Motorcycle helmet cameras & intercoms vs the law

When Schuberth announced its new ‘Concept’ helmet in 2025, it proudly pointed out that its ‘ECE-R22.06 UA’ marking meant it was the first lid to be tested and certified as safe to use with a universal accessory… like an intercom. 

But digging into what that actually means opens a massive can of worms, and it’s one we need get into so you can understand why it has such a big impact on fitting intercoms, cameras and ANY other accessory to ANY motorcycle helmet.

While debate still rages over whether the GoPro fixed to Michael Schumacher’s helmet contributed to his tragic injuries, it’s entirely plausible that sticking objects to the outside of your motorcycle lid, or indeed adding anything – inside or out – that wasn’t designed specifically for it could lead to injury or worse in a crash.

The new ‘UA’ (Universal Accessory) and ‘SA’ (Specific Accessory) classification of helmets under the ECE-R22.06 safety regulation sets out to address that, but it also means your choices for intercoms and other gear could be very limited…

Untested aftermarket accessories have never been approved

The intention of the UA and SA classification in ECE-R22.06 is to make it easier for consumers to buy helmets and intercoms (and other accessories) that have been tested and proven as safe in the event of a crash.

That’s totally true, though another way to look at it is that it’s to ensure that if someone is injured while wearing a helmet with something stuck to the side of it, the original manufacturer can’t be held liable.

If we consider this rationally it’s not a global conspiracy or some Big Brother thing: we live in a litigious world and if someone modifies a safety item and then gets hurt, who should be held responsible?

This isn’t new: in 1988’s ECE-R22.03 helmet standard, in 1995’s ECE-R22.04 and in 2000’s ECE-R22.05 the language was just as clear: ‘No component or device may be fitted to or incorporated in the protective helmet unless it is designed in such a way that it will not cause injury and that, when it is fitted to or incorporated in the protective helmet, the helmet still complies with the requirements of this Regulation.’

It’s unlikely that most consumers would be aware of this wording, or the potential issue with fitting a device that’s freely available for sale.

To avoid potential liability a helmet brand can’t supply or endorse an aftermarket accessory unless they’ve had that device tested as being safe when installed. That’s easy with a Specific Accessory, but there are a lot of aftermarket intercoms and other devices on the market, so how could they possible do that?

In response, several of the competing intercom brands formed a working group with a view to amending the certification standard, and the UA and SA markings were the result.

You now have a choice of what type of helmet to buy if you want to ensure you stick within the terms of the homologation:

The SA (Specific Accessory) standard is simple as you’re fitting what was designed specifically for the lid through collaboration between the helmet manufacturer and comms specialist – like a Shoei SRL 3, a Schuberth SC2 or HJC Smart. Brands have long been testing helmets with these devices fitted, so ‘SA’ is nothing new really.

UA (Universal Accessory) gives you some choice of what you fit, but for a helmet to remain homologated it has to be a UA-certified helmet with a UA-certified accessory.

Of course, it’s your choice what you do, but…

This Schuberth C5 has the Cardo-based SC Edge intercom fitted, which has been tested and certified as safe with the helmet

The legal implications of helmet accessories

The question of whether adding anything to your helmet could lead to prosecution or a reduction in compensation from a third party’s insurer should their client injure you is much more complicated than whether you choose to wear a protective riding jacket or not. Based on the application of contributory negligence (see this link) relating to clothing it’d be a tough case to make, but helmets are compulsory in the UK, and the Highway Code states in Rule 83 that ‘On all journeys, the rider and pillion passenger on a motorcycle, scooter or moped MUST wear a protective helmet.’ And that ‘Helmets MUST comply with the Regulations.’

Any helmet you buy from a legitimate UK retailer in the UK will comply with ECE-R22.06 (or might be old stock and meet ECE-R22.05), and in that regulation it’s clearly stated that only items designed specifically to not cause injury can be fitted.

Modifications the owner chooses to make after purchase are up to them, but this is a very grey area right now. Many people have helmets that they bought before UA and SA started being introduced, and there’s no precedent for riders being prosecuted for fitting an intercom or even a camera. The likely scenario is that consumers won’t be told what they can and can’t do, but manufacturers will make sure their products comply.

I spoke to Andrew Prendregast, Senior Partner at White Dalton Motorcycle Solicitors about both the criminal and civil aspects; “I have been working in this niche field of law for around two decades,” he told me. “With regards to the criminal side of things, i.e. where the police and/or CPS take someone to Court for an alleged criminal offence, I personally have never dealt with anyone being prosecuted for having the wrong ‘accessories’ attached to their helmet. That is not to say that someone somewhere in England and Wales has not been prosecuted, but we are very well ingrained into the motorcycle community and nothing to do with that has come across our desks, yet.

“However, with ECE Regulation 22.06 being quoted on various helmet manufacturer sites, an eagle-eyed policeman may try to target bikers. If that happens I strongly advise getting some legal advice to check they are quoting the right law, against whatever helmet you are wearing with whatever accessory is attached. It is far from easy to see what’s what and I can see mistakes being made by both riders and the police.

“Turning to the civil side of things, i.e. where you sue a car driver for knocking you off your motorbike and injuring you, I have not seen the issue of having a helmet ‘accessory’, such as an intercom etc. coming ‘into play’ in a civil claim, yet.

“However, I can definitely see it being an issue, if it was relevant, and if it was economically sensible for an insurer to explore it.

“For example, if you got knocked off by a car and broke your leg, having an intercom stuck to the side of your lid does not have any causative effect on your leg being broken. But let’s say the car knocked you off and you rolled down the road and you broke your neck and were paralysed, while wearing a lid with a large intercom on the side. In that scenario, if the car driver’s insurer were able to prove you contributed towards your own injuries to the tune of 5% or 10% by having a wrongly fitted ‘accessory’, it would save them £500,000 or £1,000,000 in a £10 million case.

“All in all, my advice – unsurprisingly as a solicitor – is to ride with a legal helmet and with legal accessories attached. It will save you any potential grief in the future.

“Anecdotally, I was involved in a case where my client was wearing an old army helmet (long story) on a vintage motorbike. With regards to the head injury he sustained after someone knocked him off, I had to tell him that he was likely to take a hit of around 10% for contributory negligence in front of a judge. So in simple terms, if his head injury was valued at £100,000 on a 100% liability basis, he had just kissed away £10,000, all for wearing a ‘period’ helmet to ride his old bike.”      

UA and SA protects you and it protects the manufacturers. There’s another problem though… currently many motorcycle stores fit comms units to customer helmets as a service, but they might become more cautious about fitting (or even selling) a device that wasn’t designed specifically for a helmet with SA certification, or that doesn’t meet the UA requirements.

How will brands ensure their intercoms and helmets are certified as safe?

Specific Accessory certification is easy to understand – the helmet is tested and certified for safety with that specific accessory installed. If you buy an SA lid, the corresponding SA accessory won’t impair your protection. It’s what already happens with integrated comms like the Shoei SRL3 and Schuberth SC Edge.

But to certify a helmet as suitable for a Universal Accessory, it has to be tested as safe for use with something that itself is UA-certified and hence falls within certain parameters.

The exact criteria are unclear, and aren’t really for consumers to have to worry about as they’ll just need to look for the labelling, but based on proposals from the working group back in 2021, plastic simulation devices of specific dimensions are likely to be used during impact testing of helmets that are seeking UA certification, and will probably be similar to these parameters:

• Maximum 200g for the main unit and a total of 500g including speakers, microphone etc.

• Maximum 40mm diameter and 12mm thick speakers (excluding any foam comfort cover). However, optional certification of helmets for speakers up to 45mm in diameter can be made.

• Maximum microphone length of 35mm, width 18mm, height 11.5mm. Any boom arm must be flexible with an outside diameter of no more than 8mm.

• At least 41mm diameter and 8mm depth inside the helmet for speaker location.

• At least 30mm of space outside the helmet’s impact test area and above the lower edge of the shell (including the rubber trim).

• A smooth, flat area on which to mount the device, or the ability to use a suitable clamp

Remember, these were proposals made for amendments to ECE-R22.06. I’ve so far been unable to verify the exact text used in the finalised requirements.

How to tell what certification a helmet has

Labelling inside the helmet and details in the owner’s manual will tell you what certification standard a helmet has been tested to. The pic above shows what you’ll find on the Schuberth Concept, which you can see is approved for use with a Universal Accessory, and with intercom speakers up to 45mm in diameter. We can also see that it’s certified to be used with a microphone, and that the intercom must be positioned to the side.

Gaining a UA certification mark is not just a formality

You might assume that the current range of aftermarket intercoms available from Sena, Cardo, Midland and Interphone will just need some paperwork pushing through in order to gain the relevant certification, but that’s not the case.

Off the record, I spoke to someone from an intercom brand at EICMA in 2025, who told me that it’s not safe to assume that their full current range – or anyone else’s – will comply with the UA classification.

Understanding that devices, their speakers and microphones need to be of a limited size, or at least fit into an area that isn’t vulnerable in a crash, it’s a fairly safe bet that some currently being sold will be very unlikely to conform to the ECE22.06 UA requirements.

But some will, and the tricky part might just be in working out how they attach to some lids.

Motorcycle intercoms that conform to ECE22.06 UA

At the time of writing the choice of Universal Accessory motorcycle intercoms are restricted to just these two:

• Midland BT Mini | Bluetooth only | £170.00 (pair) | Web link (not yet reviewed by BikeSocial)

• Midland BTR1 Advanced | Bluetooth only | £179.00 | Web link (not yet reviewed by BikeSocial)

Unfortunately, while still available in some stores, Midland does not currently have a UK importer. In future Bennetts BikeSocial intercom reviews, we will of course look at their certification.

Speaking to an industry expert, I’ve heard that we can expect to see plenty of UA-certified intercoms coming from the leading brands by the end of 2026, and they won’t necessarily be smaller than some already on the market, though how they’re intended to be positioned will vary. I’ve also seen a photo of a Cardo Packtalk fitted to a helmet that was being developed for Universal Accessory status, so I’m confident that many of the devices for sale now, will continue to be.

Motorcycle helmets that conform to ECE22.06 UA

At the time of writing, only the flip-front Schuberth Concept is certified as suitable for use with Universal accessories, but all our future helmet reviews will include details of their status.

What does the industry say?

I’ve spoken to several manufacturers of helmets and intercoms about the UA and SA certification over the past months, but – perhaps understandably given the confusion around it – few were willing to make a statement.

Cardo told me that “UCS comms (such as the LS2-4x, for example) fit UCS-ready helmets only (such as the LS2 Advant, for example), and therefore are not relevant for the UA case.

“Cardo did develop a special UA-ready cradle for its Packtalk, Freecom, and Spirit Lines (i.e. a cradle that will make all these devices 22.06 UA compatible), but did not manufacture it due to a lack of market demand.” UCS is Cardo’s own ‘Universal Communication Solution’ that if incorporated into a helmet should make it SA certified.

Jonathan Sherwood from Schuberth was the most helpful. He explained how the German company became the first helmet manufacturer in the world to offer a UA-certified helmet with its Concept…

“A key point with any certification of any product is down to how its interpreted, and we put a lot of time and effort into analysing and understanding the new legislation,” he said. “The difficulty we found is that any UA-certified device must fit onto an area of the helmet that isn’t within the designated impact testing zone, which is a very small area. It also has to be a smooth surface so the device can be stuck on, which provides a significant challenge if your helmet shell has structural forms that are not flat in that area”. He went on to explain that “Laws are enforced differently in different parts of the world. While not all countries are actively communicating or enforcing UA vs SA certifications, as a manufacturer, the laws within the EU are undoubtedly the law, and we must all make products based on the certifications that we have, regardless of how different countries might enforce those laws”.

This image from the Schuberth Concept instruction manual shows where a UA-certified intercom should be fitted

Are helmet brands just out for more money?

Buying a helmet with a Specific Accessory intercom has always been the most elegant and simple solution, and with more brands offering a choice of both Cardo and Sena now, the options are improving. With SA, you know you’re getting a fully homologated helmet that’s been proven safe, but it does restrict your choice.

It’d be easy to assume this is manufacturers trying to force you to buy their own accessories, but they – and the intercom manufacturers – certainly didn’t want this to happen. Sure, it’s potentially profitable and there’s far less hassle in trying to deal with problems created by poor user installations, but it’s not necessarily in the interest of a helmet brand to keep changing the comms units it offers with new models.

That has happened over the past few years, and it’s rightly annoyed a lot of consumers. It’s only fair though to point out that we’ve seen growth in the sale of intercoms made specifically for certain models of helmets at the same time as the tech in intercoms has had one of its most important developments: if you ride in groups, the benefits of Mesh, for instance, really can’t be understated, and that demanded a change in technology.

I asked Jonathan whether Schuberth would aim to make comms devices transferable between models: “We work very closely with people like Sena and Cardo to ensure the latest technology is in our helmets,” he told me. “We're not radio-frequency engineers or specialists in the electronics fields like our partners who are making these products, so when Sena or Cardo come to us and say ‘this is the latest advancement in  communications technology’, if the technology is right for our users, and we think consumers will love it, of course we make those changes.”

“Sometimes these new technologies do not integrate retrospectively with our historic products, but this is because new technologies can require hardware and integrations that were not available before. We would love to be able to use existing tooling, existing cabling, existing plugs etc. Doing so would save us significant costs in production and R&D. However, if new technology that improves people’s riding experience requires us to implement new hardware, we do it because we think it will improve the product experience overall.”

Helmet and intercom brands will find a way to work with this classification. Maybe we’ll see remote buttons that are placed within easier reach and the comms unit tucked out of the way to the rear. Perhaps intercoms will wrap under the neck skirt of a helmet to keep them out of the way of the testing zone, or helmets might get deeper around the base. Though if this happens, it could potentially cause interference with some airbags that inflate large bladders at the sides of the neck…

What about action cameras?

Whether or not you choose to fit an action camera to your helmet isn’t up to DJI, GoPro, Insta360 or any other manufacturer, but if they facilitate this through offering helmet mounting systems, it might start to be a problem.

Helmet-mounted cameras have been banned from track use for a long time, but riders often have them on the road for capturing their rides or as a form of dash-cam.

I asked Insta360 and DJI if they had any plans to offer Universal Accessory-certified devices, but neither had any information available.

Ultimately, it’s up to you what you do, but understanding the implications of effectively modifying a helmet is important.

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