Regulation

Thirty-nine assessors. Three of them are notified for machine learning.

4 min readMati Melchior
Thirty-nine assessors. Three of them are notified for machine learning.

Thirty-nine notified bodies hold a current notification under Regulation (EU) 2023/1230. That is a reading taken on 13 September 2026 from the European Commission's public register of notified bodies. It is a count for that date, not a standing fact, and the Regulation applies from 20 January 2027.

A count is worth only as much as the method behind it. I queried the Commission's notified-body database directly on 13 September 2026 — once for the Regulation, once for the outgoing Directive 2006/42/EC, then category by category through Annex I. The Regulation returned 49 notification records. Those reduce to 39 latest-version records held by 39 distinct bodies, none past its end date. Where a body had announced its own designation, I checked the announcement against the register.

The reason the count matters sits in Annex I. Part A lists six categories of machinery and safety components, and Article 25(2) routes every one of them to module B plus C, to module H, or to module G. There will be no self-assessment route for Part A. Part B, with its nineteen categories, will allow module A where harmonised standards have been applied in full.

Four things follow from the register.

The outgoing regime has nearly four times the assessor base of the incoming one. Directive 2006/42/EC, read the same day, shows 144 notified bodies under a current notification. That comes from 1,428 records, reducing to 298 latest-version records and 144 distinct bodies not past their end dates. A stricter filter on notification status returns 143; the figure here uses the status-agnostic filter. An assessor base assembled over roughly two decades will stop applying on 20 January 2027, and what replaces it has been built since 2024.

Three of the 39 are notified for safety components whose behaviour is fully or partly self-evolving through machine learning. They are DTI Dancert in Denmark, notified on 1 December 2025; Intercert Global in Poland, notified on 5 August 2026; and TUV Cyprus, notified on 2 September 2026. For the neighbouring category, machinery with embedded self-evolving machine-learning safety systems, the number is two: DTI Dancert and TUV Cyprus. Those are the counts for the whole Union. I examined all 39 records to reach them.

Twenty of the 39 are notified for vehicle servicing lifts. The three remaining Part A categories carry four bodies, five bodies and three bodies. I also counted where the 39 sit: eighteen are German, and Germany and Austria together account for twenty-two. On this reading, the categories written for machine learning are the thinnest-staffed part of the mandatory half of Annex I.

A body's own designation announcement can be checked against the register. TÜV SÜD Product Service GmbH, notified body 0123, announced on 23 September 2024 that it was the world's first notified body under the new Machinery Regulation. Its notification date of 8 September 2024 is the earliest among all 49 records, and the announcement holds. The register also dates Intertek Deutschland's notification to 21 December 2025.

What the register cannot show is whether 39 is enough. I ran three targeted searches for a public statement on assessment capacity, queue length or lead time, from the Commission, a trade association or a notified body. Roughly twenty-five results came back and not one of them qualified. Every apparent hit was vendor marketing. Capacity has not been measured here, and none of these counts says whether it is adequate.

The strongest argument against the count is that it is still moving, and it is stronger than it first looks. Twenty-three of the 39 were notified since 1 January 2026 and ten since 1 July 2026, on the register's own last-approval-date field as read on 13 September 2026. Most of the roster arrived inside nine months. The count also binds only the Part A route: a manufacturer whose product sits in Part B, applying harmonised standards in full, will never need one of these bodies at all. That route is not yet operable under the Regulation, though, because no harmonised standard has yet been cited under it.

If a fortieth body appears next week, this count is wrong by one, and I would want to know. What will not change by next week is the shape of it. For the two Annex I categories written for machine learning in safety functions, the entire Union had three assessors and two on 13 September 2026. A market cannot be assessed faster than its assessors were appointed.

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