Updating Vehicle Immobilization Standards
The proposed Regulations Amending the Motor Vehicle Safety Regulations (Theft Protection), published in Canada Gazette, Part I, Volume 159, Number 52 on December 27, 2025, aim to improve Canada’s vehicle theft protection requirements by updating outdated references to immobilization system standards. The amendments are made under the authority of the Motor Vehicle Safety Act and are sponsored by the Department of Transport. The initiative responds to evolving vehicle theft methods, particularly the increased use of sophisticated electronic attack tools, and seeks to align Canadian requirements with the most recent international standards.
Under the existing Motor Vehicle Safety Regulations, Canada Motor Vehicle Safety Standard 114 governs theft protection and rollaway prevention through mandatory vehicle immobilization systems. These systems, introduced in 2005 and made mandatory in 2007, are designed to prevent unauthorized vehicle use by disabling critical control units unless a coded key, keypad, or remote device is used. Amendments in 2011 accommodated emerging technologies such as keyless entry and remote start. However, the standard currently incorporates by reference several immobilization system standards that have since been significantly updated, leaving Canadian regulations misaligned with current global practices.
The amendments propose replacing outdated standards with newer versions that reflect contemporary theft risks. Specifically, the static reference to the CAN/ULC S338-98 standard would be replaced with a static reference to the ANSI/CAN/UL/ULC 338:2025 standard. The updated standard introduces testing against “electronic attack tools,” such as key programmers, signal relay devices, and emulators, and incorporates both metric and imperial units to support harmonization with U.S. standards. In parallel, the amendments would adopt United Nations Regulation No. 162 through ambulatory incorporation of the 00 series of amendments.
The proposal also includes targeted modifications to ensure consistency between standards and compatibility with Canada’s self-certification regulatory framework. Definitions of key terms would be clarified, aftermarket and cybersecurity requirements would be excluded as outside the scope of the amendments, and the UN regulation would be adapted from a type-approval model to self-certification. Under Canada’s system, manufacturers remain responsible for certifying compliance, while Transport Canada oversees enforcement through testing, audits, and defect investigations.
Outdated requirements would be repealed as part of the amendments. This includes subsections (8) to (21) of CMVSS 114, which constitute a Transport Canada–developed option that no longer reflects current theft techniques and omits electronic attack tools. References to UN Regulations Nos. 97 and 116 would also be removed, as their content is now consolidated in UN Regulation No. 162.
Canada (Proposed) December 30, 2025
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.
