The UN IWG on Cyber Security and OTA issues held its 39th session on 3 September 2026. The provisional agenda (TFCS-38-01/Rev.3) and minutes from the 38th session (TFCS-38-13) were adopted. Regarding R155 amendments: multistage vehicle proposals (GRVA/2026/28, GRVA/2026/29, TFCS-39-08) will be submitted as informal documents with a merged paragraph; component approval proposals (TFCS-39-04) had STU references removed and discussion continues; remote operation for ADS proposals were not discussed but participants are invited to consider a general refresh of Annex 5. RXWIN application proposals (TFCS-39-05, TFCS-39-06, TFCS-39-07, TFCS-39-08, TFCS-39-09, TFCS-39-10, TFCS-39-11, TFCS-39-12) were presented; items 1, 4, and 6 were agreed, item 5 was agreed in principle, and items 2 and 3 regarding R155 and R157 applicability require revised wording. Netherlands expressed concerns about vehicle discontinuation and multiple type approvals. Administrative provisions regarding Type Approval Authority for CSMS/SUMS (GRVA/2026/30, TFCS-39-02, TFCS-39-07) were discussed without consensus. Out-of-scope vehicle approvals (TFCS-38-03) discussion was deferred to a separate workshop. Two informal documents will be provided to GRVA.

Japan submitted comments on RXSWIN assignment at the 38th CS/OTA IWG. Q.1 asks whether, when a type approval is extended from UN R156-00 to UN R156-01, RXSWIN may be assigned at extension time, and if a UN Regulation refers to RE.3 Annex 7 through a supplementary amendment after UN R156-01 transitional provisions become applicable, whether RXSWIN is assigned at that time. Q.2 asks whether Approval Authorities other than the Authority granting approval are expected to have access to the OEM’s Auditable Register, as access information appears provided only to the Approval Authority concerned through paragraph 9.5.2. Q.3 asks whether software updates affecting type approval can be performed under Regulations that do not reference RE.3 Annex 7.

Proposal to amend para. 7.2.1.2.2. to delete, in cases where RXSWINs are not held on the vehicle, the requirement that the manufacturer shall declare the software version(s) of the vehicle or single ECUs with the connection to the relevant type approvals to the Approval Authority and that this declaration shall be updated each time the declared software version(s) is updated, and add that the link between the software version(s) and the RXSWINs shall be declared.

OICA, CLEPA, and CLCCR oppose the requirement in GRVA/2026/30 for a single Approval Authority to issue the Certificate of Compliance for CSMS/SUMS and vehicle type approval. They contend the approach would create multiple approvals of the same Management System, imposing administrative burden and creating unresolved legal consequences if a CoC is challenged. The organizations propose adding a new paragraph 5.1.5. instead of paragraph 5.1.3. e) to permit mutual agreement between Approval Authorities, allowing usage of a CoC issued by another Approval Authority, with such agreement documented in type approval documentation.

Proposal to amend GRVA/2026/27, which proposes amendments to UN R13, UN R13-H, UN R79, UN R89, UN R130, UN R131, UN R139, UN R140, UN R152, UN R156, UN R157, UN R171, UN R175, and UN R178:

• Throughout these regulations, amend references to the Consolidated Resolution on the Construction of Vehicles (R.E.3) as document ECE/TRANS/WP.29/78/Rev.8,
• insert new definitions for Software Identification Numbers referring to R.E.3 Annex 7 para. 2,
• amend requirements for software identification to require manufacturers provide necessary information allowing Technical Services to uniquely identify hardware and software configurations,
• insert new provisions allowing vehicle manufacturers to apply for new approvals differentiating software versions for vehicles already registered in the market from new vehicles,
• amend production discontinuation provisions to clarify production is not considered definitively discontinued if manufacturer intends to obtain subsequent extensions of approval for software updates of registered vehicles,
• insert new items in annexes regarding additional information on software identification and software updates including R_xSWIN identification, whether held on vehicle, how to read if not held on vehicle, and relevant parameters for vehicle identification.

Proposed changes to align RxSWIN provisions with the RxSWIN template adopted through WP.29-197-06, remove the proposed requirement to comply with UN R156/01 or later from R157 and R171, remove amendments to UN R155 as decided by the IWG CS/OTA, apply the RxSWIN amendments also to earlier series of amendments in R13, R13-H, R79, R131, R152, R157, and R171, update references to the latest version of R.E.3, ECE/TRANS/WP.29/78/Rev.8, in earlier series, and correct paragraph references and improve structure in R89, R139, R140, R155, R156, and R171.

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 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.

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.

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.

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.

The document clarifies two interpretation points regarding UN R156-01. First, software updates to registered vehicles require that an RXSWIN be assigned to every Regulation No. X type approval assessed during the update process, unless the manufacturer does not plan software updates for that particular system Regulation. Second, regarding para. 7.2.1.2.2., it is proposed to delete the requirement that software version changes be declared each time they are updated, since software versions are declared for each regulation subject to software updates following amendments to RE.3 Annex 7.

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.

Proposal to amend Appendix 1 to Annex 1 to revise the model of declaration of compliance for Software Update Management System Manufacturers and amend Annex 4 to revise the model of Certificate of Compliance for Software Update Management System.

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.