Machines Got Smarter, Now ISO 12100 has to Catch Up

11 Dec 2025

Bringing Safety Thinking into the Digital Age

I have been following the revision of ISO 12100 for a while now, and honestly, it is one of the most interesting and overdue updates in the world of machinery safety.

If you work in design, conformity, or safety, you know ISO 12100. It is the parent standard that sets the rules for risk assessment and risk reduction, the famous Type A standard that everything else builds on.

But machines today are not what they used to be. They are getting smarter, connected, and sometimes even self-learning. The old 2010 edition of ISO 12100 did a great job for mechanical, electrical and other physical hazards, but it never had to deal with things like AI, cybersecurity, or remote software updates. Now, with the new EU Machinery Regulation (EU) 2023/1230, all those topics have moved to the front of the stage.

The Revision Journey

The update of ISO 12100 has been moving through ISO and CEN for the past couple of years. ISO/TC 199 and CEN/TC 114 are working together under the Vienna Agreement, using a parallel ISO – CEN approval process to make sure the EN ISO text lines up with the new Machinery Regulation, which starts applying on 20 January 2027.

Right now, the current draft, ISO/DIS 12100 (Edition 2), that is in its second enquiry stage, after a wave of comments and debates from member countries. If all goes well, it could reach the Final Draft International Standard (FDIS) stage in 2026.

But… that’s a big if.

Why Timing Really Matters

ISO 12100 is not just another standard and it is the foundation of the whole safety framework. Every Type B (generic safety aspects like guards or emergency stops) and Type C (machine-specific) standard builds on it.

If ISO 12100 gets delayed, other standards can technically still move ahead, they can reference it without a date but it complicates coordination. Since so many Type B and C standards rely on its terminology and structure, most committees prefer to wait until ISO 12100 is final before aligning their updates. Without it, the harmonisation work under the new Machinery Regulation becomes slower and harder to keep consistent.

And that matters, because:

• Manufacturers get stuck between old and new rules, unsure which to follow.
• CEN committees struggle to revise their dependent standards.
• Certification and notified bodies end up in a grey zone when checking compliance.

If ISO 12100 slips, the rest of the machinery-safety world slows down with it.

The Tricky Bits

Updating this standard is not easy. Some of the biggest debates are about how to deal with modern technologies like:

• Artificial intelligence and machine learning: should the standard even call them that?
• Cybersecurity: how do we manage corrupted data or hacked safety systems?
• Remote control and software updates: how do we make sure they do not create new hazards?

Even the wording, like “tolerable risk” vs “adequate risk reduction” has sparked long discussions.

It’s a reminder that the hardest part of standardisation is not the technology… it’s the language.

So What Now?

If you are a manufacturer, designer, or safety engineer, keep calm but stay alert:

• Keep using EN ISO 12100:2010:  it’s still valid until the new one is officially published.
• Start exploring the Machinery Regulation (EU 2023/1230): especially the new EHSRs around AI and digital safety.
• Keep an eye on your national standardisation body and follow updates from ISO/TC 199 and CEN/TC 114.
• And if your products already involve AI, connectivity, or remote control, start adapting your risk assessment process now, don’t wait for the ink to dry on the new standard.

To me, this revision is not just another round of paperwork. It is more about bringing safety thinking into the digital age. We used to worry about spinning blades and crushing hazards, but now we are talking about algorithms, corrupted data, and self-learning machines.

That is a big shift, but a necessary one.

ISO 12100 has always been about designing safety into machines from the start. That principle has not changed, it’s just expanding. Now, “design” also means software, connectivity, and data.

If all goes well, the new ISO 12100 will become the bridge between traditional machinery safety and the world of smart, autonomous systems.

And honestly, I cannot wait to see it published because once it is, the rest of the standards world can finally move forward with confidence.