AIS 189 Cybersecurity Testing: What ARAI and iCAT Expect from Penetration-Test Evidence

India’s automotive cybersecurity framework was written to look like the rest of the world’s. AIS 189 derives from UNECE R155 and AIS 190 from R156, by design, so that Indian programmes could satisfy domestic approval and export-market expectations on one body of engineering evidence. That design choice has a practical consequence for testing: what the test agencies in Pune and Manesar expect from a penetration test is recognisably what a German technical service expects. This post sets out those expectations, the places where Indian programmes differ in practice, and how to write one report that serves both audiences.

One caveat up front, repeated at the end: the regulatory status, applicability and timelines of AIS 189 and AIS 190 have continued to evolve. Our AIS 189 and AIS 190 guide tracks the current position; confirm against the latest MoRTH, ARAI or iCAT notification before using any date for programme planning.

What AIS 189 Expects, and Where Testing Fits

AIS 189 asks for two things, in the same shape as R155. First, an organisational Cybersecurity Management System: governance, risk management, supplier management, monitoring and incident response, assessed at the manufacturer rather than the vehicle. Second, vehicle-type evidence: a threat analysis and risk assessment for the type, the mitigations chosen against the threat catalogue, and demonstration that those mitigations were verified by appropriate testing.

Penetration testing lives in that last clause. The standard does not prescribe a method, any more than R155 does; what it requires is that the manufacturer can show the measures were attacked and held. A structured penetration test — scoped from the TARA, executed on representative hardware, reported with reproducible evidence and retested after fixes — is the form of demonstration the agencies are used to reading, because it is the form the rest of the industry produces.

Who Reviews It: ARAI, iCAT and the CMVR Agencies

In UNECE markets the roles are split: an approval authority such as KBA or RDW grants the approval on the basis of an assessment by a designated technical service. In India the test agencies notified under the Central Motor Vehicles Rules — notably ARAI in Pune and iCAT in Manesar — carry both roles for AIS 189 and AIS 190: they assess and they approve. For the programme that means one reviewer, one conversation, and a reviewer who sees a great deal of evidence from a great many manufacturers.

Three things follow for the test report. The reviewer wants coverage before detail — which threats were exercised, which were argued away and why. They want evidence from the vehicle type under approval, not from a predecessor platform or a supplier’s generic qualification. And they want the risk assessment and the test results to agree: an attack path rated infeasible in the TARA and demonstrated on the bench is a contradiction the reviewer will find.

The Threat Catalogue: Aligned to Annex 5, Read the Same Way

AIS 189’s threat catalogue is aligned to UNECE R155 Annex 5 by design, so the seven high-level categories a European reviewer expects coverage of — back-end servers, communication channels, update procedures, unintended human actions, external connectivity, vehicle data and code, and insufficient hardening — are the categories an Indian reviewer expects too. We keep one coverage table and label it for both regimes. The Annex 5 penetration-testing checklist sets out the test cases per category; the only India-specific additions are the targets below.

Targets Indian Programmes Test That Others Often Do Not

• AIS 140 telematics and tracking devices. Vehicle location tracking and emergency-button units mandated for commercial and public-transport fleets carry GNSS, a cellular modem and a backend session — the same remote attack surface as a passenger-car telematics unit, frequently with weaker provisioning. Test the device, its backend session and the trust relationship back into the vehicle network.
• EV battery management and charging interfaces. BMS diagnostics and calibration access, on-board charger control, and charging-communication handshakes carry thermal and electrical safety consequence; findings are rated for it.
• Two- and three-wheeler connected platforms. BLE and app-based keys, cluster firmware and update paths — largely outside AIS 189’s scope, but inside UNECE R155 for anything exported to the EU from December 2027.
• Cost-optimised infotainment. Android-based heads with USB, Bluetooth and Wi-Fi surfaces and a bridge to the vehicle network, the usual route from a consumer-grade component to a vehicle-grade consequence.

The Second Audience: Your Global OEM Customer

Most Indian Tier-1s and captive engineering centres meet a penetration-testing obligation from their customer before they meet one from MoRTH. UNECE R155 has applied to every new car, van, truck and bus registered in the EU since 7 July 2024, and it regulates the OEM — who cannot pass an assessment without supplier-side evidence. The Cybersecurity Interface Agreement under ISO/SAE 21434 Clause 7 pushes the verification obligation down to the component supplier, and the OEM’s audit usually lands before the domestic submission does.

That is the argument for writing one report rather than two. A report written only for a domestic reviewer — threat labels in a local format, no TARA linkage, no ISO/SAE 21434 clause references — has to be rewritten for the OEM. A report written to the shared structure serves both. India is not a party to the 1958 Agreement, so the approval does not transfer; the evidence does, and that is what the customer is asking for.

What the Evidence Pack Contains

The table below is the through-line from what an AIS 189 reviewer expects to the artefact we hand over and the international reference it mirrors.

Timing the Test Against Both Dates

Two assessments matter, and most Indian programmes need both. An early assessment on a representative bench or prototype validates the security concept while design changes are still cheap; it is also the one that satisfies an OEM’s first-article cybersecurity review. A second assessment on production-representative hardware and firmware produces the evidence the test agency expects for the vehicle type. Between them, each firmware release that changes a security-relevant function is retested, so the submission-grade report is a closure of known findings rather than a discovery exercise.

Practically, that means scheduling the first pentest against the OEM customer’s audit date, the second against the planned ARAI or iCAT submission, and keeping four to ten weeks per ECU in the plan for each — more for vehicle-level scope. Hardware never leaves India, which removes the export-control and customs delays that stretch European engagements.

Mistakes That Stall Indian Submissions

• Reusing a predecessor platform’s report. Evidence must come from the vehicle type under approval.
• Supplier qualification instead of integration testing. A Tier-1’s component report does not cover the gateway and domain boundaries the OEM integrated it behind.
• No argued non-applicability. A blank threat category reads as an omission, even where the category genuinely does not apply.
• TARA and test results that disagree. Every confirmed finding should update an attack feasibility rating.
• Open findings without a treatment decision. Retest evidence closes them; where a fix is deferred, document the decision and the owner.

Take-Aways

AIS 189 was written to be read the way R155 is read, and the test agencies read it that way. Scope the penetration test from the TARA, cover the threat catalogue with artefacts and argued non-applicability, map results to ISO/SAE 21434 clauses, and retest before submission — and the same report serves ARAI or iCAT and the global OEM customer. For how we deliver that on Indian programmes, see automotive penetration testing in India; for the standard’s scope and status, the AIS 189 compliance page.

Agnile Technologies is headquartered in Bengaluru and delivers automotive penetration testing from its own lab or on-site at OEM and Tier-1 benches across India, with findings mapped to AIS 189, UNECE R155 Annex 5 and ISO/SAE 21434. This article is not homologation advice; confirm applicability and dates against the current official notification.