The Road Vehicles (Type-Approval) (Amendment) (No. 3) Regulations 2025

Made: 20th October 2025

Laid before Parliament: 22nd October 2025

Coming into force: 13th November 2025

The Secretary of State makes these Regulations in exercise of the powers conferred by Articles 5(3), 31(8), 36(4), 38(3) and 57(2) of Regulation (EU) 2018/858 of the European Parliament and of the Council of 30 May 2018 on the approval and market surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles, amending Regulations (EC) No 715/2007 and (EC) No 595/2009 and repealing Directive 2007/46/EC (“Regulation (EU) 2018/858”)[^f00001].

The Secretary of State has consulted with representative organisations in accordance with Article 82(3) of Regulation (EU) 2018/858.

Citation, commencement and extent

1

• (1) These Regulations may be cited as the Road Vehicles (Type-Approval) (Amendment) (No. 3) Regulations 2025.

• (2) These Regulations come into force on 13th November 2025.

• (3) These Regulations extend to England and Wales, Scotland and Northern Ireland.

Amendment of Regulation (EU) 2018/858

2

• (1) Regulation (EU) 2018/858 is amended as follows.

• (2) In Article 57 (UN Regulations required for GB type-approval), after paragraph (2), insert—

(3) UN Regulations and amendments made thereto which are compulsory and the dates from which they are compulsory are specified in Annex XII.

• (3) In Annex II (requirements for the purpose of GB type-approval of vehicles, systems, components or separate technical units)—

• (a) in Part I (regulatory acts for GB type-approval of vehicles produced in unlimited series)—

• (i) in the first table, after the row for item 74, insert—

• (ii) in Appendix 1 (regulatory acts for GB type-approval of vehicles produced in medium series pursuant to Article 41)—

• (aa) in Table 1 (M₁ vehicles), after the row for item 73, insert—

• (bb) in Table 2 (N₁ Vehicles), after the row for item 73, insert—

• (b) in Part III (list of regulatory acts setting out the requirements for the purposes of GB type approval of special purpose vehicles)—

• (i) in Appendix 1 (motor-caravans, ambulances and hearses), in the table, after the row for item 73, insert—

• (ii) in Appendix 2 (armoured vehicles), in the table, after the row for item 73, insert—

• (iii) in Appendix 3 (wheelchair accessible vehicles), in the table, after the row for item 73, insert—

• (iv) in Appendix 4 (other special purpose vehicles), in the table, after the row for item 73, insert—

• (v) in Appendix 5 (mobile cranes), in the table, after the row for item 73, insert—

• (vi) in Appendix 6 (exceptional load transport vehicles), after the row for item 73, insert—

• (4) In Annex IV (conformity of production procedures), after point 4.6, insert—

(5) Arrangements concerning software update The software update management system of the manufacturer as well as the whole vehicle type must comply with the requirements of UN Regulation No 156.

• (5) In Annex XII (UN regulations required for GB type-approval)—

• (a) in Table 1 (list of UN regulations referred to in Article 57 which apply on a compulsory basis), before the row for Regulation Number 157, insert—

• (b) in Table 2 (Scope of application of the requirements referred to in Article 57 - applicable categories per subject)—

• (i) before the row for systems replacing the driver’s input to controls, insert—

• (ii) in the explanatory notes, before note IF, insert—

X: Vehicles must meet the requirements.

• (c) after the explanatory notes to Table 2, insert—

Amendment of Regulation (EU) 2020/683

3

• (1) Commission Implementing Regulation (EU) 2020/683[^f00002] is amended as follows.

• (2) In Article 8—

• (a) the existing text becomes sub-paragraph “1.”;

• (b) after that sub-paragraph, insert—

(2) A certificate of conformity which is issued using the template provided for in Annex VIII as it has effect immediately before the coming into force of these Regulations, is to be treated as a GB certificate of conformity issued in accordance with Article 36(1) of Regulation (EU) 2018/858, if— (a) the vehicle to which it applies was manufactured before 1 June 2027; and (b) a valid GB type-approval granted in accordance with Regulation (EU) 2018/858 applies to the vehicle.

• (3) In Annex I, in the template for an information document for the GB type-approval of vehicles, systems, components or separate technical units, after point 12.10.3.2, insert——

12.11. [Intentionally blank] 12.12. [Intentionally blank] 12.13. [Intentionally blank] 12.14. Cyber security 12.14.1. General construction characteristics of the vehicle type, including: (a) the vehicle systems which are relevant to the cyber security of the vehicle type; (b) the components of those systems that are relevant to cyber security; (c) the interactions of those systems with other systems within the vehicle type and external interfaces ... 12.14.2. Schematic representation of the vehicle type: ... 12.14.3. The number of the Certificate of Compliance for cyber security management system: ... 12.14.4. Documents for the vehicle type to be approved describing the outcome of its risk assessment and the identified risks: ... 12.14.5. Documents for the vehicle type to be approved describing the mitigations that have been implemented on the systems listed, or to the vehicle type, and how they address the stated risks: ... 12.14.6. Documents for the vehicle type to be approved describing the protection of dedicated environments for aftermarket software, services, applications or data: ... 12.14.7. Documents for the vehicle type to be approved describing what tests have been used to verify the cyber security of the vehicle type and its systems and the outcome of those tests: ... 12.14.8. Description of the consideration of the supply chain with respect to cyber security: ... 12.15. Software update 12.15.1. General construction characteristics of the vehicle type: ... 12.15.2. The number of the Certificate of Compliance for software update management: ... 12.15.3. Security measures 12.15.3.1. Documents for the vehicle type to be approved describing that the update process will be performed securely: ... 12.15.3.2. Documents for the vehicle type to be approved describing that the update process will be performed securely: ... 12.15.4. Software updates over the air 12.15.4.1. Documents for the vehicle type to be approved describing that the update process will be performed safely: ... 12.15.4.2. Description of the means of informing vehicle users about an update before and after its execution: ... 12.15.5. Manufacturer’s declaration of compliance with the requirements for Software Update Management Systems

• (4) In Annex VIII (certificate of conformity in paper format), in the Appendix (templates for the certificate of conformity in paper format)—

• (a) in Part I (complete and completed vehicles)—

• (i) in vehicle categories M₁, M₂, M₃, N₁, N₂, and N₃, in each case, after point 52, insert—

1. Vehicle certified in accordance with UN Regulation No 155: yes/no (4)
2. Vehicle certified in accordance with UN Regulation No 156: yes/no (4)

• (ii) in vehicle categories O₁ and O₂, and O₃ and O₄, in each case, after point 52, insert—

1. In the case of a vehicle approved to UN Regulation No 155, vehicle certified in accordance with UN Regulation No 155: yes/no (4)
2. In the case of a vehicle approved to UN Regulation No 156, vehicle certified in accordance with UN Regulation No 156: yes/no (4)

• (b) in Part 2 (incomplete vehicles)—

• (i) in vehicle categories M₁, M₂, M₃, N₁, N₂, N₃, in each case, after point 52, insert—

1. Vehicle certified in accordance with UN Regulation No 155: yes/no (4)
2. Vehicle certified in accordance with UN Regulation No 156: yes/no (4)

• (ii) in vehicle categories O₁ and O₂, and O₃ and O₄, in each case, after point 52, insert—

1. In the case of a vehicle approved to UN Regulation No 155, vehicle certified in accordance with UN Regulation No 155: yes/no (4)
2. In the case of a vehicle approved to UN Regulation No 156, vehicle certified in accordance with UN Regulation No 156: yes/no (4)

Signed

Signed by authority of the Secretary of State for Transport

Simon Lightwood — Parliamentary Under Secretary of State — Department for Transport — 20th October 2025

Explanatory note

(This note is not part of the Regulations)

Explanatory Note

These Regulations amend Regulation (EU) 2018/858 and Commission Implementing Regulation (EU) 2020/683 to make compliance with two UNECE Regulations (UNECE Regulation No 155 on cyber security and cyber security management systems and UNECE Regulation No 156 on software updates and software update management systems) compulsory for vehicles applying for GB type approval.

Regulation 2 updates the list of technical requirements in Annex II of Regulation (EU) 2018/858 that must be met at type approval in the GB scheme to include UNECE Regulations No 155 and No 156, and procedures relating to conformity of production in Annex IV of that Regulation to reference arrangements concerning software updates. It also updates Annex XII of that Regulation to outline the dates on which the requirements apply.

Regulation 3 updates the information document used to make an application for type approval set out in Annex I of Commission Implementing Regulation (EU) 2020/683 to include provision on cyber security and software updates. It also updates Annex VIII of that Regulation to ensure that certificates of conformity contain references to UNECE Regulations No 155 and No 156 where appropriate.

The net costs imposed on business, the voluntary sector and the public sector by these Regulations have been assessed as being less than £10m in any year and therefore a full impact assessment has not been prepared.

The UN Regulations are issued by the United Nations Economic Commission for Europe. Copies of the UN Regulations referred to in these Regulations can be obtained from the UNECE website: http://www.unece.org/trans/main/wp29/wp29regs.html.

An Explanatory Memorandum and a de minimis assessment have been prepared and are available alongside this instrument at www.legislation.gov.uk. Hard copies may be obtained from the Department for Transport, Great Minster House, 33 Horseferry Road, London, SW1P 4DR.

Footnotes

[^f00001]: EUR 2018/858, amended by S.I. 2019/648, S.I. 2022/1273, S.I. 2024/146, S.I. 2025/661, and S.I. 2025/796.

[^f00002]: EUR 2020/683, amended by S.I. 2022/1273 and S.I. 2024/146.