Annex 1 adds item 9.32. for work lamp approval documentation.

Proposal to amend para. 8.1.5.1. (ADS UNR) of the audit of the safety policy guidance: Change “may state” to “states,” “may address” to “addresses,” and “may therefore describe” to “therefore describes.” The rationale states that using “may” in the interpretation paragraphs seems inappropriate for explaining regulatory intention, and present tense better suits these requirements.

Proposal to amend UN R155 and UN R156 regarding approval authority requirements:

• Add a refusal ground to para. 5.1.3. of UN R155 where the Certificate of Compliance for the Cyber Security Management System has not been issued by the same approval authority granting type approval
• Insert new para. 5.4. into UN R156 to provide that approval authorities shall not grant any type approval if the Certificate of Compliance for the Software Update Management System has not been issued by the same approval authority granting type approval.

Proposal to account for vehicles of category X and to extend its application to vehicles without driver and manual driving controls. New sections introduce definitions for Automated Driving System features (ADSF-1 and ADSF-2) and establish requirements for door closure warning systems and locking devices for vehicles equipped with ADSF-2. Vehicles of category Y are excluded from scope. Various paragraphs are amended regarding door systems, locking mechanisms, and impact definitions to address automated driving scenarios.

For the purposes of type approval under any UN Regulation requiring the verification of the timing of a system intervention, manufacturers shall provide to the approval authority or its designated technical service information on the method by which the initiation of any system intervention can be objectively identified and retrieved, including specific flags, status bits, event codes on in-vehicle networks, or visual indications on screens; clear instructions and all necessary tools for the Technical Service to extract, access and interpret the signal identifying the initiation; documented procedures including corresponding data sources, resolution, and timing accuracy appended to the type approval test report; and, where a visual indication displayed on a screen is used, documented latency between the earliest internal point at which the system initiates the function and the moment the visual indication becomes visible on the screen, expressed as a fixed value with associated uncertainty, with the documented latency value used to correct the observed timing of the screen indication appended to the type approval test report.

France supports retaining risks 3.5 (unreliable uncertainty estimation) and 6.1 (adversarial input manipulation) in Table 1. France favours secretarial text for mitigations 3.1 (blackbox behaviour), 3.2 (lack of robustness), and 3.4 (model over/underfitting) in Table 2. In Annex I, para. 11 addressing lack of robustness, France favours deleting the industry proposal on explanation of mitigations, pending merger with the mitigations table subject to level of detail determination.

Proposal to amend para. 9.(a) to clarify expansion of the protection scope of electrical and battery safety, including thermal propagation in cases of V2X, parking, and charging. The modification addresses new vehicle functionalities like V2X, defined in UN GTR No. 22, where traction batteries cover external power and energy demand. Additional requirements must be added, including isolation resistance requirements for coupling systems for charging the REESS, as defined in para. 5.1.1.2.4.4. of UN GTR No. 20.

France requests that the implementation date for all new vehicles be extended until September 2034 rather than the currently proposed date.

Proposal for editorial modifications to official documents introducing ADS-related amendments to WP.29/2026/59, WP.29/2026/61, WP.29/2026/62, WP.29/2026/48, WP.29/2026/63, WP.29/2026/64, WP.29/2026/65, WP.29/2026/66, WP.29/2026/50, WP.29/2026/53, WP.29/2026/57, WP.29/2026/67, WP.29/2026/68, WP.29/2026/69, WP.29/2026/70, WP.29/2026/71, WP.29/2026/72, WP.29/2026/162, WP.29/2026/163, WP.29/2026/147, WP.29/2026/148, WP.29/2026/149, WP.29/2026/150, WP.29/2026/151, WP.29/2026/154, WP.29/2026/101, WP.29/2026/102, WP.29/2026/103, WP.29/2026/104, WP.29/2026/105, WP.29/2026/106, WP.29/2026/107, WP.29/2026/108, WP.29/2026/109, WP.29/2026/110, WP.29/2026/111, WP.29/2026/112, WP.29/2026/113, WP.29/2026/114, WP.29/2026/115, WP.29/2026/116, WP.29/2026/118, WP.29/2026/117, WP.29/2026/119, WP.29/2026/120, WP.29/2026/121, WP.29/2026/122, WP.29/2026/125, WP.29/2026/126, WP.29/2026/127, WP.29/2026/129, WP.29/2026/130, WP.29/2026/131, WP.29/2026/132, WP.29/2026/165, WP.29/2026/166, WP.29/2026/134, WP.29/2026/159, WP.29/2026/124, WP.29/2026/133, WP.29/2026/158, WP.29/2026/89, WP.29/2026/90, WP.29/2026/95, WP.29/2026/98, and WP.29/2026/145.

Proposal to insert paragraphs establishing references to Software Identification Number definitions in Consolidated Resolution R.E.3 Annex 7 para. 2, insert paragraphs requiring manufacturers to provide Technical Services with information on hardware and software influencing performance, insert paragraphs allowing vehicle manufacturers to apply for new approvals to differentiate software versions for registered vehicles from those for new vehicles with duplication of tests avoided where possible, amend production discontinuation provisions to clarify that production is not considered definitively discontinued if manufacturers intend to obtain subsequent extensions for software updates of registered vehicles, and amend approval communications to include additional information regarding software identification and software updates in UN Regulations 51, 64, 138, 141, 142 and 165, as presented in document GRBP-83-36 and implementing Revision 8 to Consolidated Resolution No. 3 (WP.29/2025/147).

France presented feedback from a dedicated workshop on virtual testing held 7 May 2026, attended by up to 55 participants including competent persons, OICA, CLEPA, and ETRTO. The majority supports basing the proposal on the latest content of the Automated Driving Systems regulation rather than UN R152, with extraction suitable for all applications. The group agreed that an amendment to Resolution MR.1 is the best administrative option to cover both agreements. Technical content requiring agreement includes definitions, terminology, application to components and Specified Technical Units, uncertainties, safety margins, credibility levels, audit skills, and ISO references. Virtual testing should remain an alternative to physical testing. France will organize another workshop on 25 September 2026, with written contributions due by 11 September.

Responses to EPPR questionnaire on legislative gaps in the transposition of GTR 2 into UN R40.

Proposal to amend UN R155 by inserting new para. 5.1.3.(e) establishing that the Certificate of Compliance for the Cyber Security Management System shall not be issued by a different Approval Authority than the one granting type approval, and amend UN R156 by inserting new para. 5.4. establishing that Approval Authorities shall not grant type approval if the Certificate of Compliance for the Software Update Management System has not been issued by the same Approval Authority granting type approval. Justification includes ensuring holistic cybersecurity assessment, clarifying reporting obligations under para. 7.2.2.2.(g), addressing unharmonized mutual recognition of management system certificates, maintaining consistency between regulations, and upholding the fundamental principle that approval authorities retain responsibility for all aspects of type approval.

Proposal to insert a new para. 5.1.12. requiring that manufacturers provide information on the method by which the initiation signal of any system intervention required by the Regulation can be objectively identified and retrieved, including specific flags, status bits, or event codes on in-vehicle networks, and that manufacturers provide clear instructions and all necessary tools for the technical service to extract and interpret the signal, with the procedure for identifying the initiation of the system intervention and corresponding data appended to the test report.