Cybersecurity must not become a barrier

UN-R155 jeopardizes individual mobility for people with disabilities puts inclusive mobility at risk 

Paravan GmbH is warning of the unintended consequences of international vehicle regulations. Barrier-free, individual vehicle conversions are at risk of failing due to new, practically unfeasible cybersecurity requirements under UN R155. The association Mobil mit Behinderung (Mobile with Disabilities) also sees an urgent need for political action.

The new UN Regulation R155 on cybersecurity in motor vehicles aims to protect modern vehicles from digital attacks. However, it inadvertently restricts people with disabilities. Access to safety-related vehicle systems is blocked, making individual adjustments to the control of secondary functions such as turn signals, lights, or gear shifting significantly more difficult or even impossible.

Paravan GmbH, a pioneer in accessible vehicle solutions and developer of the innovative Space Drive drive-by-wire system, is sounding the alarm: Technical protection mechanisms must not lead to social exclusion. "While intended to enhance safety, in practice, it creates digital barriers to inclusion," warns Roland Arnold, Paravan GmbH's managing director. "If necessary modifications to modern vehicles are no longer possible, it may be technically understandable, but socially unacceptable."

UN R155: A protection regulation with unintended consequences.

The regulation stipulates that modifications to type-approved vehicles are permitted only if they are compatible with the manufacturer's cybersecurity management system. This applies to key functions, such as gear shifting, turn signals, and lighting, and thus to adaptations for people with physical disabilities as well.

"People with disabilities must not become collateral damage of safety regulations," emphasizes Heinrich Buschmann, founder of Mobil mit Behinderung e.V. (Mobile with Disabilities). "Mobility is participation, and by acceding to the UN Convention on the Rights of Persons with Disabilities in 2009, Germany committed itself to ensuring the greatest possible independence."

Case Study: When High Tech Becomes an Obstacle

Klaus, a 62-year-old entrepreneur and former music producer, has been in a wheelchair since he was 18. For over ten years, he has controlled his vehicles with a four-way joystick and has driven around 270,000 kilometers without an accident. For him, individual mobility is not an option but a basic requirement for his career and business.

His current vehicle is a new Mercedes S-Class with autonomous driving functions (Level 3). However, the road back to the road was long. The sedan sat in the Paravan Mobility Park in Aichelau for over half a year before the conversion could begin. The reason was that many secondary vehicle functions, such as turn signals, lights, and gear selection, could no longer be controlled by the software.

Instead of digital integration, precision mechanical motors were installed to trigger the functions via a special linkage because access via the vehicle software was no longer possible. "It was only through mobility that I was able to achieve what I have," says Klaus. "But this conversion was a huge effort. I hope that technology empowers rather than excludes.”

Klaus's case is not an isolated one. Similar challenges will arise next year with so-called volume models, such as the Mercedes CLA and V-Class, both of which will be equipped with Level 3 functionality. This means that: UN R155 and R156 are binding for all manufacturers when vehicles are type-approved within the UNECE zone, which applies to nearly all brands operating in Europe.

Mercedes is not a special case but a pioneer in consistently rolling out these highly automated vehicle architectures. Other manufacturers, such as VW, BMW, Stellantis, Hyundai, and Audi, will follow suit. In the medium term, all OEMs will be affected as soon as they launch vehicles that comply with UN R155 and offer assistance or automation packages. What appears to be an isolated case today will become a structural inclusion problem in a few years.

What needs to be done now to ensure accessibility?

To continue enabling barrier-free mobility and ensuring individual vehicle adaptations for people with disabilities, Paravan GmbH has deemed the following measures necessary:

1. A legally defined framework for exemptions or special approvals for disability-friendly conversions within the scope of UN R155.
2. Mandatory technical interfaces that enable certified conversion companies to access relevant vehicle systems while considering IT security.
3. Involve inclusion experts and specialized providers in the further development of technical regulations, such as UN R155 and UN R156.
4. Fourth, targeted political support for the development of accessible, safety-compliant technologies. Targeted political support for developing accessible, safety-compliant technologies.

New technologies can be a blessing or a curse for people with disabilities. If designed inclusively, they provide greater comfort, support, and above all, safety on the roads. However, if they become a barrier, they can hinder social participation. The transition to autonomous driving and electric mobility shows that technical innovation does not automatically lead to social innovation. Access to modern mobility must not be hindered by technological interfaces.

"Accessibility is not a luxury — it's a fundamental right," emphasizes Roland Arnold. "We don't need special arrangements, but rather clear framework conditions that combine safety and inclusion."