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CoC point R156 marked "No": can you still register the vehicle?

CoC point R156 marked "No": can you still register the vehicle?

Automotive News August 2026

We regularly get questions about the Certificate of Conformity (CoC) of new, not-yet-registered vehicles. Specifically about point R156, the Software Update Management System (SUMS).

Does it say "No" here? That doesn't mean the vehicle fails to meet type-approval requirements. And it certainly doesn't mean registration isn't possible.

What is R156?

R156 is a UNECE regulation that sets requirements for a vehicle's Software Update Management System (SUMS): the system a manufacturer uses to manage, document and secure software updates delivered remotely. Vehicles that receive updates this way must demonstrate that it happens in a controlled, secure manner. The CoC states whether a vehicle meets this requirement.

Why does it sometimes say "No"?

There are two straightforward explanations:

  • The vehicle falls outside the scope of UNECE R156.
  • The vehicle does use software updates, but they aren't covered by a homologated Software Update Management System under R156.

In short: point R156 on its own says nothing about whether you can register the vehicle.

What actually matters

Check instead whether the type-approval is valid. This information also sits on the Certificate of Conformity, and that's what determines registration, not the R156 entry.

Questions about your CoC?

Have doubts about the details on your CoC, or about registering a specific vehicle? Get in touch. We're happy to help.

Questions about your Certificate of Conformity or registering a vehicle?


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