Cybersecurity is treated as a safety control with exact logging and evidence duties.
Focus: control system integrity, intervention logs, software identification, and technical file artifacts.
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Cited legal and guidance references.
The Regulation explicitly addresses safety risks stemming from malicious third-party actions that can impact the safety of machinery. It does not replace cybersecurity-specific EU acts, but it does impose safety-oriented control-system integrity requirements. Practically: you need engineering controls (integrity, access, logging), documentation artifacts, and a clear strategy for how software updates and autonomy affect safety over the lifecycle.
The Regulation is not a general cybersecurity law. Its software obligations are safety-scoped: prevent corruption or manipulation that would break compliance with essential health and safety requirements.
The right output is a safety-software inventory tied to hazards, controls, and evidence.
Annex III requires protection of hardware components that transmit signals or data relevant to software critical for compliance, and protection of the software and data themselves.
The Regulation also requires the machinery or related product to identify installed software necessary for safe operation in an easily accessible form.
Logging only helps if teams know exactly what must be kept and for how long. Annex III gives precise retention periods for two important software-evidence categories.
These logs exist to demonstrate conformity further to a reasoned request from a competent authority, so design them for integrity and export.
Risk assessment must cover hazards that arise from intended evolution of behaviour and varying levels of autonomy, including foreseen updates.
The change process should tell you when an update is still within the original safety case and when it risks substantial modification or route reassessment.
Relevant EU cybersecurity certification schemes may support presumption of conformity for the Annex III requirements they actually cover. They do not replace the machinery safety case.
Treat scheme outputs as supporting evidence with defined boundaries.
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