Proposal to amend para. 3.5.1. in Annex 3 to require the manufacturer to demonstrate to the Type Approval Authority at least every three years that the safety management system continues to comply with requirements for software and hardware employed in the system to manage safety and continued compliance throughout the product lifecycle. This amendment resolves outstanding issues in the 01 series of amendments to UN Regulation No. 171.

Proposal to amend Annex 8, para. 3.4.1. to require that the strategy chosen shall not prejudice safe operation of the system due to failures with other systems involved in achieving the function of the system, and amend Annex 8, para. 3.4.4. to require that analysis of system behaviour on fault occurrence includes faults with other systems involved in achieving the function of the system, and to correct ‘safetys’ to ‘safety’. The proposal addresses a collision where tyre failure resulted in unsafe ABS activation. Although the 02 series clarified ABS as part of electronic control systems assessment, it does not explicitly state what is covered, potentially missing relevant faults or failures influencing system function. The additions ensure all relevant faults or failures are accounted for in manufacturers’ safety concept and analysis.

Proposal to amend Annex 4 – Data elements and format, Table 1, modifying Advanced driver distraction warning (ADDW) data elements to record status and time since warning issued instead of number of warnings and time elapsed since last warning, modifying Driver control assistance system (DCAS) driver monitoring system data elements to record time since disengagement warning issued and warning type instead of number of hands-on requests, eyes-on requests, direct control alerts, and time elapsed since last warning, and adding Driver drowsiness and attention warning (DDAW) status and time since warning issued data elements while removing number of warnings and time elapsed since last warning, with ADDW and DDAW elements listed up to five times for most recent warnings and DCAS warning type listed up to fifteen times for most recent warnings on current trip.

Proposal to amend UN R160:

• Amend definitions 2.8., 2.10., and 2.11. to clarify that automatically commanded steering function categories B2, D, and E are not part of a DCAS
• Delete definition 2.25.
• Amend definition 2.35. to simplify non-volatile memory
• Amend para. 2.45. to change service brake terminology
• Amend para. 2.51. to clarify time interval between events
• Amend para. 2.65. to abbreviate vulnerable road user
• Insert new definitions 2.71.–2.83. for rollover protection system, advanced emergency braking system, trigger activated, pre-event synchronization timer, blind spot monitoring system, emergency stop signal, turn signal, acceleration control for pedal error, advanced driver distraction warning system, driver drowsiness and attention warning system, driver control assistance system, and time to collision
• Restructure para. 5.3.1. to distinguish planar, VRU, and rollover events from AEBS events with specified triggers
• Amend para. 5.3.2. to clarify data locking conditions
• Restructure para. 5.3.3. to establish time zero for planar, VRU, rollover, and AEBS events
• Amend para. 5.4.3. to specify side and frontal collision tests
• Amend para. 6.1. to clarify post-crash acceleration measurement
• Insert transitional provisions 12.12.–12.16. providing that as from the official date of entry into force Contracting Parties shall not refuse type-approvals under the 03 series, as from 1 September 2031 or 2029 [date TBD] shall not accept type-approvals to preceding series first issued after that date, until 1 September 2033 shall continue accepting preceding series approvals first issued before 1 September 2031 or 2029 [date TBD], may grant approvals to preceding series, and shall grant extensions of existing approvals
• Amend Annex 4 Table 1 to split engine throttle and accelerator pedal data elements, increase sampling rates to 10 Hz, extend recording intervals for rollover events, add pre-event synchronization timer, trigger activated, ACPE status, ADDW status, DDAW status, blind spot monitoring status, turn signal status, DCAS status, DCAS driver monitoring system warnings, emergency stop signal status, and time to collision data elements, and modify footnotes accordingly

Proposal to amend UN R160:

• Insert new paras. 12.12. to 12.17. establishing transitional provisions for the 03 series of amendments, including that:
  • from the official date of entry into force, no Contracting Party shall refuse type approvals under the amended Regulation,
  • from 1 September 2031, Contracting Parties shall not be obliged to accept type approvals to preceding series first issued after that date,
  • until 1 September 2033, Contracting Parties shall accept type approvals to the 02 series first issued before 1 September 2031,
  • from 1 September 2033, Contracting Parties shall not be obliged to accept type approvals to preceding series,
  • Contracting Parties may grant type approvals according to any preceding series,
  • and Contracting Parties shall continue to grant extensions of existing approvals to any preceding series,
• Amend Annex 4 Table 1 and footnotes 28, 29, and 30 regarding trigger activated recording, powertrain torque demand signals, AEBS target classification, and TTC calculation requirements.

Proposal to amend footnote 25 to reduce the maximum number of recorded DCAS warnings from 15 to 10 per current ignition cycle. The justification presented cites data burden reduction while retaining information about habitual driver disengagement patterns. Supporting documentation references two autopilot collision cases—Florida 2016 and California 2018—where recorded warnings within existing data retention periods would have revealed repeated disengagement that current recording parameters miss, demonstrating that 10 warnings combined with extended recording duration enables identification of ineffective warning strategies.

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.

Questions address whether minimum vehicle architecture approval should be required before Part III can be used for additional devices; whether approved ESAs can be incorporated in original vehicle approval or as an extension to Part I approval; whether different terminology should replace CSMS for Part III approvals; whether second Part III approvals are permissible for vehicles already approved to Parts I and III; and what implications arise from end-of-support by ESA manufacturers.

Answers to questions on separate technical unit approvals under UN R155 clarify that a base vehicle must already hold an R155 type approval before an ESA can be added at Part III; approval authorities for different parts may differ with mutual recognition applying; the end of support period for an ESA manufacturer must be communicated to the vehicle manufacturer, with implications to be discussed by the IWG; installation of ESAs must follow vehicle manufacturer instructions without necessarily requiring separate agreement; STU data sharing agreements are required; and after ESA installation, a whole vehicle cyber security risk assessment is not necessary, though Part III must consider risks where ESA and base vehicle interactions occur. A working document is planned for submission to GRVA in January 2027. The IWG will explore whether Part II components may include equipment from certificated base vehicles under UN R155 multi-stage categorization and discuss incorporating STU into original approvals.

Amend para. AI to replace the heading “Examples of documents/evidence that could be provided” with “Explanation of the requirement” and insert text stating that Part C of this document provides further guidance on the application of the Regulation to vehicles which have been modified by carrying out a transformation of the vehicle.

The document presents vehicle modification use cases categorized into four cases and additional scenarios. Case 1 covers components with negligible risk or cyber-relevant non-automotive devices. Case 2 addresses cyber-relevant automotive devices approved to specific regulatory requirements, requiring installation approval and vehicle type re-approval. Case 3a addresses cyber-relevant devices not approved to specific requirements, requiring component or STU approval. Case 3b covers devices controlling vehicle functions, also requiring component or STU approval. Case 4 encompasses invasive modifications or complex interactions not covered by other cases.

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.