The agenda includes adoption of the provisional agenda and minutes from the thirty-eighth session; proposals for amendments to R155 concerning multistage vehicles, separate technical units and component approval, and remote operation for automated driving systems; review of cyber and software requirements in the ADS Regulation; application of RXSWIN to R156; administrative provisions in R155 and R156 regarding Type Approval Authority for CSMS/SUMS and issuing approvals for out-of-scope vehicle types; and preparation of GRVA 26.

Proposal to insert provisions on Software Identification Numbers and software updates across UN R13, R13-H, R79, R89, R130, R131, R152, R155, R156, R157, R171, R175, and R178 by adding definitions referencing Consolidated Resolution R.E.3 Annex 7 paragraph 2, requiring manufacturers to provide Technical Services with information on hardware and software influencing performance with test reports, permitting vehicle manufacturers to apply for new approvals differentiating software versions for registered vehicles from new vehicles where type approval regulations are updated or hardware changes occur in series production with test duplication avoided where possible, clarifying that production is not considered definitively discontinued if manufacturers obtain subsequent extensions for software updates of registered vehicles, renumbering and inserting new items in approval communication annexes for R13SWIN, R13-HSWIN, R79SWIN, R89SWIN, R130SWIN, R131SWIN, R152SWIN, R155SWIN, R157SWIN, R171SWIN, R175SWIN, and R178SWIN information including whether held on vehicle and relevant parameter identification lists, and amending R157 and R171 to align software update requirements with R156 technical specifications and transitional provisions.

Proposal to insert new Part C providing guidance for the application of UN R155 to transformed vehicles. Part C addresses identification of cyber-relevant transformations, impact on original vehicle architecture, connection risks, and impact on cyber security management systems. It specifies that transformations require new approval unless the manufacturer provides clear evidence that the original approval remains valid, and outlines critical factors and examples of cyber-relevant actions. It details documentary evidence expected from manufacturers regarding functional descriptions, connections with original vehicle types, added components and functions, and arguments demonstrating negligible intrinsic risk.

Proposal to amend para. 5.3.2. to require notification of assessment methods and criteria including paras. 8.2. and 8.3., insert new paras. 8.2. and 8.3. establishing criteria for equipment installation without further assessment, and amend Annex 1 to require disclosure of equipment excluded from assessment pursuant to paras. 8.2. and 8.3. The amendments clarify that equipment with negligible intrinsic cyber security risk installed according to manufacturer specifications and not introducing cyber security risk, and standard non-automotive equipment connected solely for power supply with no increased cyber security risk, shall not invalidate approval of the original vehicle type under UN Regulation No. 155.

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.

The UN IWG on Cyber Security and OTA held its 38th session 29 June–1 July 2026 in London with remote participation. The group adopted the provisional agenda and minutes from the 37th session. Three items from the IWG were presented at the May GRVA meeting: multistage vehicle documents to become working documents for September; RXWIN documents with elements in square brackets to be resolved; and SUMs document returned for further discussion. For R155, the group agreed to forward multistage amendment proposals as working documents to September GRVA. The UK proposal on STU and component approval for R155 was discussed extensively; the UK will draft a proposal for components only. The UK proposal on remote operation for ADS requires further development. The group will review ADS GTR cyber and software provisions. RXWIN proposal documents were adapted; R155 was removed and R89 and R156 sections amended; reviewers may address concerns by 31 July 2026. Germany’s proposal requiring the same Type-Approval Authority for CSMS and vehicle type approval was discussed; a dedicated meeting will be scheduled. The UK proposal on approvals for out-of-scope vehicle types was introduced. Draft Terms of Reference were revised and will be forwarded to GRVA for September approval. The next meeting is scheduled for 3 September 2026, 12:00–15:00 CET.

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.

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.

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 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.

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.

CLEPA welcomes questions raised by Japanese experts under doc TFCS-37-06 and identifies points requiring further clarification regarding component and STU type approval scope, technical integration, STU definition, implementation, risk assessment, impact and benefit, and post-market monitoring. CLEPA proposes that components or STUs required for initial vehicle type approval under Part I should not be subject to separate approval under Part II, noting that vehicle cybersecurity depends on vehicle-level system interactions and E/E architecture, the OEM has full visibility of system architecture, and Part I approval ensures integrated assessment.

Proposal to add para. 3.2.3.1. requiring manufacturers to provide additional information on the Cyber Security Management System at request of the Approval Authority when the Certificate of Compliance for CSMS is issued by a different Approval Authority, add para. 5.1.5. allowing the Approval Authority to refuse type approval if insufficient information on the CSMS and its implementation was provided, and add para. 7.4.1.1. requiring all granting Approval Authorities to be included in reporting when different Approval Authorities are used for the Certificate of Compliance for CSMS and type approval of the vehicle type.

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.

A comprehensive cyber security risk assessment without gaps between Parts I, II, and III is required for component or separate technical unit approval. Risk assessment is difficult for manufacturers alone; contracts are required to share vulnerability information. Identification of realistic installation use cases, information sharing between approval authorities, and clarification of responsibilities are necessary. Components with no communication to the vehicle or only mechanical and power connection do not require new approval. Components sending data to the vehicle or controlling it require Part II approval and joint risk analysis by the original equipment manufacturer and installer.

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.

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.

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.

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.

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 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 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.

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.

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 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.

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.

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.

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.

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.

Questions concerning cyber security amendments for approvals of STU submitted by the expert from Japan that address timing of working document submission to GRVA, whether Part II components may include certificated base vehicle equipment under UN R155 multi-stage categorization, whether STU definition includes ECUs within base vehicle E/E architecture, examination of use cases and implementation challenges, consistency of applicant terminology between Section 3.3.1 and Section 7.6, whether approval authorities for Parts I, II, and III must be identical, clarification of end of support period requirements in para. 2.7(b), installation agreement requirements in para. 5.1.2.1(d), and whether total Cyber Security Risk Assessment Process for whole vehicle with other equipment than ESAs is necessary after ESA installation under para. 7.4.10.

Proposal to provide guidance on application of UN R155 to transformed vehicles. Transformations require new approval unless clear evidence shows original approval remains valid. Cyber-relevant modifications include addition of electrical/electronic systems, inappropriate interface connections, and wiring protection modifications. The approval authority determines whether transformation is cyber-relevant by assessing impact on original vehicle architecture, connection risks, cybersecurity management systems, and whether non-automotive equipment complies with relevant regulations. Manufacturers must provide documentary evidence including functional descriptions, connection details, software modifications, and compliance with original manufacturer instructions.

Document includes in-session edits by the workshop.

Includes changes made during the Workshop.

Proposal to amend UN R155 and UN R156 to require that Certificates of Compliance for Cyber Security Management Systems and Software Update Management Systems be issued by the same approval authority that grants type approval. Germany reported a case where different authorities issued the certificate and type approval, creating assessment and enforcement issues. The proposal aims to ensure holistic cyber security evaluation and align both regulations.

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.

Draft specific guidance for vehicle types that are based on another vehicle type. This specific guidance is without prejudice to national procedures (e.g. as defined in the R155 methods and criteria) and applies to various use cases, such as vehicles developed, produced and/or sold in collaboration with another manufacturer, completed and transformed vehicles, “multi-stage” vehicles, etc.