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.

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 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.