MOT rules change to allow approved LED replacement headlamp bulbs

Changes to MOT testing regulations mean that vehicles fitted with ECE-approved LED replacement bulbs in halogen headlamp units can now pass an MOT, provided the bulbs have the necessary approval and a corresponding identification sticker is displayed on the vehicle.
The change, which comes into effect today (14 October, 2026), follows work by the Department for Transport (DfT), Driver and Vehicle Standards Agency (DVSA) and lighting manufacturers.
Previously, vehicles first used on or after 1 April 1986 with halogen headlamps converted to use LED bulbs would fail the MOT under the defect category ‘Light source and lamp not compatible’.
However, section 4.1.4 of the MOT testing manual, ‘Compliance with requirements’, has now been updated to allow LED replacement bulbs approved under UNECE Regulation 37 (ECE R37).
The change applies to class 3 (tricycles), class 4 (cars), and classes 5 and 7 (vans), but not motorcycles.
New approval sticker
To help MOT testers identify approved bulbs, manufacturers must now supply a secure approval sticker with ECE-approved LED replacement bulbs.
The sticker must be permanently applied to the vehicle, such as inside the engine bay, and be readily visible to the MOT tester. It must include the LEDr category, variant, rated voltage, ECE approval number, manufacturer’s name and a security feature, such as a hologram.
As approval markings are normally on the bulbs themselves, where they cannot be seen during an MOT inspection, testers only need to confirm that a corresponding sticker is present. They are not required to verify its details.
If no sticker is visible, the vehicle can still fail with a major defect recorded for ‘Light source and lamp not compatible’.
Grant Thunder, Head of MOT at the DVSA, said: “We’ve worked closely with the Department for Transport and lighting manufacturers to develop a practical way to identify ECE approved LED replacement light sources during MOT testing.
“Bulbs will be sold with an approval sticker which must be applied to the vehicle and be visible to the MOT tester at the point of test so they can determine if an ECE approved LED light source is fitted.”
Which bulbs are approved?
OSRAM, one of the lighting manufacturers involved in discussions with the DfT and DVSA, has welcomed the change.
According to OSRAM, H11 and C5W are currently the only LED replacement bulb types included in the latest edition of UNECE Regulation 37, with further types expected to be added over the next two to three years.
Carl Harrison, Product Manager for Bulbs and Vehicle Lighting at OSRAM, said: “There has been a lot of work behind the scenes on this issue and we are thrilled the hard work of everyone involved has paid off.”
Garages should be aware that the change does not apply to all aftermarket LED replacement bulbs. Non-approved LED conversions will continue to fail, while approved products must have the required identification sticker displayed on the vehicle.

