UN Regulation No. 155 - Uniform provisions concerning the approval of vehicles with regards to cyber security and cyber security management system [2025/5]

Official Journal EN of the European Union L series 2025/5 10.1.2025 Only the original UN/ECE texts have legal effect under international public law. The status and date of entry into force of this Regulation should be checked in the latest version of the UN/ECE status document TRANS/WP.29/343, available at: https://unece.org/status- 1958-agreement-and-annexed-regulations UN Regulation No. 155 - Uniform provisions concerning the approval of vehicles with regards to cyber security and cyber security management system [2025/5]

Incorporating all valid text up to:

Supplement 3 to the original version of the Regulation – Date of entry into force: 10 January 2025 This document is meant purely as documentation tool. The authentic and legally binding texts are: — ECE/TRANS/WP.29/2020/79 (as amended by ECE/TRANS/WP.29/2020/94 and ECE/TRANS/WP.29/2020/97) — ECE/TRANS/WP.29/2022/54 — ECE/TRANS/WP.29/2023/70 and — ECE/TRANS/WP.29/2024/55 CONTENTS Regulation

1. Scope

2. Definitions

3. Application for approval

4. Markings

5. Approval

6. Certificate of Compliance for Cyber Security Management System

7. Specifications

8. Modification of vehicle type and extension of type approval

9. Conformity of production

10. Penalties for non-conformity of production

11. Production definitively discontinued

12. Names and addresses of Technical Services responsible for conducting approval test, and of Type Approval Authorities Annexes 1 Information document 2 Communication 3 Arrangement of approval mark 4 Model of Certificate of Compliance for CSMS 5 List of threats and corresponding mitigations

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1. Scope

1.1. This Regulation applies to vehicles, with regard to cyber security, of Categories L, M, N and O, if fitted with at least one electronic control unit.

1.2. This Regulation is without prejudice to other UN Regulations, regional or national legislations governing the access by authorized parties to the vehicle, its data, functions and resources, and conditions of such access. It is also without prejudice to the application of national and regional legislation on privacy and the protection of natural persons with regard to the processing of their personal data.

1.3. This Regulation is without prejudice to other UN Regulations, national or regional legislation governing the development and installation/system integration of replacement parts and components, physical and digital, with regards to cybersecurity.

2. Definitions

For the purpose of this Regulation the following definitions shall apply:

2.1. "Vehicle type" means vehicles which do not differ in at least the following essential respects:

(a) The manufacturer’s designation of the vehicle type;

(b) Essential aspects of the electric/electronic architecture and external interfaces with respect to cyber security.

2.2. "Cyber security" means the condition in which road vehicles and their functions are protected from cyber threats to electrical or electronic components.

2.3. "Cyber Security Management System (CSMS)" means a systematic risk-based approach defining organisational processes, responsibilities and governance to treat risk associated with cyber threats to vehicles and protect them from cyber-attacks.

2.4. "System" means a set of components and/or sub-systems that implements a function or functions.

2.5. "Development phase" means the period before a vehicle type is type approved.

2.6. "Production phase" refers to the duration of production of a vehicle type.

2.7. "Post-production phase" refers to the period in which a vehicle type is no longer produced until the end-of-life of all vehicles under the vehicle type. Vehicles incorporating a specific vehicle type will be operational during this phase but will no longer be produced. The phase ends when there are no longer any operational vehicles of a specific vehicle type.

2.8. "Mitigation" means a measure that is reducing risk.

2.9. "Risk" means the potential that a given threat will exploit vulnerabilities of a vehicle and thereby cause harm to the organization or to an individual.

2.10. "Risk Assessment" means the overall process of finding, recognizing and describing risks (risk identification), to comprehend the nature of risk and to determine the level of risk (risk analysis), and of comparing the results of risk analysis with risk criteria to determine whether the risk and/or its magnitude is acceptable or tolerable (risk evaluation).

2.11. "Risk Management" means coordinated activities to direct and control an organization with regard to risk.

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2.12. "Threat" means a potential cause of an unwanted incident, which may result in harm to a system, organization or individual.

2.13. "Vulnerability" means a weakness of an asset or mitigation that can be exploited by one or more threats.

3. Application for approval

3.1. The application for approval of a vehicle type with regard to cyber security shall be submitted by the vehicle manufacturer or by their duly accredited representative.

3.2. It shall be accompanied by the undermentioned documents in triplicate, and by the following particulars:

3.2.1. A description of the vehicle type with regard to the items specified in Annex 1 to this Regulation.

3.2.2. In cases where information is shown to be covered by intellectual property rights or to constitute specific know-how of the manufacturer or of their suppliers, the manufacturer or their suppliers shall make available sufficient information to enable the checks referred to in this Regulation to be made properly. Such information shall be treated on a confidential basis.

3.2.3. The Certificate of Compliance for CSMS according to paragraph 6 of this Regulation.

3.3. Documentation shall be made available in two parts:

(a) The formal documentation package for the approval, containing the material specified in Annex 1 which shall be supplied to the Approval Authority or its Technical Service at the time of submission of the type approval application. This documentation package shall be used by the Approval Authority or its Technical Service as the basic reference for the approval process. The Approval Authority or its Technical Service shall ensure that this documentation package remains available for at least 10 years counted from the time when production of the vehicle type is definitively discontinued.

(b) Additional material relevant to the requirements of this regulation may be retained by the manufacturer, but made open for inspection at the time of type approval. The manufacturer shall ensure that any material made open for inspection at the time of type approval remains available for at least a period of 10 years counted from the time when production of the vehicle type is definitively discontinued.

4. Marking

4.1. There shall be affixed, conspicuously and in a readily accessible place specified on the approval form, to every vehicle

conforming to a vehicle type approved under this Regulation an international approval mark consisting of:

4.1.1. A circle surrounding the Letter "E" followed by the distinguishing number of the country which has granted approval.

4.1.2. The number of this Regulation, followed by the letter "R", a dash and the approval number to the right of the circle described in paragraph 4.1.1. above.

4.2. If the vehicle conforms to a vehicle type approved under one or more other Regulations annexed to the Agreement in the country which has granted approval under this Regulation, the symbol prescribed in paragraph 4.1.1. above need not be repeated; in this case the Regulation and approval numbers and the additional symbols of all the Regulations under which approval has been granted in the country which has granted approval under this Regulation shall be placed in vertical columns to the right of the symbol prescribed in paragraph 4.1.1. above.

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4.3. The approval mark shall be clearly legible and shall be indelible.

4.4. The approval mark shall be placed on or close to the vehicle data plate affixed by the Manufacturer.

4.5. Annex 3 to this Regulation gives examples of the arrangements of the approval mark.

5. Approval

5.1. Approval Authorities shall grant, as appropriate, type approval with regard to cyber security, only to such vehicle types that satisfy the requirements of this Regulation.

5.1.1. The Approval Authority or the Technical Service shall verify by means of document checks that the vehicle

manufacturer has taken the necessary measures relevant for the vehicle type to:

(a) Collect and verify the information required under this Regulation through the supply chain so as to demonstrate that supplier-related risks are identified and are managed;

(b) Document risks assessment (conducted during development phase or retrospectively), test results and mitigations applied to the vehicle type, including design information supporting the risk assessment;

(c) Implement appropriate cyber security measures in the design of the vehicle type;

(d) Detect and respond to possible cyber security attacks;

(e) Log data to support the detection of cyber-attacks and provide data forensic capability to enable analysis of attempted or successful cyber-attacks.

5.1.2. The Approval Authority or the Technical Service shall verify by testing of a vehicle of the vehicle type that the vehicle manufacturer has implemented the cyber security measures they have documented. Tests shall be performed by the Approval Authority or the Technical Service itself or in collaboration with the vehicle manufacturer by sampling.

Sampling shall be focused but not limited to risks that are assessed as high during the risk assessment.

5.1.3. The Approval Authority or Technical Service shall refuse to grant the type approval with regard to cyber security where the vehicle manufacturer has not fulfilled one or more of the requirements referred to in paragraph 7.3.,

notably:

(a) The vehicle manufacturer did not perform the exhaustive risk assessment referred to in paragraph 7.3.3.; including where the manufacturer did not consider all the risks related to threats referred to in Annex 5, Part A;

(b) The vehicle manufacturer did not protect the vehicle type against risks identified in the vehicle manufacturer’s risk assessment or proportionate mitigations were not implemented as required by paragraph 7.;

(c) The vehicle manufacturer did not put in place appropriate and proportionate measures to secure dedicated environments on the vehicle type (if provided) for the storage and execution of aftermarket software, services, applications or data;

(d) The vehicle manufacturer did not perform, prior to the approval, appropriate and sufficient testing to verify the effectiveness of the security measures implemented.

5.1.4. The assessing Approval Authority shall also refuse to grant the type approval with regard to cyber security where the Approval Authority or Technical Service has not received sufficient information from the vehicle manufacturer to assess the cyber security of the vehicle type.

5.2. Notice of approval or of extension or refusal of approval of a vehicle type pursuant to this Regulation shall be communicated to the Parties to the 1958 Agreement which apply this Regulation, by means of a form conforming to the model in Annex 2 to this Regulation.

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5.3. Approval Authorities shall not grant any type approval without verifying that the manufacturer has put in place satisfactory arrangements and procedures to manage properly the cyber security aspects as covered by this Regulation.

5.3.1. The Approval Authority and its Technical Services shall ensure, in addition to the criteria laid down in Schedule 2 of the 1958 Agreement that they have:

(a) Competent personnel with appropriate cyber security skills and specific automotive risk assessments knowledge;(1)

(b) Implemented procedures for the uniform evaluation according to this Regulation.

5.3.2. Each Contracting Party applying this Regulation shall notify and inform by its Approval Authority other Approval Authorities of the Contracting Parties applying this UN Regulation about the method and criteria taken as a basis by the notifying Authority to assess the appropriateness of the measures taken in accordance with this regulation and in particular with paragraphs 5.1., 7.2. and 7.3.

This information shall be shared (a) only before granting an approval according to this Regulation for the first time and (b) each time the method or criteria for assessment is updated.

This information is intended to be shared for the purposes of collection and analysis of the best practices and in view of ensuring the convergent application of this Regulation by all Approval Authorities applying this Regulation.

5.3.3. The information referred to in paragraph 5.3.2 shall be uploaded in English language to the secure internet database "DETA",(2)established by the United Nations Economic Commission for Europe, in due time and no later than 14 days before an approval is granted for the first time under the methods and criteria of assessment concerned. The information shall be sufficient to understand what minimum performance levels the Approval Authority adopted for each specific requirement referred to in paragraph 5.3.2 as well as the processes and measures it applies to verify that these minimum performance levels are met.(3)

5.3.4. Approval Authorities receiving the information referred to in paragraph 5.3.2 may submit comments to the notifying Approval Authority by uploading them to DETA within 14 days after the day of notification.

5.3.5. If it is not possible for the granting Approval Authority to take into account the comments received in accordance with paragraph 5.3.4., the Approval Authorities having sent comments and the granting Approval Authority shall seek further clarification in accordance with Schedule 6 to the 1958 Agreement. The relevant subsidiary Working Party(4)of the World Forum for Harmonization of Vehicle Regulations (WP.29) for this Regulation shall agree on a common interpretation of methods and criteria of assessment.(5) That common interpretation shall be implemented and all Approval Authorities shall issue type approvals under this Regulation accordingly.

(1) E.g. ISO 26262-2018, ISO/PAS 21448, ISO/SAE 21434.

(2) https://www.unece.org/trans/main/wp29/datasharing.html.

(3) Guidance for the detailed information (e.g. method, criteria, performance level) to be uploaded and the format shall be given in the interpretation document which is under preparation by the Task Force on Cyber Security and Over-the-Air issues for the seventh session of GRVA.

(4) The Working Party on Automated/Autonomous and Connected Vehicles (GRVA)

(5) This interpretation shall be reflected in the interpretation document referred to in the footnote to paragraph 5.3.3.

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5.3.6. Each Approval Authority granting a type approval pursuant to this Regulation shall notify other Approval Authorities of the approval granted. The type approval together with the supplementing documentation shall be uploaded in English language by the Approval Authority within 14 days after the day of granting the approval to DETA.(6)

5.3.7. The Contracting Parties may study the approvals granted based on the information uploaded according to paragraph

5.3.6. In case of any diverging views between Contracting Parties this shall be settled in accordance with Article 10 and Schedule 6 of the 1958 Agreement. The Contracting Parties shall also inform the relevant subsidiary Working Party of the World Forum for Harmonization of Vehicle Regulations (WP.29) of the diverging interpretations within the meaning of Schedule 6 to the 1958 Agreement. The relevant Working Party shall support the settlement of the diverging views and may consult with WP.29 on this if needed

5.4. For the purpose of paragraph 7.2. of this Regulation, the manufacturer shall ensure that the cyber security aspects covered by this Regulation are implemented.

6. Certificate of Compliance for Cyber Security Management System

6.1. Contracting Parties shall appoint an Approval Authority to carry out the assessment of the manufacturer and to issue a Certificate of Compliance for CSMS.

6.2. An application for a Certificate of Compliance for Cyber Security Management System shall be submitted by the vehicle manufacturer or by their duly accredited representative.

6.3. It shall be accompanied by the undermentioned documents in triplicate, and by the following particular:

6.3.1. Documents describing the Cyber Security Management System.

6.3.2. A signed declaration using the model as defined in Appendix 1 to Annex 1.

6.4. In the context of the assessment, the manufacturer shall declare using the model as defined in Appendix 1 to Annex 1 and demonstrate to the satisfaction of the Approval Authority or its Technical Service that they have the necessary processes to comply with all the requirements for cyber security according to this Regulation.

6.5. When this assessment has been satisfactorily completed and in receipt of a signed declaration from the manufacturer according to the model as defined in Appendix 1 to Annex 1, a certificate named Certificate of Compliance for CSMS as described in Annex 4 to this Regulation (hereinafter the Certificate of Compliance for CSMS) shall be granted to the manufacturer.

6.6. The Approval Authority or its Technical Service shall use the model set out in Annex 4 to this Regulation for the Certificate of Compliance for CSMS.

6.7. The Certificate of Compliance for CSMS shall remain valid for a maximum of three years from the date of deliverance of the certificate unless it is withdrawn.

6.8. The Approval Authority which has granted the Certificate of Compliance for CSMS may at any time verify that the requirements for it continue to be met. The Approval Authority shall withdraw the Certificate of Compliance for CSMS if the requirements laid down in this Regulation are no longer met.

(6) Further information on the minimum requirements for the documentation package will be developed by GRVA during its seven session.

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6.9. The manufacturer shall inform the Approval Authority or its Technical Service of any change that will affect the relevance of the Certificate of Compliance for CSMS. After consultation with the manufacturer, the Approval Authority or its Technical Service shall decide whether new checks are necessary.

6.10. In due time, permitting the Approval Authority to complete its assessment before the end of the period of validity of the Certificate of Compliance for CSMS, the manufacturer shall apply for a new or for the extension of the existing Certificate of Compliance for CSMS. The Approval Authority shall, subject to a positive assessment, issue a new Certificate of Compliance for CSMS or extend its validity for a further period of three years. The Approval Authority shall verify that the CSMS continue to comply with the requirements of this Regulation. The Approval Authority shall issue a new certificate in cases where changes have been brought to the attention of the Approval Authority or its Technical Service and the changes have been positively re-assessed.

6.11. The expiry or withdrawal of the manufacturer’s Certificate of Compliance for CSMS shall be considered, with regard to the vehicle types to which the CSMS concerned was relevant, as modification of approval, as referred to in paragraph 8, which may include the withdrawal of the approval if the conditions for granting the approval are not met anymore.

7. Specifications

7.1. General specifications

7.1.1. The requirements of this Regulation shall not restrict provisions or requirements of other UN Regulations.

7.2. Requirements for the Cyber Security Management System

7.2.1. For the assessment the Approval Authority or its Technical Service shall verify that the vehicle manufacturer has a Cyber Security Management System in place and shall verify its compliance with this Regulation.

7.2.2. The Cyber Security Management System shall cover the following aspects:

7.2.2.1. The vehicle manufacturer shall demonstrate to an Approval Authority or Technical Service that their Cyber

Security Management System applies to the following phases:

(a) Development phase;

(b) Production phase;

(c) Post-production phase.

7.2.2.2. The vehicle manufacturer shall demonstrate that the processes used within their Cyber Security Management System ensure security is adequately considered, including risks and mitigations listed in Annex 5. This shall

include:

(a) The processes used within the manufacturer’s organization to manage cyber security;

(b) The processes used for the identification of risks to vehicle types. Within these processes, the threats in Annex 5, Part A, and other relevant threats shall be considered;

(c) The processes used for the assessment, categorization and treatment of the risks identified;

(d) The processes in place to verify that the risks identified are appropriately managed;

(e) The processes used for testing the cyber security of a vehicle type;

(f) The processes used for ensuring that the risk assessment is kept current;

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(g) The processes used to monitor for, detect and respond to cyber-attacks, cyber threats and vulnerabilities on vehicle types and the processes used to assess whether the cyber security measures implemented are still effective in the light of new cyber threats and vulnerabilities that have been identified.

(h) The processes used to provide relevant data to support analysis of attempted or successful cyber-attacks.

7.2.2.3. The vehicle manufacturer shall demonstrate that the processes used within their Cyber Security Management System will ensure that, based on categorization referred to in paragraph 7.2.2.2 (c) and 7.2.2.2 (g), cyber threats and vulnerabilities which require a response from the vehicle manufacturer shall be mitigated within a reasonable timeframe.

7.2.2.4. The vehicle manufacturer shall demonstrate that the processes used within their Cyber Security Management System will ensure that the monitoring referred to in paragraph 7.2.2.2 (g) shall be continual. This shall:

(a) Include vehicles after first registration in the monitoring;

(b) Include the capability to analyse and detect cyber threats, vulnerabilities and cyber-attacks from vehicle data and vehicle logs. This capability shall respect paragraph 1.3. and the privacy rights of car owners or drivers, particularly with respect to consent.

7.2.2.5. The vehicle manufacturer shall be required to demonstrate how their Cyber Security Management System will manage dependencies that may exist with contracted suppliers, service providers or manufacturer’s sub- organizations in regards of the requirements of paragraph 7.2.2.2.

7.3. Requirements for vehicle types

7.3.1. The manufacturer shall have a valid Certificate of Compliance for the Cyber Security Management System relevant to the vehicle type being approved. However, for type approvals of vehicles of Categories M, N and O first issued before 1 July 2024, and for type approvals of vehicles of Category L first issued before 1 July 2029, and for each extension thereof, if the vehicle manufacturer can demonstrate that the vehicle type could not be developed in compliance with the CSMS, then the vehicle manufacturer shall demonstrate that cyber security was adequately considered during the development phase of the vehicle type concerned..

7.3.2. The vehicle manufacturer shall identify and manage, for the vehicle type being approved, supplier-related risks.

7.3.3. The vehicle manufacturer shall identify the critical elements of the vehicle type and perform an exhaustive risk assessment for the vehicle type and shall treat/manage the identified risks appropriately. The risk assessment shall consider the individual elements of the vehicle type and their interactions. The risk assessment shall further consider interactions with any external systems. While assessing the risks, the vehicle manufacturer shall consider the risks related to all the threats referred to in Annex 5, Part A, as well as any other relevant risk.

7.3.4. The vehicle manufacturer shall protect the vehicle type against risks identified in the vehicle manufacturer’s risk assessment. Proportionate mitigations shall be implemented to protect the vehicle type. The mitigations implemented shall include all mitigations referred to in Annex 5, Part B and C which are relevant for the risks identified. However, if a mitigation referred to in Annex 5, Part B or C, is not relevant or not sufficient for the risk identified, the vehicle manufacturer shall ensure that another appropriate mitigation is implemented.

8/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 In particular, for type approvals of vehicles of Categories M, N and O first issued before 1 July 2024, and for type approvals of vehicles of Category L first issued before 1 July 2029, and for each extension thereof, the vehicle manufacturer shall ensure that another appropriate mitigation is implemented if a mitigation measure referred to in Annex 5, Part B or C is technically not feasible. The respective assessment of the technical feasibility shall be

provided by the manufacturer to the approval authority.

7.3.5. The vehicle manufacturer shall put in place appropriate and proportionate measures to secure dedicated environments on the vehicle type (if provided) for the storage and execution of aftermarket software, services, applications or data.

7.3.6. The vehicle manufacturer shall perform, prior to type approval, appropriate and sufficient testing to verify the effectiveness of the security measures implemented.

7.3.7. The vehicle manufacturer shall implement measures for the vehicle type to:

(a) Detect and prevent cyber-attacks against vehicles of the vehicle type;

(b) Support the monitoring capability of the vehicle manufacturer with regards to detecting threats, vulnerabilities and cyber-attacks relevant to the vehicle type;

(c) Provide data forensic capability to enable analysis of attempted or successful cyber-attacks.

7.3.8. Cryptographic modules used for the purpose of this Regulation shall be in line with consensus standards. If the cryptographic modules used are not in line with consensus standards, then the vehicle manufacturer shall justify their use.

7.4. Reporting provisions

7.4.1. The vehicle manufacturer shall report at least once a year, or more frequently if relevant, to the Approval Authority or the Technical Service the outcome of their monitoring activities, as defined in paragraph 7.2.2.2.(g)), this shall include relevant information on new cyber-attacks. The vehicle manufacturer shall also report and confirm to the Approval Authority or the Technical Service that the cyber security mitigations implemented for their vehicle types are still effective and any additional actions taken.

7.4.2. The Approval Authority or the Technical Service shall verify the provided information and, if necessary, require the vehicle manufacturer to remedy any detected ineffectiveness.

If the reporting or response is not sufficient the Approval Authority may decide to withdraw the CSMS in compliance with paragraph 6.8.

8. Modification of vehicle type and extension of type approval

8.1. Every modification of the vehicle type which affects its technical performance with respect to cybersecurity and/or documentation required in this Regulation shall be notified to the approval authority which approved the vehicle type. The Approval Authority may then either:

8.1.1. Consider that the modifications made still comply with the requirements and documentation of existing type approval; or

8.1.2. Proceed to necessary complementary assessment pursuant to paragraph 5, and require, where relevant, a further test report from the Technical Service responsible for conducting the tests.

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8.1.3. Confirmation or extension or refusal of approval, specifying the alterations, shall be communicated by means of a communication form conforming to the model in Annex 2 to this Regulation. The Approval Authority issuing the extension of approval shall assign a series number for such an extension and inform there of the other Parties to the 1958 Agreement applying this Regulation by means of a communication form conforming to the model in Annex 2 to this Regulation.

9. Conformity of production

9.1. The Conformity of Production Procedures shall comply with those set out in the 1958 Agreement, Schedule 1 (E/ ECE/TRANS/505/Rev.3) with the following requirements:

9.1.1. The holder of the approval shall ensure that results of the conformity of production tests are recorded and that the annexed documents remain available for a period determined in agreement with the Approval Authority or its Technical Service. This period shall not exceed 10 years counted from the time when production is definitively discontinued;

9.1.2. The Approval Authority which has granted type approval may at any time verify the conformity control methods applied in each production facility. The normal frequency of these verifications shall be once every three years.

10. Penalties for non-conformity of production

10.1. The approval granted in respect of a vehicle type pursuant to this Regulation may be withdrawn if the requirements laid down in this Regulation are not complied with or if sample vehicles fail to comply with the requirements of this Regulation.

10.2. If an Approval Authority withdraws an approval it has previously granted, it shall forthwith so notify the Contracting Parties applying this Regulation, by means of a communication form conforming to the model in Annex 2 to this Regulation.

11. Production definitively discontinued

11.1. If the holder of the approval completely ceases to manufacture a type of vehicle approved in accordance with this Regulation, he shall so inform the authority which granted the approval. Upon receiving the relevant communication that authority shall inform thereof the other Contracting Parties to the Agreement applying this Regulation by means of a copy of the approval form bearing at the end, in large letters, the signed and dated annotation "PRODUCTION DISCONTINUED".

12. Names and addresses of Technical Services responsible for conducting approval test, and of Type Approval Authorities

12.1. The Contracting Parties to the Agreement which apply this Regulation shall communicate to the United Nations Secretariat the names and addresses of the Technical Services responsible for conducting approval tests and of the Type Approval Authorities which grant approval and to which forms certifying approval or extension or refusal or withdrawal of approval, issued in other countries, are to be sent.

10/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 ANNEX 1 Information document The following information, if applicable, shall be supplied in triplicate and include a list of contents. Any drawings shall be supplied in appropriate scale and in sufficient detail on size A4 or on a folder of A4 format. Photographs, if any, shall show sufficient detail.

1. Make (trade name of manufacturer): ...................................................................................

2. Type and general commercial description(s): ...........................................................................

3. Means of identification of type, if marked on the vehicle: ..............................................................

4. Location of that marking: ..............................................................................................

5. Category(ies) of vehicle: ................................................................................................

6. Name and address of manufacturer/ manufacturer's representative: ...................................................

7. Name(s) and Address(es) of assembly plant(s): .........................................................................

8. Photograph(s) and/or drawing(s) of a representative vehicle: ...........................................................

9. Cyber Security

9.1. 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.

9.2. Schematic representation of the vehicle type

9.3. The number of the Certificate of Compliance for CSMS: ...............................................................

9.4. Documents for the vehicle type to be approved describing the outcome of its risk assessment and the identified

risks: ...................................................................................................................

9.5. 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: ..........................................

9.6. Documents for the vehicle type to be approved describing protection of dedicated environments for aftermarket software, services, applications or data: ................................................................................

9.7. 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: .......................................................

9.8. Description of the consideration of the supply chain with respect to cyber security: ..................................

ELI: http://data.europa.eu/eli/reg/2025/5/oj 11/30EN OJ L, 10.1.2025 Annex 1 - Appendix 1 Model of Manufacturer’s Declaration of Compliance for CSMS Manufacturer’s declaration of compliance with the requirements for the Cyber Security Management System

Manufacturer Name: ..........................................................................................................

Manufacturer Address: ........................................................................................................ ......................................................................................................... (Manufacturer Name) attests that the necessary processes to comply with the requirements for the Cyber Security Management System laid down in paragraph 7.2 of UN Regulation 155 are installed and will be maintained.

Done at: ................................................................................................................(place)

Date: ..........................................................................................................................

Name of the signatory: ........................................................................................................

Function of the signatory: ..................................................................................................... (Stamp and signature of the manufacturer’s representative) 12/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 ANNEX 2 Communication (Maximum format: A4 (210 × 297 mm))

issued by: Name of administration: .................................. .................................. .................................. ()

Concerning:(2) Approval granted Approval extended Approval withdrawn with effect from dd/mm/yyyy Approval refused Production definitively discontinued of a vehicle type, pursuant to UN Regulation No. 155 Approval No.: .................................................................................................................

Extension No.: .................................................................................................................

Reason for extension: .........................................................................................................

1. Make (trade name of manufacturer): ...................................................................................

2. Type and general commercial description(s) ...........................................................................

3. Means of identification of type, if marked on the vehicle: ..............................................................

3.1. Location of that marking: ..............................................................................................

4. Category(ies) of vehicle: ................................................................................................

5. Name and address of manufacturer / manufacturer’s representative: ..................................................

6. Name(s) and Address(es) of the production plant(s) ....................................................................

7. Number of the certificate of compliance for cyber security management system: .....................................

8. Technical Service responsible for carrying out the tests: ...............................................................

9. Date of test report: .....................................................................................................

10. Number of test report: .................................................................................................

11. Remarks: (if any). ......................................................................................................

12. Place: ...................................................................................................................

(1) Distinguishing number of the country which has granted/extended/refused/withdrawn approval (see approval provisions in the Regulation).

(2) Strike out what does not apply.

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13. Date: ...................................................................................................................

14. Signature: ..............................................................................................................

15. The index to the information package lodged with the Approval Authority, which may be obtained on request is

attached:

14/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 ANNEX 3 Arrangement of approval mark MODEL A (See paragraph 4.2 of this Regulation) a = 8 mm min.

The above approval mark affixed to a vehicle shows that the road vehicle type concerned has been approved in the Netherlands (E 4), pursuant to Regulation No.155, and under the approval number 001234. The first two digits of the approval number indicate that the approval was granted in accordance with the requirements of this Regulation in its original form (00).

ELI: http://data.europa.eu/eli/reg/2025/5/oj 15/30EN OJ L, 10.1.2025 ANNEX 4 MODEL OF CERTIFICATE OF COMPLIANCE FOR CSMS Certificate of compliance for cyber security management system With UN Regulation No. 155 Certificate Number [Reference number] [……Approval Authority] Certifies that

Manufacturer: .................................................................................................................

Address of the manufacturer: ................................................................................................. complies with the provisions of paragraph 7.2 of Regulation No. 155

Checks have been performed on: .............................................................................................. by (name and address of the Approval Authority or Technical Service): ....................................................

Number of report: ...........................................

The certificate is valid until [.......................... Date] Done at [.............................................. Place] On [................................................... Date] [................................................... Signature]

Attachments: description of the Cyber Security Management System by the manufacturer.

16/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 ANNEX 5 List of threats and corresponding mitigations

1. This annex consists of three parts. Part A of this annex describes the baseline for threats, vulnerabilities and attack methods. Part B of this annex describes mitigations to the threats which are intended for vehicle types. Part C describes mitigations to the threats which are intended for areas outside of vehicles, e.g. on IT backends.

2. Part A, Part B, and Part C shall be considered for risk assessment and mitigations to be implemented by vehicle manufacturers.

3. The high-level vulnerability and its corresponding examples have been indexed in Part A. The same indexing has been referenced in the tables in Parts B and C to link each of the attack/vulnerability with a list of corresponding mitigation measures.

4. The threat analysis shall also consider possible attack impacts. These may help ascertain the severity of a risk and identify additional risks. Possible attack impacts may include:

(a) Safe operation of vehicle affected;

(b) Vehicle functions stop working;

(c) Software modified, performance altered;

(d) Software altered but no operational effects;

(e) Data integrity breach;

(f) Data confidentiality breach;

(g) Loss of data availability;

(h) Other, including criminality.

PART A Vulnerability or attack method related to the threats High level descriptions of threats and relating vulnerability or attack method are listed in Table A1.

Table A1 List of vulnerability or attack method related to the threats High level and sub-level descriptions of vulnerability/ threat Example of vulnerability or attack method

4.3.1. Threats 1 Back-end servers used as a 1.1 Abuse of privileges by staff (insider attack) regarding means to attack a vehicle or

1.2 Unauthorized internet access to the server (enabled back-end extract data for example by backdoors, unpatched system servers software vulnerabilities, SQL attacks or other means) related to vehicles in the

1.3 Unauthorized physical access to the server field (conducted by for example USB sticks or other media connecting to the server) 2 Services from back-end server 2.1 Attack on back-end server stops it functioning, for being disrupted, affecting the example it prevents it from interacting with vehicles operation of a vehicle and providing services they rely on

ELI: http://data.europa.eu/eli/reg/2025/5/oj 17/30EN OJ L, 10.1.2025 High level and sub-level descriptions of vulnerability/ threat Example of vulnerability or attack method 3 Vehicle related data held on 3.1 Abuse of privileges by staff (insider attack) back-end servers being lost or compromised ("data breach")

3.2 Loss of information in the cloud. Sensitive data may be lost due to attacks or accidents when data is stored by third-party cloud service providers

3.3 Unauthorized internet access to the server (enabled for example by backdoors, unpatched system software vulnerabilities, SQL attacks or other means)

3.4 Unauthorized physical access to the server (conducted for example by USB sticks or other media connecting to the server)

3.5 Information breach by unintended sharing of data (e.g. admin errors)

4.3.2 Threats to 4 Spoofing of messages or data 4.1 Spoofing of messages by impersonation (e.g. V2X vehicles received by the vehicle cooperative awareness or manoeuvre coordination regarding messages, GNSS messages, etc.) their communica-

4.2 Sybil attack (in order to spoof other vehicles as if tion channels there are many vehicles on the road) 5 Communication channels 5.1 Communications channels permit code injection, for used to conduct unauthorized example tampered software binary might be injected manipulation, deletion or into the communication stream other amendments to vehicle held code/data

5.2 Communications channels permit manipulate of vehicle held data/code

5.3 Communications channels permit overwrite of vehicle held data/code

5.4 Communications channels permit erasure of vehicle held data/code

5.5 Communications channels permit introduction of data/code to the vehicle (write data code) 6 Communication channels 6.1 Accepting information from an unreliable or permit untrusted/unreliable untrusted source messages to be accepted or are vulnerable to session

6.2 Man in the middle attack/ session hijacking hijacking/replay attacks

6.3 Replay attack, for example an attack against a communication gateway allows the attacker to downgrade software of an ECU or firmware of the gateway 7 Information can be readily 7.1 Interception of information / interfering radiations / disclosed. For example, monitoring communications through eavesdropping on communications or through

7.2 Gaining unauthorized access to files or data allowing unauthorized access to sensitive files or folders 18/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 High level and sub-level descriptions of vulnerability/ threat Example of vulnerability or attack method 8 Denial of service attacks via 8.1 Sending a large number of garbage data to vehicle communication channels to information system, so that it is unable to provide disrupt vehicle functions services in the normal manner

8.2 Black hole attack, in order to disrupt communication between vehicles the attacker is able to block messages between the vehicles 9 An unprivileged user is able to 9.1 An unprivileged user is able to gain privileged access, gain privileged access to for example root access vehicle systems 10 Viruses embedded in 10.1 Virus embedded in communication media infects communication media are vehicle systems able to infect vehicle systems 11 Messages received by the 11.1 Malicious internal (e.g. CAN) messages vehicle (for example X2V or diagnostic messages), or

11.2 Malicious V2X messages, e.g. infrastructure to transmitted within it, contain vehicle or vehicle-vehicle messages (e.g. CAM, malicious content DENM)

11.3 Malicious diagnostic messages

11.4 Malicious proprietary messages (e.g. those normally sent from OEM or component/system/function supplier)

4.3.3. Threats to 12 Misuse or compromise of 12.1 Compromise of over the air software update vehicles update procedures procedures. This includes fabricating the system regarding update program or firmware their update procedures

12.2 Compromise of local/physical software update procedures. This includes fabricating the system update program or firmware

12.3 The software is manipulated before the update process (and is therefore corrupted), although the update process is intact

12.4 Compromise of cryptographic keys of the software provider to allow invalid update 13 It is possible to deny legitimate 13.1 Denial of Service attack against update server or updates network to prevent rollout of critical software updates and/or unlock of customer specific features

4.3.4. Threats to 15 Legitimate actors are able to 15.1 Innocent victim (e.g. owner, operator or vehicles take actions that would maintenance engineer) being tricked into taking an regarding unwittingly facilitate a cyber- action to unintentionally load malware or enable an unintended attack attack human actions

15.2 Defined security procedures are not followed facilitating a cyber attack

ELI: http://data.europa.eu/eli/reg/2025/5/oj 19/30EN OJ L, 10.1.2025 High level and sub-level descriptions of vulnerability/ threat Example of vulnerability or attack method

4.3.5. Threats to 16 Manipulation of the 16.1 Manipulation of functions designed to remotely vehicles connectivity of vehicle operate systems, such as remote key, immobilizer, regarding functions enables a cyber- and charging pile their external attack, this can include connectivity telematics; systems that

16.2 Manipulation of vehicle telematics (e.g. manipulate and permit remote operations; temperature measurement of sensitive goods, connections and systems using short range remotely unlock cargo doors) wireless communications

16.3 Interference with short range wireless systems or sensors 17 Hosted 3rd party software, 17.1 Corrupted applications, or those with poor software e.g. entertainment security, used as a method to attack vehicle systems applications, used as a means to attack vehicle systems 18 Devices connected to external 18.1 External interfaces such as USB or other ports used as interfaces e.g. USB ports, OBD a point of attack, for example through code injection port, used as a means to attack vehicle systems

18.2 Media infected with a virus connected to a vehicle system

18.3 Diagnostic access (e.g. dongles in OBD port) used to facilitate an attack, e.g. manipulate vehicle parameters (directly or indirectly)

4.3.6. Threats to 19 Extraction of vehicle data/ 19.1 Extraction of copyright or proprietary software from vehicle data/ code vehicle systems (product piracy) code

19.2 Unauthorized access to the owner’s privacy information such as personal identity, payment account information, address book information, location information, vehicle’s electronic ID, etc.

19.3 Extraction of cryptographic keys 20 Manipulation of vehicle data/ 20.1 Illegal/unauthorized changes to vehicle’s electronic code ID

20.2 Identity fraud. For example, if a user wants to display another identity when communicating with toll systems, manufacturer backend

20.3 Action to circumvent monitoring systems (e.g. hacking/ tampering/ blocking of messages such as ODR Tracker data, or number of runs)

20.4 Data manipulation to falsify vehicle’s driving data (e.g. mileage, driving speed, driving directions, etc.)

20.5 Unauthorized changes to system diagnostic data 21 Erasure of data/code 21.1 Unauthorized deletion/manipulation of system event logs 22 Introduction of malware 22.2 Introduce malicious software or malicious software activity 20/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 High level and sub-level descriptions of vulnerability/ threat Example of vulnerability or attack method 23 Introduction of new software 23.1 Fabrication of software of the vehicle control system or overwrite existing software or information system 24 Disruption of systems or 24.1 Denial of service, for example this may be triggered operations on the internal network by flooding a CAN bus, or by provoking faults on an ECU via a high rate of messaging 25 Manipulation of vehicle 25.1 Unauthorized access of falsify the configuration parameters parameters of vehicle’s key functions, such as brake data, airbag deployed threshold, etc.

25.2 Unauthorized access of falsify the charging parameters, such as charging voltage, charging power, battery temperature, etc.

4.3.7. Potential 26 Cryptographic technologies 26.1 Combination of short encryption keys and long vulnerabil- can be compromised or are period of validity enables attacker to break ities that insufficiently applied encryption could be exploited if

26.2 Insufficient use of cryptographic algorithms to not protect sensitive systems sufficiently protected or hardened 26.3 Using already or soon to be deprecated cryptographic algorithms 27 Parts or supplies could be 27.1 Hardware or software, engineered to enable an attack compromised to permit or fails to meet design criteria to stop an attack vehicles to be attacked 28 Software or hardware 28.1 Software bugs. The presence of software bugs can be development permits a basis for potential exploitable vulnerabilities. This vulnerabilities is particularly true if software has not been tested to verify that known bad code/bugs is not present and reduce the risk of unknown bad code/bugs being present

28.2 Using remainders from development (e.g. debug ports, JTAG ports, microprocessors, development certificates, developer passwords, …) can permit access to ECUs or permit attackers to gain higher privileges 29 Network design introduces 29.1 Superfluous internet ports left open, providing vulnerabilities access to network systems

29.2 Circumvent network separation to gain control.

Specific example is the use of unprotected gateways, or access points (such as truck-trailer gateways), to circumvent protections and gain access to other network segments to perform malicious acts, such as sending arbitrary CAN bus messages 31 Unintended transfer of data 31.1 Information breach. Personal data may be leaked can occur when the car changes user (e.g. is sold or is used as hire vehicle with new hirers)

ELI: http://data.europa.eu/eli/reg/2025/5/oj 21/30EN OJ L, 10.1.2025 High level and sub-level descriptions of vulnerability/ threat Example of vulnerability or attack method 32 Physical manipulation of 32.1 Manipulation of electronic hardware, e.g.

systems can enable an attack unauthorized electronic hardware added to a vehicle to enable "man-in-the-middle" attack Replacement of authorized electronic hardware (e.g., sensors) with unauthorized electronic hardware Manipulation of the information collected by a sensor (for example, using a magnet to tamper with the Hall effect sensor connected to the gearbox) PART B Mitigations to the threats intended for vehicles

1. Mitigations for "Vehicle communication channels" Mitigations to the threats which are related to "Vehicle communication channels" are listed in Table B1.

Table B1 Mitigation to the threats which are related to "Vehicle communication channels" Table A1 Threats to "Vehicle communication channels" Ref Mitigation reference

4.1 Spoofing of messages (e.g. V2X M10 The vehicle shall verify the authenticity and cooperative awareness or manoeuvre integrity of messages it receives coordination messages, GNSS messages, etc.) by impersonation

4.2 Sybil attack (in order to spoof other M11 Security controls shall be implemented for storing vehicles as if there are many vehicles on cryptographic keys (e.g., use of Hardware Security the road) Modules)

5.1 Communication channels permit code M10 The vehicle shall verify the authenticity and injection into vehicle held data/code, for M6 integrity of messages it receives example tampered software binary Systems shall implement security by design to might be injected into the minimize risks communication stream

5.2 Communication channels permit M7 Access control techniques and designs shall be manipulation of vehicle held data/code applied to protect system data/code

5.3 Communication channels permit overwrite of vehicle held data/code

5.4 Communication channels permit

21.1 erasure of vehicle held data/code

5.5 Communication channels permit introduction of data/code to vehicle systems (write data code) 22/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 Table A1 Threats to "Vehicle communication channels" Ref Mitigation reference

6.1 Accepting information from an M10 The vehicle shall verify the authenticity and unreliable or untrusted source integrity of messages it receives

6.2 Man in the middle attack / session M10 The vehicle shall verify the authenticity and hijacking integrity of messages it receives

6.3 Replay attack, for example an attack against a communication gateway allows the attacker to downgrade software of an ECU or firmware of the gateway

7.1 Interception of information / interfering M12 Confidential data transmitted to or from the radiations / monitoring vehicle shall be protected communications

7.2 Gaining unauthorized access to files or M8 Through system design and access control it data should not be possible for unauthorized personnel to access personal or system critical data. Example of Security Controls can be found in OWASP

8.1 Sending a large number of garbage data M13 Measures to detect and recover from a denial of to vehicle information system, so that it service attack shall be employed is unable to provide services in the normal manner

8.2 Black hole attack, disruption of M13 Measures to detect and recover from a denial of communication between vehicles by service attack shall be employed blocking the transfer of messages to other vehicles

9.1 An unprivileged user is able to gain M9 Measures to prevent and detect unauthorized privileged access, for example root access access shall be employed

10.1 Virus embedded in communication M14 Measures to protect systems against embedded media infects vehicle systems viruses/malware should be considered

11.1 Malicious internal (e.g. CAN) messages M15 Measures to detect malicious internal messages or activity should be considered

11.2 Malicious V2X messages, e.g. M10 The vehicle shall verify the authenticity and infrastructure to vehicle or vehicle- integrity of messages it receives vehicle messages (e.g. CAM, DENM)

11.3 Malicious diagnostic messages

11.4 Malicious proprietary messages (e.g. those normally sent from OEM or component/system/function supplier)

ELI: http://data.europa.eu/eli/reg/2025/5/oj 23/30EN OJ L, 10.1.2025

2. Mitigations for "Update process" Mitigations to the threats which are related to "Update process" are listed in Table B2.

Table B2 Mitigations to the threats which are related to "Update process" Table A1 Threats to "Update process" Ref Mitigation reference

12.1 Compromise of over the air software M16 Secure software update procedures shall be update procedures. This includes employed fabricating the system update program or firmware

12.2 Compromise of local/physical software update procedures. This includes fabricating the system update program or firmware

12.3 The software is manipulated before the update process (and is therefore corrupted), although the update process is intact

12.4 Compromise of cryptographic keys of the M11 Security controls shall be implemented for software provider to allow invalid update storing cryptographic keys

13.1 Denial of Service attack against update M3 Security Controls shall be applied to back-end server or network to prevent rollout of systems. Where back-end servers are critical to critical software updates and/or unlock of the provision of services there are recovery customer specific features measures in case of system outage. Example Security Controls can be found in OWASP

3. Mitigations for "Unintended human actions facilitating a cyber attack" Mitigations to the threats which are related to "Unintended human actions facilitating a cyber attack" are listed in Table B3.

Table B3 Mitigations to the threats which are related to "Unintended human actions facilitating a cyber attack" Table A1 Threats relating to "Unintended human actions" Ref Mitigation reference

15.1 Innocent victim (e.g. owner, operator or M18 Measures shall be implemented for defining and maintenance engineer) is tricked into controlling user roles and access privileges, taking an action to unintentionally load based on the principle of least access privilege malware or enable an attack 24/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 Table A1 Threats relating to "Unintended human actions" Ref Mitigation reference

15.2 Defined security procedures are not M19 Organizations shall ensure security procedures followed are defined and followed including logging of actions and access related to the management of the security functions

4. Mitigations for "External connectivity and connections" Mitigations to the threats which are related to "external connectivity and connections" are listed in Table B4.

Table B4 Mitigation to the threats which are related to "external connectivity and connections" Table A1 Threats to "External connectivity and Ref Mitigation reference connections"

16.1 Manipulation of functions designed to M20 Security controls shall be applied to systems that remotely operate vehicle systems, such as have remote access remote key, immobiliser, and charging pile

16.2 Manipulation of vehicle telematics (e.g. manipulate temperature measurement of sensitive goods, remotely unlock cargo doors)

16.3 Interference with short range wireless systems or sensors

17.1 Corrupted applications, or those with poor M21 Software shall be security assessed, software security, used as a method to authenticated and integrity protected. attack vehicle systems Security controls shall be applied to minimise the risk from third party software that is intended or foreseeable to be hosted on the vehicle

18.1 External interfaces such as USB or other M22 Security controls shall be applied to external ports used as a point of attack, for example interfaces through code injection

18.2 Media infected with viruses connected to the vehicle

18.3 Diagnostic access (e.g. dongles in OBD M22 Security controls shall be applied to external port) used to facilitate an attack, e.g. interfaces manipulate vehicle parameters (directly or indirectly)

ELI: http://data.europa.eu/eli/reg/2025/5/oj 25/30EN OJ L, 10.1.2025

5. Mitigations for "Potential targets of, or motivations for, an attack" Mitigations to the threats which are related to "Potential targets of, or motivations for, an attack" are listed in Table B5.

Table B5 Mitigations to the threats which are related to "Potential targets of, or motivations for, an attack" Table A1 Threats to "Potential targets of, or motivations Ref Mitigation reference for, an attack"

19.1 Extraction of copyright or proprietary M7 Access control techniques and designs shall be software from vehicle systems (product applied to protect system data/code. Example piracy / stolen software) Security Controls can be found in OWASP

19.2 Unauthorized access to the owner’s privacy M8 Through system design and access control it information such as personal identity, should not be possible for unauthorized payment account information, address personnel to access personal or system critical book information, location information, data. Examples of Security Controls can be vehicle’s electronic ID, etc. found in OWASP

19.3 Extraction of cryptographic keys M11 Security controls shall be implemented for storing cryptographic keys e.g. Security Modules

20.1 Illegal/unauthorised changes to vehicle’s M7 Access control techniques and designs shall be electronic ID applied to protect system data/code. Example Security Controls can be found in OWASP

20.2 Identity fraud. For example, if a user wants to display another identity when communicating with toll systems, manufacturer backend

20.3 Action to circumvent monitoring systems M7 Access control techniques and designs shall be (e.g. hacking/ tampering/ blocking of applied to protect system data/code. Example messages such as ODR Tracker data, or Security Controls can be found in OWASP.

number of runs) Data manipulation attacks on sensors or transmitted data could be mitigated by correlating the data from different sources of

20.4 Data manipulation to falsify vehicle’s information driving data (e.g. mileage, driving speed, driving directions, etc.)

20.5 Unauthorised changes to system diagnostic data

21.1 Unauthorized deletion/manipulation of M7 Access control techniques and designs shall be system event logs applied to protect system data/code. Example Security Controls can be found in OWASP.

22.2 Introduce malicious software or malicious M7 Access control techniques and designs shall be software activity applied to protect system data/code. Example Security Controls can be found in OWASP.

23.1 Fabrication of software of the vehicle control system or information system 26/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 Table A1 Threats to "Potential targets of, or motivations Ref Mitigation reference for, an attack"

24.1 Denial of service, for example this may be M13 Measures to detect and recover from a denial of triggered on the internal network by service attack shall be employed flooding a CAN bus, or by provoking faults on an ECU via a high rate of messaging

25.1 Unauthorized access to falsify M7 Access control techniques and designs shall be configuration parameters of vehicle’s key applied to protect system data/code. Example functions, such as brake data, airbag Security Controls can be found in OWASP deployed threshold, etc.

25.2 Unauthorized access to falsify charging parameters, such as charging voltage, charging power, battery temperature, etc.

6. Mitigations for "Potential vulnerabilities that could be exploited if not sufficiently protected or hardened" Mitigations to the threats which are related to "Potential vulnerabilities that could be exploited if not sufficiently protected or hardened" are listed in Table B6.

Table B6 Mitigations to the threats which are related to "Potential vulnerabilities that could be exploited if not sufficiently protected or hardened" Threats to "Potential vulnerabilities that could be Table A1 exploited if not sufficiently protected or Ref Mitigation reference hardened"

26.1 Combination of short encryption keys and M23 Cybersecurity best practices for software and long period of validity enables attacker to hardware development shall be followed break encryption

26.2 Insufficient use of cryptographic algorithms to protect sensitive systems

26.3 Using deprecated cryptographic algorithms

27.1 Hardware or software, engineered to enable M23 Cybersecurity best practices for software and an attack or fail to meet design criteria to hardware development shall be followed stop an attack

28.1 The presence of software bugs can be a basis M23 Cybersecurity best practices for software and for potential exploitable vulnerabilities. This hardware development shall be followed. is particularly true if software has not been Cybersecurity testing with adequate coverage tested to verify that known bad code/bugs is not present and reduce the risk of unknown bad code/bugs being present

ELI: http://data.europa.eu/eli/reg/2025/5/oj 27/30EN OJ L, 10.1.2025 Threats to "Potential vulnerabilities that could be Table A1 exploited if not sufficiently protected or Ref Mitigation reference hardened"

28.2 Using remainders from development (e.g. debug ports, JTAG ports, microprocessors, development certificates, developer passwords, …) can permit an attacker to access ECUs or gain higher privileges

29.1 Superfluous internet ports left open, providing access to network systems

29.2 Circumvent network separation to gain M23 Cybersecurity best practices for software and control. Specific example is the use of hardware development shall be followed. unprotected gateways, or access points Cybersecurity best practices for system design (such as truck-trailer gateways), to and system integration shall be followed circumvent protections and gain access to other network segments to perform malicious acts, such as sending arbitrary CAN bus messages

7. Mitigations for "Data loss / data breach from vehicle" Mitigations to the threats which are related to "Data loss / data breach from vehicle" are listed in Table B7.

Table B7 Mitigations to the threats which are related to "Data loss / data breach from vehicle" Table A1 Threats of "Data loss / data breach from vehicle" Ref Mitigation reference

31.1 Information breach. Personal data may be breached M24 Best practices for the protection of data when the car changes user (e.g. is sold or is used as integrity and confidentiality shall be hire vehicle with new hirers) followed for storing personal data.

8. Mitigations for "Physical manipulation of systems to enable an attack" Mitigation to the threats which are related to "Physical manipulation of systems to enable an attack" are listed in Table B8.

Table B8 Mitigations to the threats which are related to "Physical manipulation of systems to enable an attack" Table A1 Threats to "Physical manipulation of systems to Ref Mitigation reference enable an attack"

32.1 Manipulation of OEM hardware, e.g. M9 Measures to prevent and detect unauthorized unauthorised hardware added to a vehicle access shall be employed to enable "man-in-the-middle" attack 28/30 ELI: http://data.europa.eu/eli/reg/2025/5/ojEN OJ L, 10.1.2025 PART C Mitigations to the threats outside of vehicles

1. Mitigations for "Back-end servers" Mitigations to the threats which are related to "Back-end servers" are listed in Table C1.

Table C1 Mitigations to the threats which are related to "Back-end servers" Table A1 Threats to "Back-end servers" Ref Mitigation reference

1.1 & 3.1 Abuse of privileges by staff (insider M1 Security Controls are applied to back-end systems to attack) minimise the risk of insider attack

1.2 & 3.3 Unauthorised internet access to the M2 Security Controls are applied to back-end systems to server (enabled for example by minimise unauthorised access. Example Security backdoors, unpatched system Controls can be found in OWASP software vulnerabilities, SQL attacks or other means)

1.3 & 3.4 Unauthorised physical access to the M8 Through system design and access control it should server (conducted by for example USB not be possible for unauthorised personnel to access sticks or other media connecting to personal or system critical data the server)

2.1 Attack on back-end server stops it M3 Security Controls are applied to back-end systems. functioning, for example it prevents it Where back-end servers are critical to the provision of from interacting with vehicles and services there are recovery measures in case of system providing services they rely on outage. Example Security Controls can be found in OWASP

3.2 Loss of information in the cloud. M4 Security Controls are applied to minimise risks Sensitive data may be lost due to associated with cloud computing. Example Security attacks or accidents when data is Controls can be found in OWASP and NCSC cloud stored by third-party cloud service computing guidance providers

3.5 Information breach by unintended M5 Security Controls are applied to back-end systems to sharing of data (e.g. admin errors, prevent data breaches. Example Security Controls can storing data in servers in garages) be found in OWASP

2. Mitigations for "Unintended human actions" Mitigations to the threats which are related to "Unintended human actions" are listed in Table C2.

ELI: http://data.europa.eu/eli/reg/2025/5/oj 29/30EN OJ L, 10.1.2025 Table C2 Mitigations to the threats which are related to "Unintended human actions" Table A1 Threats relating to "Unintended human actions" Ref Mitigation reference

15.1 Innocent victim (e.g. owner, operator or M18 Measures shall be implemented for defining and maintenance engineer) is tricked into controlling user roles and access privileges, taking an action to unintentionally load based on the principle of least access privilege malware or enable an attack

15.2 Defined security procedures are not M19 Organizations shall ensure security procedures followed are defined and followed including logging of actions and access related to the management of the security functions

3. Mitigations for "Physical loss of data" Mitigations to the threats which are related to "Physical loss of data" are listed in Table C3.

Table C3 Mitigations to the threats which are related to "Physical loss of data loss" Table A1 Threats of "Physical loss of data" Ref Mitigation reference

30.1 Damage caused by a third party. Sensitive data may M24 Best practices for the protection of data be lost or compromised due to physical damages in integrity and confidentiality shall be cases of traffic accident or theft followed for storing personal data.

Example Security Controls can be found

30.2 Loss from DRM (digital right management) in ISO/SC27/WG5 conflicts. User data may be deleted due to DRM issues

30.3 The (integrity of) sensitive data may be lost due to IT components wear and tear, causing potential cascading issues (in case of key alteration, for example) 30/30 ELI: http://data.europa.eu/eli/reg/2025/5/oj