Annex X: a major step forward for independent repair – if we get the implementation right
I regularly write here about competition in the European automotive aftermarket – and, judging by the conversations and comments those articles generate, it’s a subject many of you care about too.
I had plenty of conversations about this at Automechanika Frankfurt earlier this month. Access and repairability came up time and again, and it was good to see how engaged people are in what increasingly connected and software-defined vehicles mean for competition in our industry.
One development at the heart of that debate is the latest changes to Annex X of the EU Type Approval Regulation. Put simply, Annex X sets the rules around the access independent repairers should have to the information and systems they need to repair a vehicle.
The first of the new requirements came into effect on 23 June, with further provisions being phased in over the next two years. Together, they strengthen independent workshops’ rights to access the information and vehicle systems they need to carry out repairs.
At their heart is a simple reality: access to a modern vehicle can no longer be defined by whether a technician can plug a diagnostic tool into its OBD connector.
Diagnosing a fault, fitting a replacement component or completing a repair can now require access to the vehicle in different ways, as well as coding and part pairing, software updates or ADAS calibration.
Annex X is bringing the regulatory framework into line with that reality.
Where manufacturers give their authorised networks other ways to access a vehicle – through Ethernet, WLAN or service APIs, for example, or remotely – independent operators must be given equivalent access. There are now clearer limits on the conditions manufacturers can impose on OBD and other in-vehicle access.
Independent workshops must also be given access to a wider range of repair and maintenance information, including ADAS calibration data, guidance on software updates and information needed to repair and safely handle EV batteries.
And this is only the first stage. From December, variant coding, part pairing – including for remanufactured parts – and reprogramming will become accessible for newer vehicle types. Further requirements will follow in June 2027 and June 2028.
These are technical changes, but their impact in the workshop is significant. An independent repairer might have the right technician, diagnostic equipment and replacement component. But if that component needs to be digitally paired with the vehicle and the workshop can't access the functionality required, they still can't finish the job.
We've already seen why getting these rules right matters.
In 2023, the Court of Justice of the European Union ruled in a case brought by A.T.U. and Carglass against FCA Italy, now part of Stellantis. FCA's Secure Gateway system required independents to meet conditions including registering with the manufacturer and connecting diagnostic tools to a manufacturer-designated server.
The Court was clear: manufacturers cannot make access to repair, maintenance and OBD information subject to conditions beyond those permitted by the Type Approval Regulation. The wider competitive implication was that if additional restrictions reduce the number of independent repairers able to access that information, consumer choice is reduced too.
The latest Annex X amendments give greater clarity to a principle our industry has defended for a long time: technological progress must not become a barrier to independent repair.
But getting the rules right on paper is only part of the job.
As we have seen with SERMI, there can be a significant difference between having a right of access and being able to use it reliably in a workshop.
For me, that's where the focus needs to be now: making sure these new rights actually work in the workshop. Manufacturers need to meet the requirements consistently, independents need to be able to exercise their rights in practice, and tool providers need to develop multibrand solutions that work for thousands of independent businesses.
Where barriers emerge, our industry needs to identify them quickly and work with manufacturers and policymakers to resolve them. We’re encouraging customers to report barriers to us so we can represent their interests and take action.
There is a timely conversation to be had in Great Britain too.
The latest Annex X amendments don't automatically apply in GB, but the UK Government is now consulting on bringing the GB rules on access to repair and maintenance information into line with the latest EU changes. I believe that's the right direction.
Twenty years ago, protecting competition might have meant ensuring an independent workshop could access the right part and technical information. Increasingly, today it also means ensuring that workshop can access the vehicle's systems to configure, calibrate and update it.
Annex X is a significant step towards protecting that principle for the next generation of vehicles. Now we need to make sure it delivers for the workshops who rely on it.