DSSAD data, whether stored on or off the vehicle, shall be readily available and retrievable through an electronic communication interface that complies with a publicly available standard, with internationally recognized standards recommended to promote interoperability. Data elements concerning activation and deactivation of the feature shall be available via the vehicle’s information display or user interface where controls related to manual performance of the DDT are provided, with access to timestamps subject to restrictions ensuring compliance with data protection requirements.

Proposal to amend para. 8.1.5.1.(d) to replace “a key” with “an”, delete “effective”, and insert “processes” before “of the SMS”. The proposal streamlines guidance text on SMS safety policy to improve clarity in describing how safety policy demonstrates management commitment to safety through approval by the accountable executive and supports promotion of safety and continuous improvement of the SMS.

Proposal to modify the safety risk management definition by replacing “the core” with “an”, changing “that supports” to “described in”, deleting “and the intended results of the Organization, as well as the effectiveness of other organizational processes”, capitalizing “Organization” to “organization”, and removing the comma after “Organization”. The term safety risk management restricts itself to the management of safety risks without consideration of factors such as financial, legal, economic, or reputational risks.

Proposal to amend para. 8.1.7.1.(f) to replace “ensures” with “focuses on” in the element text describing performance monitoring practices to track safety outcomes over time.

Proposal to delete “This clarifies that corrective” and replace with “Corrective”, and delete “/systemic” in para. 8.1.7.1.(e). The revised text states: Corrective actions may address both technical aspects (ADS) and organizational aspects (SMS).

Proposal to modify para. 8.1.7.1.(h) to replace “aims to ensure that” with “focuses on”, replace “Assessment of how organizations coordinate” with “Assessment that organizations coordinate”, delete “and product reviews” from the list of change management triggers, and delete “the approach and output from various” before “monitoring procedures” and delete “including operational data, safety reports and performance indicator” from the examples of monitoring procedures.

Proposal to delete and amend the draft guidance on para. 8.1.7.1. to replace “The intention of this requirement is to ensure that organizations have robust mechanisms to verify, monitor, and continuously improve safety performance. The regulatory text emphasizes” with “The Regulation implies,” delete “evidence-based” from the description of safety assurance as a continuous process, replace “aimed at ensuring that” with “to monitor the effectiveness of,” delete “remain effective” after “safety measures,” replace “whether” with “insofar that” and delete “risk control measures remain effective and whether” in the definition of safety assurance, delete “systematic” before “processes,” replace “that” with “on” after “confidence,” delete “and” before “products,” replace “established” with deletion, replace “employee reporting” with “internal feedback,” add “to maintain the demonstrated performance” after “safety improvements,” add “of KPI for the organization” in the evaluation clause, and replace “improvement of” with deletion and restructure the final clause to read “of the products.”

Proposal to revise para. 8.1.7.1.(g) to delete “Monitoring is expected to cover both the ADS and the SMS, ensuring a comprehensive view of safety performance.” and insert “Monitoring practices include the monitoring of the ADS product (i.e., using SPIs) and evaluation of the Safety Management System so that it remains effective (i.e., using KPIs).”

Proposal to delete “The intention is to ensure that”, delete “organizations have”, insert “This element focuses on”, insert “the”, and insert “organization’s” in para. 8.1.7.1.(d) to improve and streamline the text, changing “The intention is to ensure that organizations have processes to identify, implement, and track corrective actions to maintain safety at an acceptable level” to “This element focuses on the organization’s processes to identify, implement, and track corrective actions to maintain safety at an acceptable level.”

Proposal to delete "This provision ensures that " and insert “This element focuses on” before “changes”, delete “systematically”, and insert "that " after “changes” in para. 8.1.7.1.© to improve and streamline the text so that the description reads “This element focuses on changes that are assessed and managed, recognizing that modifications can introduce new risks.”

Proposal to delete “The requirement highlights that safety assurance is expected to extend beyond the organization to include” from para. 8.1.7.1.(b), insert “Safety assurance covers the organization and also” in its place, and delete “, reflecting a system-of-systems perspective” from the same para. Document ADS-21-42.

Proposal to modify the interpretation text for para. 8.1.7.1.(a) to replace “ensures” with “focuses on” in the statement describing the element for periodic independent internal audits and external audits.

Proposal for guidance on operational states, including remote termination and a diagram illustrating ADS and feature operational states, update guidance on terms “on”, “off”, “available,” “active,” “unavailable,” and “disabled” as canonical operational state terms for ADS descriptions and clarify that “active” applies only to features.

Proposal for explanation that where confirmatory testing reveals apparent non-conformities, the assessor provides results to the manufacturer for review as foreseen by 6/8.3.3.1.2, the manufacturer conducts the same tests, and where results are consistent with the assessor’s, the manufacturer develops remedies and provides evidence to the assessor, or where manufacturer test results differ, the two parties discuss discrepancies and agree on next steps.

Proposal to amend the guidance on reporting safety-relevant communication issues by deleting “Such an occurrence could be reported in case of” and replacing it with “Examples of communication issues could include”, deleting “The remote interaction is unavailable” and replacing it with “Interruption of remote interaction,”, replacing “Information” with “Communication”, adding “the” before “safety threshold”, and adding “(if indicated in the safety case)” after “safety threshold”, and replacing the period after “unavailable” with “, or”.

Proposal for guidance on reporting average feature engagement time in para. 4. The average engagement time is a statistical measure of how long an ADS feature stays engaged per activation (e.g., cumulative time / number of activations). The average is expected to be computed in an aggregated manner, i.e., over the whole fleet of vehicles having the same ADS feature.

This document proposes guidance on reporting cyber security issues affecting autonomous driving systems safety. The proposal modifies the description of reportable cyber security incidents to replace “Safety-relevant ECU compromised” with “Any cybersecurity threat identified to safety relevant ECU, or” and deletes “ADS control channel manipulated.” The text also clarifies that reporting must align with UN R155 where this Regulation is applied, replacing the reference to “CSMS procedure where R155 is applied.”

Proposal to clarify guidance on reporting maintenance and repair issues by deleting “Such an occurrence is expected to be reported in case of” and inserting “Examples of maintenance or repair issues could include”, adding “safety-critical” before “software”, adding “potential” before “safety”, deleting “implications” and inserting “consequences, or”, deleting “Fitted hardware not compliant to safety performance specifications” and inserting “Not following the repair instructions given by the manufacturer.”

Proposal to clarify guidance on reporting unauthorized modifications to the ADS by deleting “Such an occurrence is expected to be reported in case of” and replacing it with “Examples of unauthorised modifications to the ADS could include”, deleting “Sensor tampering; obstruction;” and inserting language to specify that ADS-relevant software or hardware tampering, or third-party hardware interfering with ADS, could constitute unauthorized modifications affecting intended functionality.

Proposal to clarify reporting of vehicle approval numbers by inserting “(if applicable)” after “national or supra-national regulatory frameworks” in the vehicle approval number section of GTR Annex 2/UNR Annex 4. The insertion indicates that the vehicle approval number does not apply in all jurisdictions.