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Document explains concerns about the approach in GRVA/2026/30 to require a single Approval Authority to issue certificates of compliance for Cyber Security Management Systems and Automated Driving Systems Management Systems and vehicle type approval. The proposed changes would lead to double or triple approvals of management systems, creating administrative burden and unresolved legal consequences regarding challenged certificates of compliance and their effects on other issued certificates for the same management system. The submission proposes clarifying existing wording, documenting implications of challenged certificates, and adding a new paragraph 5.1.5. to UN R155 permitting mutual agreement between Approval Authorities regarding certificate usage.
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