Regulatory Changes

New technical standards for train certification in Spain: 2028 and 2030 deadlines for manufacturers

E
Equipo Editorial CambiosLegales
Sep 10, 2026 6 min 16 views

Key data

RegulationResolution of August 27, 2026, from the State Railway Safety Agency (AESF)
Affected instructionIF MR ALC-20 — Technical specifications for railway rolling stock for the entry into service of self-propelled units, locomotives and coaches
BOE publicationSeptember 10, 2026
Entry into forceSeptember 11, 2026
Replaced standardET 03.365.008.6
New reference standardETC ASFA FET Version 1 (approved by Resolution 5/2026)
Mandatory deadline (new design and metric vehicles in production)January 1, 2028
Mandatory deadline (conventional and dual vehicles in production)January 1, 2030
Affected partiesRolling stock manufacturers, certification bodies and railway operators
CategoryRegulatory Changes
Impact analysis reserved for subscribers
The detailed impact analysis of this regulation is available with the PRO and Business plans. Access the full content and receive personalized alerts.
From €9.99/month · Cancel anytime

If you manufacture, certify or operate railway rolling stock in Spain, this resolution changes the technical references you must comply with to obtain authorization for entry into service. The Resolution of August 27, 2026 from AESF, published in the BOE on September 10, 2026 and in force from the following day, updates Annex C of the IF MR ALC-20 instruction with new mandatory regulatory references and a differentiated transitional regime depending on the vehicle's status.

The change is significant: it affects onboard movement control systems (CMS class B), interfaces between class A and class B systems, and legal recorders. These are critical safety elements that condition the entire certification process.

What does this regulation establish?

The resolution updates the Annex C of the IF MR ALC-20 instruction, replacing in five normative indices the reference to the old technical specification ET 03.365.008.6 with the new Technical Circulation Specification ETC ASFA FET Version 1, approved by Resolution 5/2026.

The five affected indices correspond to the following technical areas:

  • Onboard CMS class B systems
  • Interfaces between class A and class B systems
  • Legal recorders

The following table summarizes the transitional regime established, which is the most relevant element for operational planning:

Vehicle typeSituationCompliance deadline
Any typeDesign phase initiated after entry into force (11/09/2026)January 1, 2028
Metric vehiclesIn production at the time of entry into forceJanuary 1, 2028
Conventional vehiclesIn production at the time of entry into forceJanuary 1, 2030
Dual vehiclesIn production at the time of entry into forceJanuary 1, 2030
Vehicles in operationAlready in commercial serviceExempt — does not apply

During the transitional period, evaluation bodies may apply either the previous framework (ET 03.365.008.6) or the new one (ETC ASFA FET Version 1) indistinctly. This flexibility is relevant for ongoing projects that have already initiated their certification process.

Economic and operational impact

The direct economic impact of this resolution does not come from sanctions or fees: it comes from the cost of redesign and recertification if ongoing processes do not adapt in time to the new ETC ASFA FET Version 1.

The main vectors of operational impact are:

  • New design projects: any vehicle whose design phase begins after September 11, 2026 must incorporate the new technical specification from the start. Designing on the old standard would mean having to redesign CMS class B systems, class A/B interfaces and legal recorders before January 2028.
  • Metric vehicles in production: the adaptation deadline is the same as for new designs (January 1, 2028), leaving less margin than for conventional and dual vehicles.
  • Conventional and dual vehicles in production: have a longer deadline until January 1, 2030, but must plan the transition with sufficient advance notice to avoid compromising delivery schedules.
  • Certification bodies: must update their evaluation procedures to handle both standards during the transitional period and be prepared to apply exclusively the new one from the corresponding deadline dates.

Who does it affect?

  • Railway rolling stock manufacturers (self-propelled units, locomotives and coaches) that operate or supply to the Spanish railway network.
  • Conformity assessment bodies (notified and designated bodies) that certify rolling stock for the Spanish network.
  • Railway operators that have ongoing processes for incorporating new rolling stock or that manage supply contracts with manufacturers.
  • Engineering and homologation departments of companies in the sector that work with CMS class B systems, class A/B interfaces or legal recorders.

Practical example

A manufacturer that in October 2026 initiates the design of a new metric self-propelled unit for a Spanish commuter line must incorporate from day one the ETC ASFA FET Version 1 as the technical reference for CMS class B systems and legal recorders. If its engineering team works with documents from the old ET 03.365.008.6 out of habit, the evaluation body may reject the technical documentation from January 1, 2028, blocking the authorization for entry into service.

In contrast, that same manufacturer has in parallel a conventional locomotive in production since July 2026. For that vehicle, it can continue applying ET 03.365.008.6 during the transitional period and has until January 1, 2030 to complete the transition to the new standard, giving it room to plan the adaptation without altering the current production schedule.

Do you need to track this and other regulations?

Consult the full details in CambiosLegales

What should companies do now?

  1. Audit the status of each project in portfolio: classify each vehicle into one of the three categories (new design, in production, in operation) to determine which deadline applies and if there is an exemption.
  2. Update technical design documentation: for all projects initiated after September 11, 2026, replace references to ET 03.365.008.6 with ETC ASFA FET Version 1 in the five normative indices of Annex C of the IF MR ALC-20.
  3. Coordinate with the evaluation body: confirm which regulatory framework will apply during the transitional period for ongoing projects, as the resolution allows applying either standard indistinctly until the deadline dates.
  4. Plan the transition for conventional and dual vehicles in production: although the deadline is 2030, initiate the technical review in advance to avoid compromising delivery schedules or creating bottlenecks in the certification phase.
  5. Verify the exemption for vehicles in operation: formally confirm with the evaluation body that vehicles already in commercial service are outside the scope of this update and document it in the technical file.

Frequently asked questions

When is the new ETC ASFA FET Version 1 mandatory for trains in design?

For vehicles whose design phase begins on or after September 11, 2026 (the date the resolution enters into force), ETC ASFA FET Version 1 is mandatory from January 1, 2028. The same deadline applies to metric vehicles that were already in production on that date.

What deadline do manufacturers of conventional trains in production have to adapt?

Conventional and dual vehicles that were already in production when the resolution entered into force (September 11, 2026) have until January 1, 2030 to comply with the new ETC ASFA FET Version 1. During the transitional period they can continue applying the old ET 03.365.008.6.

Do trains already in service have to comply with the new standard?

No. Vehicles that are already in operation at the time the resolution enters into force are completely exempt from this regulatory update. The new ETC ASFA FET Version 1 only applies to vehicles in design or production phase.

What specific technical systems change with this update?

The update affects five normative indices of Annex C of the IF MR ALC-20 instruction, relating to: onboard CMS class B systems, interfaces between class A and class B systems, and legal recorders. In all of them, the reference to ET 03.365.008.6 is replaced with the new ETC ASFA FET Version 1 (approved by Resolution 5/2026).

Can certification bodies continue using the old standard during the transition?

Yes. During the transitional period, evaluation bodies may apply either the previous framework (ET 03.365.008.6) or the new one (ETC ASFA FET Version 1) indistinctly. This flexibility is maintained until the deadline dates: January 1, 2028 for new designs and metric vehicles in production, and January 1, 2030 for conventional and dual vehicles in production.

Official source

Consult complete regulation in official source

Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-18972



Share:
E
Equipo Editorial CambiosLegales

El equipo editorial de CambiosLegales analiza diariamente los cambios normativos que afectan a empresas y autónomos en España, ofreciendo análisis pro...

Comments

No comments yet. Be the first to comment!

Leave a comment
Activate alerts