You may have heard about changes to machinery legislation in 2026 and wondered what they mean for automatic doors.
The EU Machinery Directive is being replaced by the EU Machinery Regulation (EU) 2023/1230. Article 54 confirms:
“It shall apply from 20 January 2027.”
For automatic-door businesses, the first thing to understand is that the position differs depending on where you work. Source: EU Machinery Regulation, Article 54
Does it apply across the UK?
In Northern Ireland, the new EU Regulation will apply from January 2027 under the Windsor Framework.
The Department for Business and Trade’s explanatory memorandum states:
“Under the Windsor Framework, the EU Regulation will apply directly to NI.”
In England, Scotland and Wales, the Supply of Machinery (Safety) Regulations 2008 remain the domestic framework. The Government’s 2026 measures provide for continued recognition of machinery meeting the relevant new EU requirements, including CE marking.
The Government also intends to update Great Britain’s requirements. Its memorandum states:
“Requirements in GB will be updated as soon as parliamentary time allows.”
Businesses therefore need to distinguish between the British compliance route and the recognised EU route.
Source: UK Government explanatory memorandum, paragraphs 5.9, 5.11 and 6.8
What is changing?
The Regulation addresses safety-related software, connected controls and responsibility for substantial alterations.
Altering an existing door
A company carrying out a substantial modification:
“shall be considered to be a manufacturer for the purposes of this Regulation”
The legal definition involves an unforeseen physical or digital alteration that creates a hazard or increases risk, requiring specified changes to protective measures or safety controls. Routine repairs are not automatically substantial modifications.
Software and connected controls
Safety-critical software and data must be protected against accidental or deliberate interference. Relevant software and configuration changes must be traceable.
Source: Annex III, sections 1.1.9 and 1.2.1
Digital instructions
Digital instructions are permitted subject to accessibility and retention conditions. Paper copies must be available on request at purchase, with essential paper safety information required where non-professional use is intended or reasonably foreseeable.
What does that mean on a job?
ADIA’s practical advice is to look beyond the component being fitted and consider the complete door.
Before changing an operator, controller or access-control connection, ask:
- Is this change covered by the manufacturer’s instructions?
- Could it affect the sensors, closing behaviour or emergency operation?
- What testing and documentation will demonstrate that the completed door is safe?
- Who is taking responsibility for the finished installation?
These questions are particularly useful when mixing equipment from different suppliers or introducing remote control.
For example, adding an access-control connection should prompt a check of how the door behaves when access is refused, power fails or an emergency signal is received.
These are practical examples of matters to assess. They do not mean every access-control connection or operator replacement automatically meets the legal definition of a substantial modification.
How does this relate to BS EN 16005?
BS EN 16005 is not being replaced by the new Machinery Regulation. It remains an important safety standard for powered pedestrian doors.
Standards are continually reviewed and developed to reflect changes in technology, safety knowledge and legislation. Businesses should keep up to date with relevant revisions and understand how they affect installation, testing and maintenance.
The European Commission is also preparing the list of standards supporting the new Regulation. It states:
“It will feature the vast majority of currently cited harmonised standards under the Machinery Directive.”
Businesses should check the applicable edition and its recognised status rather than assume every existing reference transfers unchanged. This announcement does not establish a particular revision date for BS EN 16005.
Source: European Commission guidance on machinery harmonised standards
How should members prepare?
ADIA recommends starting with a review of your existing processes:
- Ask suppliers what will change in their products and documentation for 2027.
- Record safety-related settings and software versions where relevant.
- Keep risk assessments, commissioning results and handover documents together.
- Assess proposed alterations before starting work.
- Check the requirements for the market where the door will be supplied or installed.
Start by making sure your records explain what was installed, how it was tested and who is responsible for it.
Information checked in September 2026. Legislative references are linked throughout. The installation examples and preparation checklist are ADIA’s practical recommendations; individual installations and alterations require their own assessment.