UN R116 — 01 series of amendments

In paragraphs 5.1.5., 6.1.8. and 8.1.6., the definition of “Key” now says “mechanical and/or electronic solution” in place of “device”. The words “operated only by that device” become “operated by that mechanical and/or electronic solution”. A “Primary user” is a user who is able to authorize digital keys, and there can be more than one (paragraphs 5.1.7., 6.1.13. and 8.1.11.). A “Digital key” means a key designed to be transferred to multiple devices by the primary user(s) through dedicated processes. “Close proximity” means a distance of less than 6 m (paragraphs 5.1.9. and 8.1.13.).

Paragraphs 5.2.16., 6.2.10., 7.2.7. and 8.2.11. say that, in addition, digital keys must comply with the provisions of Annex 11. Annex 11 aims to specify documentation and verification requirements for digital keys that operate the device to prevent unauthorized use and/or alarm system and/or immobilizer. For type approval, the vehicle manufacturer must provide a description of the authorization process, the revocation process and the boundary of functional operation. The manufacturer must also describe the safety measures designed within the digital key revocation process for safe operation of the vehicle. Detailed information must be in the owner's manual of the vehicle, or given by any other communication means in the vehicle. As a minimum, this information must include the method(s) for authorization and for revocation of the digital key.

Annex 11 adds definitions of “Authorization process” and “Revocation process” (paragraphs 2.1. and 2.2.). A digital key must only be transferred to a device through the authorization process (paragraph 4.1.). There must be a revocation process (paragraph 4.2.). Revocation of a digital key must not result in an unsafe condition (paragraph 4.2.1.). A risk reduction analysis documents the risk to vehicle occupants caused by revocation of a digital key and the resulting risk reduction. It must be possible for the primary user(s) to identify the number of authorized registered digital keys (paragraph 4.2.2.).

Paragraph 2.3. of Annex 11 adds a definition of “Boundary of functional operation”. Unlocking of the device to prevent unauthorized use requires that an authorized registered digital key is detected in the vehicle interior or in close proximity. Unsetting of the immobilizer requires detection of an authorized registered digital key in the vehicle interior, or an actuation by user intent in close proximity. The requirements in paragraphs 4.3.1. and 4.3.2. do not apply during remote-control manoeuvring and remote-control parking as defined in UN Regulation No. 79.

The distance limit for unsetting the immobilizer by detection in the interior is verified with a tolerance of 2000 mm around the vehicle perimeter. The vehicle is parked in a secure condition in unobstructed free field condition, with engine off and all windows, doors and roof closed. The vehicle manufacturer provides a typical user device for test in agreement with the technical service, with battery state of charge at maximum. The technical service defines four test points around the vehicle perimeter at a distance not less than 2000 mm. The user device is placed at each test point, with the vehicle door closed during each attempt to operate the vehicle under its own power. If at one of the test points the vehicle can be operated under its own power, the requirement is not met.

The effectiveness of the system must not be adversely affected by cyber-attacks, cyber threats and vulnerabilities. The effectiveness of the security measures must be demonstrated by compliance with UN Regulation No. 155. Verification of the functionality of the digital key must be conducted with support of the manufacturer's documentation as specified in paragraph 3. Only auditors/assessors with the necessary technical and administrative knowledge may conduct the assessments under Annex 11. They must in particular be competent as auditor/assessor for ISO 26262-2018 and ISO/PAS 21448. They must also be able to make the necessary link with cybersecurity aspects in accordance with UN Regulation No. 155 and ISO/SAE 21434.

From the official date of entry into force of the 01 series, Contracting Parties must not refuse to grant or accept 01 series type approvals. As from 1 September 2022, Contracting Parties applying this Regulation are not obliged to accept 00 series approvals first issued after 1 September 2022. Until 1 September 2024, they must continue to accept 00 series approvals first issued before 1 September 2022. As from 1 September 2024, they are not obliged to accept type approval issued to the preceding series of amendments (paragraph 13.3.4.). Under paragraph 13.3.5., they must continue to accept preceding-series approvals for vehicles not affected by the provisions introduced with the 01 series. Contracting Parties may grant type approvals to any preceding series and must continue to grant extensions of existing approvals to any preceding series (paragraph 13.4.).