The Informal Working Group on Cyber Security and Software Updates will continue to consider how cyber security and software updates have a bearing on automotive safety and security, and whether any changes are necessary to the Regulations and guidance it has produced under WP.29. In particular, the IWG shall maintain official documents regarding UN R155, UN R156, and Recommendations on uniform provisions concerning cyber security and software updates; develop amendments to relevant documents; develop a proposal to amend UN Regulations under the responsibility of GRVA to record details of an RXSWIN where applicable which have been mandated by the 01 series of UN Regulation No. 156; develop proposals to amend UN Regulation No. 155 and its interpretation document to support application in national/regional frameworks for aspects such as multi-stage manufacturing; consider and develop deliverables regarding software updates after registration potentially creating a proposal for modification to the type approval numbering or a classification of update categories; support and review the application of cyber security and software update provisions across GRs notably for the Global Technical Regulation on Automated Driving Systems; and provide opportunities to participants to share knowledge, experience and ideas from implementation of national regulation/standards regarding CS/OTA as well as UN R155 and R156. The IWG will continue its activities until November 2029.

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.

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.

The agenda includes review of proposals for amendments to R155 concerning multistage vehicles, separate technical units and component approval, approval-authority requirements for CSMS CoC and vehicle type approval, and remote operation for ADS; review of cyber and software requirements in the ADS Regulation based on WP.29/2022/60 as amended by WP.29/2023/87; discussion of RXWIN application amendments; and consideration of terms of reference renewal ahead of mandate expiration in November 2026.

Vehicles of categories M₁, N, O, R, S and T may fall out of scope of UN R155 or UN R156 if they lack ECUs or do not permit software updates. Approval authorities currently make individual determinations regarding whether vehicles are in or out of scope, and justification for out-of-scope decisions must be recorded to ensure vehicles remain out of scope during the lifetime of whole vehicle approval. UN Regulation No. 10 provides precedent by allowing approvals for vehicles where certain equipment is not relevant. A similar provision could be incorporated into UN R155 and UN R156 by amending the scope and adding provisions to section 5 allowing manufacturers to obtain approvals for vehicles that do not permit software updates, with requirements of paragraph 7 not applying.

The document requests guidance on the legal basis for provisions within UN Regulations extending beyond the End-of-Production date and which authority such provisions address. Examples include UN R171 requirements for manufacturers to demonstrate safety management systems to the Type Approval Authority every three years and report annually on Driven Coded Auxiliary System operation until production is discontinued, and UN R155 requirements for Cyber Security Management Systems to apply to the post-production phase when vehicles remain operational but are no longer produced. The document poses an additional question regarding vehicle safety when manufacturers cease operations and cannot fulfill post-deployment safety provisions.

The CS/OTA Task Force held its thirty-seventh session on 21-22 April 2026 by video conference. The group adopted the provisional agenda and minutes from the thirty-sixth session. Discussions addressed proposals for amendments to UN R155 concerning multi-stage vehicle approvals and separate technical units, for which a subworking group was established. Proposals were also considered on type approval authority responsibility for cyber security management systems and remote operation of automated driving systems. The group reviewed cyber and software requirements in the ADS GTR and WP.29/2022/60 as amended by WP.29/2023/87, and discussed application of RXSWIN to UN Regulations, selecting option 2 for presentation to GRVA with R155, R156, and R89 square bracketed. The IWG mandate renewal was discussed, with potential new items including component and STU approval and software numbering proposals.

China supports establishing a new task force or informal working group on vehicle data security and sees the need for a dedicated UN Regulation or Global Technical Regulation. Work can begin with applicability analysis of existing regulations, gradually establishing the main framework of the standard, the scope of data management, and handling of special cases. China is ready to act as a key contributor, offering typical use cases, design questionnaires based on GB 44497 and GB 44464, delivering terms of reference with other Contracting Parties, and proposing basic framework and specific requirements by February 2028.

The Informal Working Group on Cyber Security and Software Updates discussed amendments to UN R155 and UN R156 for multi-stage approval, including simplified handling for low-risk devices and clarification of intrinsic cyber risk assessment. The group reviewed proposals from GRVA-25-31 and GRVA-25-32 concerning continued validity of approvals and Certificate of Compliance issuance. A Sub-Working Group was established to develop component and separate technical unit approval concepts. Pending discussion include RXSWIN application to components, STUs, and the extent of application to UN R155 and UN R156, and type-approval numbering for software updates.

Proposal to insert provisions on software identification and software updates into UN R13, UN R13-H, UN R79, UN R89, UN R130, UN R131, UN R152, UN R155, UN R156, UN R157, UN R171, UN R175, and UN R178 by adding definitions referencing Consolidated Resolution R.E.3 Annex 7, requiring manufacturers to provide Technical Services with information on hardware and software influencing performance, permitting vehicle manufacturers to apply for new approvals differentiating software versions for registered versus new vehicles, clarifying that production discontinuation does not apply when manufacturers seek approval extensions for software updates of registered vehicles, and amending communication forms to include software identification numbers and related information.

Proposal to amend UN R155 regarding cyber security assessment and approval procedures:

• Amend para. 5.3.2. to require approval authorities to notify other approval authorities of methods and criteria used to assess measures taken in accordance with the Regulation
• Insert new para. 8.2. to exclude equipment with negligible intrinsic cyber security risk from further assessment where installation does not impinge on the cyber security management system and is connected exclusively via an approved interface
• Insert new para. 8.3. to exclude standard domestic, business or industrial equipment connected only for power from further assessment where the equipment is unmodified and complies with applicable regional and national cyber security requirements
• Amend Annex 1 to include any equipment excluded from assessment pursuant to paras. 8.2. and 8.3.

Proposal to insert new Part C providing guidance on application of UN R155 to transformed vehicles. Part C defines when transformations require new approval, establishes terminology for original vehicle types, transformed vehicle types, transformations, and installations, identifies cyber-relevant transformations by evaluating impact on architecture and connection risks, addresses intrinsic cyber security risks, clarifies non-automotive equipment requirements, and specifies documentary evidence manufacturers must provide to approval authorities or technical services, including functional descriptions, connection details, software modifications, and component lists.

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.

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.

The UN IWG on Cyber Security and OTA will meet April 21-22, 2026 via video conference. The agenda includes adoption of the provisional agenda and minutes from the previous session, proposals for amendments to UN R155 and its interpretation document regarding multistage vehicles and type approval authorities, review of cyber and software requirements in the ADS Regulation, discussion of RXSWIN application, renewal of the IWG mandate expiring November 2026, and confirmation of next steps.

Proposal to amend UN R155 by clarifying its scope to exclude certain equipment. The proposal amends paragraph 5.3.2. to require approval authorities to notify others of assessment methods and criteria. New paragraphs 8.2. and 8.3. establish that vehicle manufacturer installation of equipment with negligible intrinsic cyber security risk, or standard domestic, business or industrial equipment connected only for power, shall not require further assessment under paragraph 7, provided specified criteria are justified. Annex I is amended to include any equipment excluded from assessment pursuant to paragraphs 8.2. and 8.3.

The Informal Working Group on EV/HFCV Retrofit Systems held its seventh meeting on 5th March 2026. The group adopted the provisional agenda, approved minutes of the previous meeting, and acknowledged ongoing activities under GRPE, GRSP and GRVA. Electrical safety review will continue once clarification regarding UN R100 is available. Cybersecurity discussions covered very old vehicles, older vehicles without cybersecurity provisions, and modern vehicles compliant with UN R155. Braking aspects and the structure of the draft UN Regulation were discussed, including vehicle versus system approval approaches and minimum and maximum vehicle age within the regulation’s scope.

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.

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.

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.