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Autonomous mobile machinery: what the Machinery Regulation requires

Driverless transport systems, autonomous mowers, mobile robots: the Regulation covers them expressly for the first time. The requirements are in chapter 3 of Annex III – here is the overview.

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In brief

  • Autonomous mobile machinery is mobile machinery with an autonomous mode in which all essential safety functions are ensured without permanent interaction with operators (Annex III 3.1.1).
  • The control system must perform the safety functions autonomously; remote supervision may only stop, start or bring the machine into a safe state.
  • Depending on the risk assessment: enclosed area with a protective system, or detection of persons and obstacles.
  • Autonomous does not automatically mean Annex I – only if a learning system ensures safety functions.
Annex III 3.1.13.2.43.33.3.33.6.3

The requirements at a glance

TopicRequirementAnnex III
ConceptMobile machinery with an autonomous mode in which all essential safety functions are ensured in its travel and working area without permanent interaction with operators3.1.1(c)
Supervisory functionWhere appropriate, remote supervision by a supervisor; only stopping, starting or bringing into a safe position and state; machine not operable without active supervision3.2.4
Control systemPerforms the safety functions autonomously, even where functions are commanded via remote supervision3.3
TravelRisks related to the area in which it travels and works must be taken into account3.3.2
Protection conceptDepending on the risk assessment: enclosed area with a perimeter protective system and/or detection of persons, domestic animals and obstacles3.3.3
TrailersMovements with trailers or towed equipment must not create risks in the danger zone3.3.3
SteeringFailure of the steering system must not affect safety3.3.5
ChargingNo contact or collision risks when travelling autonomously to the charging station3.5.1
InstructionsCharacteristics of the intended travel, working and danger zones3.6.3

Chapter 3 applies in addition to chapter 1 to all machinery presenting hazards due to mobility. Which solution is sufficient in a given case – protected area, sensors, speed – follows from the risk assessment and is a task for specialists.

What else applies

  • Chapter 1 still applies: control systems, human-machine interaction (1.1.6(f), (g)), coexistence in a shared space (1.3.7) and protection against corruption (1.1.9).
  • Learning behaviour: where the logic evolves by itself, the additional requirements for control systems (1.2.1) and possibly Annex I Part A point 6 apply.
  • Connectivity: if the machine is also a product with digital elements, the Cyber Resilience Act applies too.

Frequently asked questions

Is a driverless transport system autonomous mobile machinery?

If it operates in an autonomous mode with all essential safety functions ensured without permanent interaction with operators, yes (3.1.1(c)). The classification must be justified in the risk assessment.

Do I need a notified body?

Not because of autonomy alone. A notified body is needed if the machine falls under Annex I – for example with embedded learning systems ensuring safety functions.

Must there be a supervisor?

The supervisory function is required “where appropriate” (3.2.4). If provided, the machine must not be operable without the supervisory function active.

Document autonomous machinery properly

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Read next

Sources. Regulation (EU) 2023/1230, OJ L 165, 29.6.2023, including the corrigendum of 1.4.2025; Directive 2006/42/EC for the previous regime.

The information has been checked against the official text, paraphrased and shortened; only the official text is authentic.

normakte is a drafting and calculation aid; it replaces neither conformity assessment, nor a notified body, nor a technical assessment by a specialist, nor legal advice.

Further reading: other topics of the Machinery Regulation