EN   EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, XXX   
[…](2024) XXX  draft  
 
COMMISSION DELEGATED REGULATION (EU) …/...  
of XXX  
supplementing Regulation (EU) 2019/2144 of the European Parliament and of the 
Council by laying down detailed rules concerning the specific test procedures and 
technical requirements for the type -approval of heavy -duty motor vehicles with regard 
to their e vent data recorder and for the type -approval of those systems as separate 
technical units and amending Annex II to that Regulation  
(Text with EEA relevance)   EN 1  EN EXPLANATORY MEMORANDUM  
1. CONTEXT  OF THE  DELEGATED  ACT  
Regulation (EU) 2019/2144 of the European Parliament and of the Council mandates motor 
vehicles  of categories M 2, M3, N2 and N 3 to be equipped with event data recorders (EDR) from 
7th January 2026 for new vehicle types and from 7th January 2029 for all new vehicles.  
According to studies1, EDR can provide valuable accident data that can help to impr ove 
vehicle safety. The information on the status of the vehicle and its systems at the moment of a 
collision, as well as shortly before and after a collision, should enable better understanding of 
the causes and circumstances of accidents and the function ing of the vehicle’s safety systems. 
This analysis will help to improve the vehicle’s safety and reduce the number of accidents.  
After the Commission Delegated Regulation (EU) 2022/545  on EDR for light vehicles (M 1 
and N 1), the present act is a second meas ure on EDR, stipulating requirements with regard to 
the remaining vehicle categories M 2, N2, M 3 and N 3. 
2. CONSULTATIONS  PRIOR  TO THE  ADOPTION  OF THE  ACT  
In preparing this act, the Commission carried out appropriate consultations with Member 
State experts and stakeholders, with meetings to exchange views on the proposed approach on 
8 December 202 3 and 8 February  2024. The provisions of the UN Regulation No 169, 
referred to in the Annex to this act, have been prepared by a UNECE working group involving 
the EU stakeholders, including EU Member States, road safety organisations and industry 
representatives.  
3. LEGAL  ELEMENTS  OF THE  DELEGATED  ACT  
The Act establ ishes technical requirements and testing procedures for vehicle type -approval 
with regard to EDR, as well as type -approval of EDR as a separate technical unit (STU). For 
type-approval of a vehicle type, the Act refers to the provisions of a UN Regulation N o 169, 
making its requirements applicable under the General Vehicle Safety Regulation (GSR). 
These requirements concern data elements that EDR must record, the format of these data, 
requirements for data capture (including those on recording and overwritin g of data, on -board 
storing and the locking of certain data records) and requirements for crash test performance 
and survivability.  
The catalogue of data elements that EDR must record is included in Annex 4 to UN 
Regulation 169. All technical requirements  shall apply from the dates specified in the GSR.    
In addition to the requirements of UN Regulation No 169 , the Act lays down additional 
requirements concerning data retrieval, privacy and security of data.  
                                                 
1 E.g. Study on the benefits resulting from the installation of Event Data Recorders, Final Report, David 
Hynd and Mike McCarthy , 2014; 
https://ec.europa.eu/transport/site s/default/files/docs/study_edr_2014.pdf  ;  Vehicle Event Record ing 
based on Intelligent Crash  Assessment VERONICA – II, 2009, 
https://ec.europa.eu/transport/road_safety/sites/default/files/pdf/projects_sources/veronica2_final_report
.pdf ;  General Safety Regulation – Technical study to assess and develop performance requirements 
and test protocols for various measures implementing the new General Safety Regulation, for accident 
avoidance and vehicle occupant, pedestrian and cyclist protection in case of collisions – Final report, 
European Commission, Directorate -General for Internal Market, Industry, Entrepreneurship and SMEs, 
Seidl , M., Edwards, M., Hynd, D. et al ,  Publications Office,  2021,   https://op.europa.eu/en/publication -
detail/ -/publication/6987b729 -a313 -11eb -9585 -01aa75ed71a1/language -en  EN 2  EN Where there is type -approval of an EDR as an STU, the Act lays down the same technical 
requirements as those in UN Regulation No 169 for data capture, establishment of time zero 
(of an event), data overwriting, power failure and pr ohibition of deactivation. The other 
requirements in UN Regulation No 169, as well as the additional requirements in th is Act, 
shall be complied with by the vehicle type in which an EDR type -approved as an STU is 
fitted.EN 3  EN COMMISSION DELEGATED REGULATION (EU) …/...  
of XXX  
supplementing Regulation (EU) 2019/2144 of the European Parliament and of the 
Council by laying down detailed rules concerning the specific test procedures and 
technical requirements for the type -approval of heavy -duty motor vehicles with regard 
to their e vent data recorder and for the type -approval of those systems as separate 
technical units and amending Annex II to that Regulation  
(Text with EEA relevance)  
THE EUROPEAN COMMISSION,  
Having regard to the Treaty on the Functioning of the European Union,  
Havi ng regard to Regulation (EU) 2019/2144 of the European Parliament and of the Council 
of 27 November 2019 on type -approval requirements for motor vehicles and their trailers, and 
systems, components and separate technical units intended for such vehicles, a s regards their 
general safety and the protection of vehicle occupants and vulnerable road users, amending 
Regulation (EU) 2018/858 of the European Parliament and of the Council and repealing 
Regulations (EC) No 78/2009, (EC) No 79/2009 and (EC) No 661/200 9 of the European 
Parliament and of the Council and Commission Regulations (EC) No 631/2009, (EU) No 
406/2010, (EU) No 672/2010, (EU) No 1003/2010, (EU) No 1005/2010, (EU) No 1008/2010, 
(EU) No 1009/2010, (EU) No 19/2011, (EU) No 109/2011, (EU) No 458/2011 , (EU) No 
65/2012, (EU) No 130/2012, (EU) No 347/2012, (EU) No 351/2012, (EU) No 1230/2012 and 
(EU) 2015/1662, and in particular Article 4(6) and Article 6(6) thereof,  
Whereas:  
(1) Regulation (EU) 2019/2144 lays down a general obligation for motor vehicles to be 
equipped with certain advanced vehicle systems. Annex II to that Regulation  should  
list requirements for the type -approval of motor vehicles with regard to their event 
data recorder s and for the type -approval of those systems as separate technical units . It 
is necessary to supplement those require ments by establishing detailed harmonised  
rules on the specific test procedures and technical requirements for such type -
approval.  
(2) The technical requirements and test procedures set out in this Regulation concer n 
motor vehicle categories M2, M3, N2 and N 3 , in accordance with the applicable dates 
for refusal to grant EU type -approval regarding those categories of motor vehicles set 
out in Regulation (EU) 2019/2144 .  
(3) In accordance with Article 3, point (13) , of Re gulation (EU) 2019/2144, t he event data 
recorder is a system with the only purpose of recording and storing critical crash -
related parameters and information shortly before, during and immediately after a 
collision  with a view to obtain more accurate, in -depth accident data  enabling Member 
States to conduct road safety analysis and assess the effectiveness of specific 
measures.   
                                                 
2 OJ L 325, 16.12.2019, p. 1.  EN 4  EN (4) The test procedures and detailed technical requirements for type -approval of vehicle 
types with regard to event data recorders are subject to the provisions of UN 
Regulation  No 1693. That UN Regulation should therefore be added to the list of 
applicable requirements referred to in Articles 4(5) of Regulation (EU) 2019/2144 . 
(5) UN Regulation No 169 include s the requirements regarding  data elements that event 
data recorder s are to record, the format of th ose data, the requirements for data 
capture , recording  and on -board storing , as well as requirements on survivability.   
(6) In order to ensure  that vehicle manufacturers take appropriate m easures to ensure the 
protection of the event data recorder’s data against manipulation and the availability of 
the event data recorder’s  data over the standardised interface , and to enable those data 
to be anonymised,  those requirements should be supplemented with additional 
requirements  for data retrieval, privacy and security of data.  
(7) To ensure that the data recorded by the event data recorders remain anonymised, the 
manufacturers should be obliged to take appropriate  measures preventing that th ose 
data are reported or retrieved together with any information relate d to a natural person.  
(8) Until standardi sed communication protocols for access and retrieval of event data  are 
in place through  a Commission  delegated act , vehicle manufacturer s should provide 
information  to relevant parties  on how to access, retrieve and interpret the data in the 
event data recorder.  
(9) Event data recorder’s correct operational status, as well as their correct functionality 
and software integr ity, should be verified by periodic roadworthiness tests of vehicles.  
(10) The table containing the list of requirements in Annex II to Regulation (EU) 
2019/2144 does not contain any reference to regulatory acts as regards event data 
recorders  for categories M 2, M3, N2 and N 3. It is therefore necessary to introduce a 
reference to this Regulation  and UN Regulation No 169 in that Annex.   
(11) Regulation (EU) 2019/2144 should therefore be amended accordingly.  
(12) The provisions of this Regulation are closely interlinked as those provisions  set out  
rules on the technical requirements for the type -approval of motor vehicles with regard 
to their event data recorder , as well as for the type-approval of event data recorders  as 
a separate technical unit. As a result of t he rules laid down in this Regulation, it is 
necessary to add the reference to this Regulation  and UN Regulation No 169 in Annex 
II to Regulation (EU) 2019/2144. It is therefore appropriate to lay down those 
provisions in a single Delegated Regulation . 
(13) As the requirements of Regulation (EU) 2019/2144 as regards event data recorders for 
vehicles of categories M 2, M3, N2 and N 3 are to apply from 7th January  2026, this 
Regulation should apply from the same date.  
HAS ADOPTED THIS REGULATION:  
Article 1  
Scope  
This Regulation shall apply to vehicle catego ries M 2, M3, N2 and N 3, as defined in Article 4 of 
Regulation (EU) 2018/858  of the European Parliament and of the Council4. 
                                                 
3 [reference to UN Regulation No [169] published in the OJ]  
4 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 EN 5  EN Article 2  
Applicable technical requirements   
1. The event data recorder  system of a vehic le shall comply with the technical 
requirements set out in:  
(a) UN Regulation No 169; and 
(b) Article s 3, 4 and 5 of this Regulation . 
2. Type -approval of an event data recorder  as a separate technical unit shall be subject 
to the separate technical unit complying with the same requirements as those set out 
in paragraphs 5.3 (introductory paragraph), 5.3.3, 5.3.4, 5.3.5 and 5.5 of UN 
Regulation No 169.  
3. Where the motor vehicle is fit ted with an event data recorder  type-approved as a 
separate technical unit, the vehicle and its event data recorder shall comply with the  
technical  requirements  referred to in paragraph 1  of this Article . However, as regards 
paragraph 5 of UN Regulation No 169, they shall comply with the requirements set 
out in paragraphs 5.1 , 5.2, 5.3.1, 5.3.2, and 5.4  of that Regulation . 
Article 3 
Data security   
1. The crash -related  data that the event data recorder records  and stores  shall be 
protected against manipulation by compl ying with the relevant technical 
requirements and transitional provisions of UN Regulation No 1555, the original 
series or any later series of amendments  thereof .  
2. Software updates performed on the event data recorder shall be protected to 
reasonably  prevent them from being compromised and reasonably prevent invalid 
updates.  
Article 4  
Data retrieval  
1. Crash -related  data recorded  by the event data recorders  shall be made available for 
retrieval through the serial data port on the standardised data link connector referred 
to in point 2.9 of Annex X to Regulation (EU) 2018/858 . Where  the serial data port 
is no longer functional after a collision , the data shall be retrievable by a direct 
connection to the event data recorder . 
2. The vehicle manufacturer shall  provide the type -approval authority and, at the 
request  of a type -approval authority , any interested manufacturer or repairer of 
components, diagnostic tools or test equipment with information about how the event 
data can be acce ssed, retrieved and interpreted .  
3. Vehicle s and their event data recorder s shall be designed  in a way that enables a data 
retrieval tool  to produce event reports that contain the following data elements:  
(a) each of the mandatory data elements, as required under UN Regulation No 169 
                                                                                                                                                         
separate technical units intended for such vehicles, amending Regulations (EC) No 715/2007 and (EC) 
No 595/2009 and repealing Directive 2007/46/EC (OJ L 151, 14.6.2018, p. 1).  
5 UN Regula tion No 155 – Uniform provisions concerning the approval  of vehicles with regards to 
cybersecurity and cybersecurity management system [2021/387] (OJ L 82, 9.3.2021, p. 30 ). EN 6  EN (b) the precise vehicle type, variant and version (including the fitted active safety 
and accident avoidance systems) of the vehicle   hosting the event data recorder.  
The manufacturer shall demonstrate that  data referred to in the point (b) above  are 
avail able after an impact referred to in paragraph 5.4. 1 of UN Regulation No 169. 
4. The data recorded by the event data recorder shall not be available for retrieval over 
interfaces accessible without the need to unlock  the vehicle or to use  tools, or over 
vehicle interfaces for wireless connections.  
5. The event data recorder’s data made available  pursuant to paragraph 1 :  
(a) shall be available in a machine -readable format;  
(b) shall not include or be  made  available together with any information allowing 
to relate t hose data to a natural person . 
Article 5 
Provisions for roadworthiness testing  
For the purpose of periodic roadworthiness tests of vehicles, it shall be possible to verify the 
following features of the event data recorder  system:  
(1) its correct operational st atus, by visible observation of the failure warning signal 
status following the activation of the vehicle master control switch and any bulb 
check. Where the failure warning signal is displayed in a common space (the area on 
which two or more information f unctions/symbols may be displayed, but not 
simultaneously), it must be checked first that the common space is functional prior to 
the failure warning signal status check;  
(2) its correct functionality and the software integrity, by the use of an electronic veh icle 
interface, such as the one laid down in Section I, point (14), of Annex III to Directive 
2014/45/EU  of the European Parliament and of the Council6, where the technical 
characteristics of the vehicle allow for it and the necessary data is made availabl e. 
Manufacturers shall ensure to make available the technical information for the use of 
the electronic vehicle interface in accordance with Article 6 of Commission 
Implementing Regulation (EU) 2019/6217.  
Article 6 
Amendment to Regulation (EU) 2019/2144  
Annex II to Regulation (EU) 2019/2144 is amended in accordance with the Annex to this 
Regulation.  
                                                 
6 Directive 2014/45/EU of the European Parliament and of the Council of 3 April 20 14 on periodic 
roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC  (OJ L 127 
29.4.2014, p. 51 ). 
7 Commission Implementing Regulation (EU) 2019/621 of 17 April 2019 on the technical information 
necessary for roadworthiness testing of the items to be tested, on the use of the recommended test 
methods, and establishing detailed rules concerning the data format and the procedures for accessing the 
relevant technical information  (OJ L 108, 23.4.2019, p. 5 ). EN 7  EN Article 7 
Entry into force  and date of application  
This Regulation shall enter into force on the twentieth day following that of its publication in 
the Offici al Journal of the European Union . 
It shall apply from 7 January  2026. 
This Regulation shall be binding in its entirety and directly applicable in all Member States.  
Done at Brussels,  
 For the Commission  
The President   
Ursula von der Leyen