Machinery Regulation 2027: what changes for autonomous cleaning robots

On 20 January 2027, Regulation (EU) 2023/1230 on machinery replaces the 2006 Machinery Directive. Autonomous cleaning robots are among the machines most directly affected: they move without a driver, connect to the cloud, receive updates and run software that decides their path. This guide sums up what the new text changes for them, and what a buyer or a renter should check from 2027 onwards. For the safety standard specific to floor robots, see our IEC 63327 barometer.

What changes on 20 January 2027

The Regulation was published in the Official Journal of the European Union in June 2023. Unlike the Directive it replaces, it does not go through national transposition: the same text applies on the same date in every member state. On 20 January 2027, Directive 2006/42/EC is repealed.

The switch-over rule is straightforward. A machine placed on the market from 20 January 2027 must comply with the Regulation, with an EU declaration of conformity that refers to it. A machine placed on the market before that date remains governed by the Directive: robots already installed do not need to be brought into line retrospectively, unless they undergo a substantial modification.

For a site operator, that means two populations of robots can coexist for years on the same premises: machines supplied before the cut-off date, documented under the Directive, and machines supplied afterwards, documented under the Regulation. Both are lawful. What matters is that each one's paperwork matches the date it was placed on the market.

Why cleaning robots are in the front line

The 2006 Directive was written for machines driven or controlled by an operator. A commercial cleaning robot ticks three boxes it did not foresee. It is autonomous, since it moves and chooses its path without a driver. It is connected, since it sends its reports to the cloud and receives remote updates. And it is software-driven, since detecting people, avoiding obstacles and stopping all depend on sensors and algorithms.

The Regulation addresses all three. It does not create a "cleaning robot" category, but its new requirements apply in full to autonomous scrubber-dryers, sweepers and vacuums, just as they do to delivery robots and autonomous trucks.

Autonomous mobile machinery: what the text requires

The Regulation sets specific requirements for autonomous mobile machinery, meaning machinery able to move within its working area without a driver. Among other things, it calls for a supervisory function, allowing the machine to be monitored and stopped remotely, and for perception of the environment and decision-making that ensure safe paths, with a stop when there is danger.

It also requires the machine to communicate clearly what it is doing and what it is about to do. On a floor robot, that corresponds to features already common among the best manufacturers: light and sound signals, a projected path on the floor, a status screen, a monitoring app. From 2027, these are no longer selling points but requirements. How the sensors behind this perception work, and where they fall short, is explained in our article on cleaning robot LiDAR and obstacle detection.

The harmonised standards that will spell out these requirements are still being drafted, and their list is expected at the end of 2026. Until then, each manufacturer carries out its own risk assessment.

Software, learning and cybersecurity

Two new features concern software. The first is protection against corruption: components and software that transmit safety-relevant data must be protected against accidental or malicious alteration, and an update must not degrade safety functions. For a connected robot, that goes straight to remote updates and access to the controls. For how to put this into practice on the client side, with a dedicated network, individual accounts, remote access and a data processing agreement, see our article on cleaning robot cybersecurity.

The second concerns machines whose behaviour evolves in operation because they learn. Where that self-evolving behaviour performs safety functions, the Regulation requires a conformity assessment by a notified body, with no option of self-certification. Most current cleaning robots do not change their safety functions by learning after delivery; it is for the manufacturer to state and justify this.

The EU Artificial Intelligence Act adds to this framework: artificial intelligence systems used as safety components of machinery are classed as high-risk systems, with obligations applying from August 2027.

Digital instructions, declaration of conformity, CE marking

The instructions for use may now be supplied in digital form. The manufacturer must then make them downloadable and viewable for the whole expected lifetime of the machine, and for at least ten years after it is placed on the market. A paper copy must still be supplied free of charge if the buyer asks for it at the time of purchase, within one month.

CE marking and the EU declaration of conformity remain the proof of conformity. For a robot delivered after 20 January 2027, the declaration must refer to Regulation (EU) 2023/1230, not to Directive 2006/42/EC.

It is worth keeping a copy of the declaration and a link to the digital instructions in your own site file for each robot. If the machine is inspected, involved in an incident or handed over to another site, those two documents are the first things asked for.

Substantial modification: beware of DIY fixes

This is the provision that matters most to site operators. A modification that the original manufacturer did not provide for, and that creates a new hazard or increases an existing risk, is a substantial modification. Whoever carries it out becomes the manufacturer of the modified machine, with all the obligations that entails: risk assessment, technical documentation, declaration of conformity.

On a cleaning robot, concrete examples include disabling or moving a sensor, raising the speed beyond the settings provided, fitting an accessory the manufacturer has not approved, or bypassing a stop. Accessories and settings offered by the manufacturer, on the other hand, stay within the original conformity. In practice, the simplest safeguard is to leave all interventions on the machine to the manufacturer or its approved network, which is also what a proper maintenance contract provides for.

What about IEC 63327?

IEC 63327 sets out the particular safety requirements for automatic floor treatment machines for commercial use, in other words commercial cleaning robots. For a buyer, it is currently the best evidence that a model's safety has been assessed against a framework designed for its use. In our barometer, only 13% of the models on the market publish their conformity.

The Regulation does not name standards one by one: it refers to the harmonised standards published in the Official Journal, which give a presumption of conformity. Until that list is published, documented IEC 63327 conformity remains a strong signal, and one to ask for every time.

What a buyer or a renter should check

Six points cover the essentials for a robot bought or rented from 2027:

1. The EU declaration of conformity refers to Regulation (EU) 2023/1230 if the robot is placed on the market after 20 January 2027.
2. IEC 63327 conformity is published, with the name of the test laboratory.
3. The update policy is described: who rolls out updates, and how safety functions are protected.
4. The instructions are available online, with a paper copy supplied on request.
5. Interventions on the machine are carried out only by the manufacturer or its approved network.
6. For a rental, these obligations sit with the rental company and should be written into the contract, a point to weigh alongside the others in our guide to rental or purchase.

What it changes at Easy to Clean

As an authorised distributor, we deliver robots with the manufacturer's declaration of conformity, we do not modify machines beyond the settings and accessories the manufacturer provides for, and updates go through its network. Under our full service, conformity, maintenance and updates stay our responsibility: clients do not have to follow these regulatory changes themselves.

Sources and references

Regulations, public bodies and manufacturer documents this article draws on. Links open in a new tab.

• Regulation (EU) 2023/1230 of the European Parliament and of the Council of 14 June 2023 on machinery and repealing Directive 2006/42/EC (EUR-Lex (European Union)) : The full text of the Machinery Regulation: application from 20 January 2027, autonomous mobile machinery, protection against corruption, digital instructions and substantial modification.
• Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (Artificial Intelligence Act) (EUR-Lex (European Union)) : The EU Artificial Intelligence Act, which treats artificial intelligence systems used as safety components of machinery as high-risk systems.