What it means: No standard gives a presumption of conformity under the Regulation yet. Until one is cited, a manufacturer shows conformity with the essential requirements of Annex III directly, and the Annex I Part B route through harmonised standards applied in full is not open.
Cited under the Regulation
0As of · single-market-economy.ec.europa.euCommission page: "a new Commission Implementing Decision with the list of harmonised standards under the new Machinery Regulation is being prepared." No machinery-regulation implementing decision found in the Official Journal up to 31 Oct 2026.
Commission's stated timing for the first list
Before the end of 2026As of · single-market-economy.ec.europa.euCommission page: "The first Machinery Regulation list can be expected before the end of this year." IBF Solutions (last amended 21 Oct 2026) says the same. The Commission's answer to written question E-002354/2026 (6 Aug 2026) could not be re-read on 31 Oct 2026, so it is not the source here.
Last list update under Directive 2006/42/EC
Implementing Decision (EU) 2026/2015, 4 September 2026As of · eur-lex.europa.euOJ L 2026/2015, 7 Sep 2026. Amends the Directive 2006/42/EC list (Implementing Decision (EU) 2023/1586): 67 references inserted and 2 replaced, counted from the Annex rows on 31 Oct 2026. Article 2 repeals Implementing Decision (EU) 2023/1586 with effect from 20 January 2027.
What it means: The Guide is how the Commission explains its reading of the Regulation. On 1 November 2026 the published chapters were drafts, not the complete Guide, and none of them covered AI or machine-learning safety functions.
Draft chapters published
4As of · ibf-solutions.comDraft chapters dated 18 Oct 2026, published 19 Oct 2026: protection against corruption and safety of control systems; seating and restraint systems; vibrations; contact with live overhead power lines. "These documents are draft chapters, not the final, complete Guide." No Commission page for the Regulation's Guide was found.
Chapters still to come
not publishedAs of · ibf-solutions.comThe total number of chapters is not published. The Editorial Group's status report of 27 Apr 2026 lists workstreams not among the four drafts, including AI-powered safety functions and software as safety components, substantial modification, and autonomous mobile machinery. IBF reports the Guide is due in Q4 2026.
What it means: Every product in Annex I Part A needs one of these bodies, whatever standards it applies. That includes the two machine-learning categories, points 5 and 6, counted below.
Notified bodies, all categories
39As of · webgate.ec.europa.euCount of the Commission's register (NANDO / Single Market Compliance Space) read on 13 Sep 2026; method in the post "notified-bodies-machinery-regulation-count". Not re-read on 31 Oct 2026: the register is a JavaScript application that could not be read automatically.
Annex I Part A point 5 · ML safety components
3As of · webgate.ec.europa.euAnnex I Part A point 5: "Safety components with fully or partially self-evolving behaviour using machine learning approaches ensuring safety functions." DTI Dancert (DK), Intercert Global (PL), TUV Cyprus (CY).
Annex I Part A point 6 · machinery with embedded ML safety systems
2As of · webgate.ec.europa.euAnnex I Part A point 6: machinery with embedded systems with fully or partially self-evolving behaviour using machine learning approaches ensuring safety functions. DTI Dancert (DK), TUV Cyprus (CY).
AI Act delegated act
2 August 2028
the date by which the AI requirements must apply
What it means: Regulation (EU) 2026/1744 moved machinery to Section B of AI Act Annex I. The AI health and safety requirements for machinery will come as a Commission delegated act that adds them to Annex III of the Machinery Regulation.
Delegated act, draft or adopted
not publishedAs of · eur-lex.europa.euNo draft, consultation or adopted delegated act found on 31 Oct 2026. The Commission's "Have your say" portal could not be read automatically, so this is a search result, not a confirmed negative from the portal.
Legal basis
Regulation (EU) 2026/1744, Article 3 (new text in Article 8 of Regulation (EU) 2023/1230)As of · eur-lex.europa.euAdopted 8 Jul 2026, OJ 24 Jul 2026. The Commission "shall adopt delegated acts ... to amend Annex III ... by adding health and safety requirements in respect of Artificial Intelligence (AI) systems"; "Those delegated acts shall apply by 2 August 2028." The Annex moves Regulation (EU) 2023/1230 from Section A to Section B (point 21) of AI Act Annex I.
Product Liability Directive
5 of 27
member states with a published law · due 9 December 2026
What it means: Directive (EU) 2024/2853 makes software, AI included, a product. It covers products placed on the market after 9 December 2026, the day national laws are due.
Legal basis
Directive (EU) 2024/2853, Article 22As of · eur-lex.europa.euMember states bring the national laws into force by 9 December 2026. The Directive covers products placed on the market or put into service after 9 December 2026 (Article 2(1), as corrected on 7 May 2026).
Humanoid and AI safety standards
Committee draft · stage 30.60
ISO 25785-1, dynamically stable industrial mobile robots
What it means: On 1 November 2026 none of the three was a published standard. A committee draft (CD) or a final draft (FDIS) can still change, so no product can claim compliance with it.
ISO 25785-1 · dynamically stable industrial mobile robots
Committee draft · stage 30.60As of · iss.rsISO/CD 25785-1, Robotics: safety requirements for dynamically stable industrial mobile robots, Part 1: Robots (ISO/TC 299). Stage 30.60, close of voting/comment period, since 8 Jul 2026. Read from the ISO project database as mirrored by the Institute for Standardization of Serbia, because the ISO catalogue (iso.org/standard/91469) refused automated reads on 31 Oct 2026.
ISO/IEC TS 22440-1 · functional safety and AI systems
Committee draft · stage 30.60As of · iss.rsISO/IEC CD TS 22440-1, Artificial intelligence: functional safety and AI systems, Part 1: Requirements (ISO/IEC JTC 1/SC 42). Stage 30.60 since 11 Apr 2026; parts 2 and 3 are at the same stage. Read from the mirrored ISO project database (iso.org/standard/89535 refused automated reads on 31 Oct 2026).
IEC 61508 edition 3 · functional safety
Final draft (FDIS) ballot · stage 50.20As of · iss.rsIEC 61508-1 ED3 (IEC TC 65/SC 65A): stage 50.20 since 2 Oct 2026, next stage (proof) 13 Nov 2026. Parts 2, 3, 4 and 7 show the same stage and dates. No IEC publication forecast was found. Read from the IEC project database as mirrored by the Institute for Standardization of Serbia (iec.ch refused automated reads on 31 Oct 2026).
Product Liability Directive: 27 member states
Directive (EU) 2024/2853 must be transposed by 9 December 2026. One row per member state: the furthest stage a public source shows, the date of that stage (for "nothing published", the date the source was read), and the source.
Member state
Status
Date
Source
Austria AT
DraftMinisterial draft Produkthaftungsgesetz 2026 (151/ME, Ministry of Justice) reached the Nationalrat on 23 Oct 2026; comments due 12 Nov 2026.
DraftBill amending the Civil Code product-liability rules introduced in the Chamber on 16 Oct 2026. Secondary source; the Chamber document was not found.
Nothing publishedOnly a plan: the Cabinet's legislative programme for Jul–Dec 2026 lists an amendment to the Consumer Protection Act to transpose the Directive, due September 2026. No draft text found.
DraftChamber print 295, amendment to the Civil Code, sent to deputies 3 Sep 2026. The page does not cite the Directive; the link to it comes from law-firm commentary.
DraftGovernment bill HE 190/2026 vp (Product Liability Act and Consumer Protection Act amendment) submitted 24 Sep 2026. The parliament's site could not be read; date from a law-firm page.
Nothing publishedThe current EU-adaptation bill (PJL 25-118) does not cover the Directive. A law-firm tracker of 30 Oct 2026 finds no draft; a CMS deck of 13 Oct 2026 lists France as "draft". Contested.
Law publishedGesetz zur Modernisierung des Produkthaftungsrechts und zur Änderung weiterer Vorschriften of 22 Oct 2026, BGBl. 2026 I Nr. 321, issued 27 Oct 2026.
Nothing publishedLaw-firm tracker of 30 Oct 2026: "legislation is being drafted". No General Scheme, bill or statutory instrument found. No primary source.
Law publishedCivil Code Book 6 amendments (XV-1080) adopted by the Seimas on 25 Jun 2026; the date is adoption, not publication in the Register of Legal Acts, which could not be read. Two law-firm trackers list Lithuania as implemented.
DraftMinistry of Justice bill UC163 amending the Civil Code and the Code of Civil Procedure; created 7 Sep 2026, inter-ministerial review from 22 Sep 2026.
First edition, 1 November 2026. From the next update on, every number that changes is listed here with its old and new value.
How this tracker is kept
Every number is read from a public source and printed with that source and the date it was read. Where no source publishes a number, the tracker says "not published" instead of estimating one. Updates are made by hand: nothing here is fetched automatically, and an older "as of" date means that number was not re-read in the latest update.
Updated . The tracker has no feed of its own. Posts that report a change appear in the site feed: /rss.xml
Cite this
APA
Melchior, M. (2026, November 1). The 20 January 2027 Tracker: what must exist before Regulation (EU) 2023/1230 applies. Physical AI Safety. https://physical-ai-safety.com/tracker
BibTeX
@misc{melchior2026tracker,
author = {Melchior, Mati},
title = {{The 20 January 2027 Tracker: what must exist before Regulation (EU) 2023/1230 applies}},
howpublished = {Physical AI Safety},
year = {2026},
month = nov,
date = {2026-11-01},
url = {https://physical-ai-safety.com/tracker}
}
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