Guide to application of the Machinery Regulation (EU) 2023/1230

Detailed insights into the content changes of the new Guide will probably only be possible with the publication of the first draft documents (possibly in February 2025).

In their call for participation on 26 March 2025, however, the first details were published regarding the organisational structure and the focus on which these so-called subgroups are to specialise:

Group A will, among other things, review the suitability of the current Guide to application of the Machinery Directive with regard to the essential health and safety requirements (EHSRs) amended in the MR, the topic of ‘substantial modification’, and machine-specific provisions of the New Legislative Framework.

Group B focuses on functional safety and deals with the topics of AI-powered safety functions and software as a safety component.

Group C covers the topics of autonomous mobile machines, the risk of contact with overhead power lines, and seating/restraint systems (e.g. safety belts).

Group D deals with the topic of cybersecurity, which has been newly included in the MVO. Here, too, overlaps with another EU regulation are to be expected, namely the new Cyber Resilience Act. This requirement is to be specified in technical terms within the framework of the new prEN 50742 standard.

Group E is responsible for digital operating instructions and documentation (e.g. the declaration of conformity).
 

Originally, the relevant drafts were due to be published as early as February 2026, but there will be further delays. Although the individual sub-groups already have drafts at their disposal – covering topics such as vibrations, seating and restraint systems, and digital documentation – some of these still require significant revision or need to be amended in response to criticism.

A working document is already available on the topic of “risk of contact with live overhead lines”, which is currently still under discussion. Attention will then turn to the topic of “autonomous mobile machines”.

According to the sub-group, the “final draft proposals” for the topics “AI-supported safety functions” and “software as a safety component” are expected to be available during the next meetings in June/July. At present, there is only a “base proposal” for these, which is currently being discussed due to the diverse range of viewpoints and comments.

A consolidated draft on the eagerly awaited topic of cybersecurity is expected by mid-July 2026. The drafts for Section 1.1.9 (Protection against corruption) are currently complete, whilst Section 1.2.1 (Safety and reliability of control systems) is still in progress.

The reasons cited for the delays include, amongst others, the considerable effort required for discussion and coordination within and between the groups. At the same time, the groups are aware of the urgency of the guidance and wish to deliver results swiftly.

Details on the current status can be found in the Editorial Group’s status report, which was drawn up following the Editorial Group’s meeting on 9 April 2026 and presented at the last meeting of the ‘Expert Group on Machinery’ on 27 April 2026.
 

Following publication of the Machinery Regulation in the EU Official Journal in June 2023, a revision of version 2.2 of the Guide to the MD was initiated in order to communicate changes regarding the form of the instructions at an early stage.

Therefore, version 2.3 of the Guide to Application of the Machinery Directive already includes the amended sections § 255 (Form of the operating instructions), § 261 (Inclusion of the EC declaration of conformity in the operating instructions), § 264 (Assembly, installation and connection), § 382 (The EC declaration of conformity for a machine), § 384 (The Declaration of Incorporation for partly completed machinery) and § 390 (Assembly instructions for partly completed machinery). For these sections, compliance with the provisions of the Machinery Regulation with regard to the new format of the documents also means compliance with the corresponding provisions of the Machinery Directive.

Details can be found in our article on the new version 2.3 of the Guide to Application of the Machinery Directive.
 

The future guide to the Machinery Regulation and other guides play an important role in interpreting the legal requirements of the MVO and are valuable sources of knowledge in practice – however, these accompanying documents of the EU Commission are not legally binding like EU regulations or directives!
 

As soon as a final edition of the guide is published by the EU Commission, we will provide the full-text PDF as a data set on the live server and prepare the individual contents of the guide promptly for the Safexpert Knowledge Base.

This provides Safexpert users with the advantage that the respective explanations are displayed parallel to the corresponding sections of the Machinery Directive in the StandardsManager.