The UK government has launched a comprehensive 'call for evidence' on the regulatory framework for automated vehicles (AVs), emphasizing safety and ongoing in-use compliance. This initiative, open for responses until March 2026, is a significant step towards ensuring AVs are safe and legally compliant before they hit the roads.
The document, spanning 79 pages and posing 125 questions, delves into two critical chapters: 'Getting AVs on the Road' and 'Once AVs Are on the Road'. Each chapter addresses essential aspects of AV deployment, from technical standards and authorization requirements to user responsibilities and incident investigation.
Chapter 1: Getting AVs on the Road
- Type Approval: AVs must adhere to technical and safety standards aligned with international regulations (UNECE).
- Authorisation Requirements: Each AV needs an Authorised Self-Driving Entity (ASDE) responsible for safety and regulatory compliance throughout its lifecycle.
- User-in-Charge (UIC): Defines the responsibilities of the 'disengaged driver' during AV operation, including transition demands and training.
- No-User-in-Charge (NUIC) Licensing: Conditions for operators running passenger services without onboard safety 'drivers', applicable to fully autonomous buses and pod-style vehicles.
- Insurance and Data Access: Motor insurers must cover both conventional and automated driving. The focus is on data access from the Automated Driving System (ADS) for claims adjusting and subrogated actions.
Chapter 2: Once AVs Are on the Road
- In-Use Regulatory Scheme (IURS): Ongoing oversight and compliance monitoring for the ADS, with the keeper responsible for roadworthiness. Civil and regulatory sanctions will be enforced.
- Incident Investigation: Independent statutory inspectors will investigate AV-related incidents under a no-blame framework to enhance road safety, modeled after existing rail and maritime investigation branches.
- Cyber Security: Requirements will align with UN Regulations 155 and 156, addressing risks from connectivity and remote operations. The current ecosystem already faces potential systemic cyber risks, though their full understanding remains a challenge.
- Accessibility & Environment: Seeking evidence on inclusive design and environmental impacts, including end-of-life considerations.
Looking Ahead
The call for evidence invites responses from industry stakeholders, academics, road users, and accessibility groups, shaping future regulations for safe, equitable, and sustainable AV deployment. The government's 'main regs' for automated driving will be developed under the Automated Vehicle Act 2024.
The timeline envisions the call for evidence concluding by the end of 2025, followed by a consultation on draft provisions in the second half of 2026. This approach aims to balance insurer interests, commercial confidentiality, and data protection principles, particularly regarding data access for insurers.
This summary provides an overview, and further articles will delve into the detailed aspects of the chapters. For more information, contact the authors or your Clyde & Co representatives.
