Audit Log: which machines run which software version, and who approved the change

Starting on January 20, 2027, the EU Machinery Regulation will apply to any machines that you put on the market. However, the issue dates back further. When you find a defect in software that runs on machines in the field, the first thing you need to know is which machines run the affected version. For machines placed on the market from 2027, what follows is an obligation: correct the defect, withdraw or recall the machines, and tell the national authorities what went wrong and what you did about it.

For older machines, the regulation puts no such duty on the OEM, but you may want to handle them the same way. The Audit Log makes that possible.

One CI upload, two approvals, one operator confirmation on the machine, and one verified version change from 2.3.1 to 2.3.9 on RT-720 Kassel #12.

Later on, a search will show which machines run this version, and there will be a record showing who authorized it.

The two answers given so far assume that the change was transmitted via the DataPlatform; in fact, not all changes are passed in this way. For example, someone may connect a laptop to the diagnostic connector, or a dealer might decide to make a repair on their own.

The CANlink® mobile TCU can be set up to monitor the application versions on the machine and thus keep a record of any changes that take place. We can't say who made these changes; all we can state is that a version has changed, on which machine it changed, and that there is no authorization for it in the DataPlatform.

The machine notes that a change has been made to its software, whereas only the DataPlatform states that no one has authorized this change.

From January 20, 2027, the EU Machinery Regulation requires a machine to identify the safety-relevant software installed on it, to collect evidence when that software or its configuration is modified, and to keep a tracing log of interventions and versions for five years after each upload. It applies to machines you place on the market from that date, not to machines already in the field.

When it comes to new machines, the decision is made before production begins, at the same time as the ECU is selected. One possibility is to incorporate the logging facility into every ECU; in this case, each ECU would store its own versions and records of its interventions, and a technician would still be able to access them five years later. This approach involves a certain amount of work per ECU, per model, and per supplier, and yet you still have to search through the data across the whole fleet many years later. With the Audit Log, however, there is no need for any changes to the ECUs as long as the application version is visible on the CAN bus, which is the case for most ECUs.

Machines that are already in use do not have any new responsibilities placed upon them; you still want the record. The procedure for checking for defects is the same regardless of whether the machine was sold in 2021 or in 2028, and in both cases, a dealer who makes changes without being asked is the same kind of problem. You are already able to get hold of these machines.

The CANlink® mobile TCUs already report their own software and configuration versions, so there is no need to set anything up.

With regard to ECUs, you specify to the CANlink® mobile TCU which versions should be collected. This is a configuration change, not a modification of the machine: it involves no change to the ECU firmware, no additional hardware, and no involvement of the ECU supplier. It applies to all machines that are in service and have a CANlink® mobile TCU. The only requirement is that the value has to be visible on the CAN bus.

The machine's manufacturer bears this obligation, and it is tied to the machine. We supply the evidence that you use to meet this obligation.