UL 1998-3rd A1: TLS 1.3 Mandatory for V2G Devices in North America

On April 29, 2026, UL Solutions formally published Supplement A1 to the third edition of UL 1998, mandating that all vehicle-to-grid (V2G) equipment intended for the North American market must integrate a FIPS 140-3–validated TLS 1.3 protocol stack and submit firmware security audit reports — effective June 1, 2026. This update directly impacts manufacturers and exporters of bidirectional EV chargers, V2G communication modules, and EMS edge gateways, particularly those based in China supplying to U.S. and Canadian markets.

Event Overview

UL Solutions released Supplement A1 to UL 1998, Third Edition, on April 29, 2026. The supplement requires that, as of June 1, 2026, all V2G devices marketed in North America must include an embedded TLS 1.3 protocol stack validated under FIPS 140-3, and manufacturers must provide a firmware security audit report as part of certification. The scope explicitly covers bidirectional charging controllers, V2G communication modules, and energy management system (EMS) edge gateways.

Industries Affected

Direct Exporters (OEMs & ODMs)

Export-oriented hardware manufacturers—especially Chinese OEMs/ODMs supplying V2G components to North America—face immediate compliance pressure. Their existing product certifications may no longer be valid post-June 1, 2026, unless updated firmware and audit documentation are submitted and accepted by UL. Impact manifests in delayed time-to-market, additional validation costs, and potential contract renegotiation with North American utilities or aggregators.

Hardware Design & Firmware Development Firms

Firms providing firmware engineering, secure boot implementation, or cryptographic stack integration for V2G systems must now prioritize TLS 1.3 support aligned with FIPS 140-3 requirements. Legacy TLS 1.2–only implementations will not meet the new baseline. Impact includes extended development cycles for cryptographic module requalification and tighter integration testing with UL’s security assessment framework.

Third-Party Certification & Testing Laboratories

Laboratories supporting UL 1998 certification workflows must update their test plans and reporting templates to cover FIPS 140-3–aligned TLS 1.3 verification and firmware audit review. Impact includes revised service offerings, staff training on NIST SP 800-155 and FIPS 140-3 validation evidence requirements, and potential backlog in security-focused test slots.

Energy Management System (EMS) Integrators

EMS integrators deploying edge gateways in V2G-enabled commercial or utility-scale projects must verify upstream device compliance prior to procurement. Non-compliant gateways risk rejection during UL field evaluations or disqualification from utility incentive programs requiring UL 1998–A1 conformance. Impact appears in tightened vendor qualification checklists and increased pre-deployment verification steps.

What Enterprises and Practitioners Should Focus On Now

Monitor official UL communications for implementation guidance

UL has not yet published detailed technical guidance on acceptable TLS 1.3 stack configurations or audit report format requirements. Enterprises should subscribe to UL’s Standards Updates portal and track any forthcoming white papers or FAQs related to Supplement A1.

Prioritize firmware revision planning for high-volume SKUs

Analysis shows that integrating and validating a FIPS 140-3–compliant TLS 1.3 stack typically adds 8–12 weeks to firmware release timelines. Exporters should identify top-selling V2G SKUs bound for North America and initiate stack evaluation and integration planning immediately — especially where open-source TLS libraries (e.g., Mbed TLS, wolfSSL) require customization for FIPS mode.

Distinguish between certification submission deadlines and enforcement timing

Observably, UL does not specify whether the June 1, 2026 date applies to first-time certifications only, or also to renewal applications for legacy-certified devices. Enterprises should confirm with UL whether grandfathering provisions apply and prepare contingency plans for products currently in the certification pipeline.

Initiate early engagement with FIPS 140-3–accredited labs

Firmware security audits required under A1 must be conducted by labs accredited under the Cryptographic Module Validation Program (CMVP). Current wait times for CMVP-accredited lab capacity exceed 10 weeks in some regions. Companies should schedule preliminary scoping calls with such labs now to align on evidence expectations and timeline feasibility.

Editorial Perspective / Industry Observation

This update is better understood as a regulatory signal reinforcing the convergence of cybersecurity and grid interoperability standards — rather than an isolated technical amendment. From an industry perspective, UL 1998–A1 reflects growing alignment between NIST cybersecurity frameworks (e.g., SP 800-207 on zero trust) and grid-edge device certification. It signals that future revisions to UL 1998 — and likely IEEE 2030.5–based conformance testing — will treat cryptographic protocol maturity and validation rigor as non-negotiable baseline criteria. Continued monitoring is warranted, as this requirement may inform upcoming updates to CSA C22.2 No. 107.1 or IEC 63110 adoption pathways in Canada.

Conclusion

UL 1998–A1 does not introduce new functional capabilities for V2G devices, but elevates baseline security assurance to match evolving threat models in distributed energy resource (DER) environments. Its practical significance lies less in technical novelty and more in its role as a de facto gatekeeper for North American market access. For affected enterprises, it is more accurately interpreted as a hard deadline for security architecture modernization — not merely a compliance checkbox.

Source Attribution

Main source: UL Solutions — Official Announcement of UL 1998, Third Edition, Supplement A1 (issued April 29, 2026).
Areas requiring ongoing observation: UL’s forthcoming technical implementation guidance, CMVP lab capacity updates, and potential harmonization with CSA or ANSI standards committees.