1. Software Updates Current situation
is already addressed today by the existing type approval process, incl. its documentation
could be part of type differentiation criteria
For example, in case of braking and steering equipment it is part of the complex electronic system annex
Some software changes will require the extension of an existing system approval

2. Software Updates Example A: Change of assisted steering torques
A software update changes the assisted steering torques, dependent on the speed to improve ride-ability/comfort:
no hardware changes
minimum steering performance (e.g. overriding force, etc.) defined in the regulation and specified in the system approval are unchanged
The software change does not affect the steering type and its minimum performance, the update does not impair the type approval.

3. Software Updates Example B: “Automated Lane Change” via S/W update
Via a software update, a new vehicle receives a new „automated lane change“ feature, while having all the necessary hardware installed in the vehicle:
no hardware changes
the software change requires at least the extension of an existing approval
The software can only be updated on the new vehicle if an extension of the steering system approval is granted.
The situation for updates on already registered
vehicles is not harmonized and depends on the specific after-market regulation of the concerned country.

4. Software Updates A possible solution to be discussed
The software update could be seen as a replacement part or a retrofit system. There are already some examples, see UN Regulations :
59 (Replacement silencing systems),
90 (Replacement braking parts),
92 (Replacement silencing systems for motorcycles),
103 (Replacement pollution control devices),
114 (Airbag module for a replacement airbag system),
115 (LPG and CNG retrofit systems),
124 (Replacement wheels for passenger cars).
(see document ITS/AD for details).
The software update could be type approved as a separate technical unit for a specific vehicle type.
The Contracting Parties may make this separate technical unit mandatory in their territory if a software update is not covered by the existing vehicle type approval.
A first draft example of such a type approval of software updates as separate technical units: “TFCS-03-xx OICA Example type approval for software updates of steering systems with ACSF V0”
The prevention of malicious updating of the software has to be developed more in detail: “code signing” and “authentication” of the update.