| Regulatory objectOdlišná odpoveď | Autonomous vehicle + approved defined operating area + keeper + technical supervision | Automated road transport system: vehicle + technical system + route/zone + service organisation | Fully automated vehicle + owner + operating area + transport service + remote intervention arrangements | APS permit holder and pilot-operator architecture as the 2026 transitional route; authorised self-driving vehicle / responsible-entity architecture enacted but not yet commenced | Conditionally admitted L3 vehicle + designated user entity + specified roads/speeds + road-access pilot | Autonomous vehicle/ADS + manufacturer/importer + road-use accountability layer | EU-approved vehicle + national test-operation / narrower operational exceptions | Licensed FAV operator + approved operation + control centre + supervision operator + ODD |
|---|
| Technical approval baselineOdlišná odpoveď | EU/UNECE technical baseline plus German autonomous-vehicle operating permit under StVG/AFGBV | EU type approval / relevant vehicle technical approval | EU ADS type approval | UK vehicle approval/self-driving authorisation architecture under AV Act implementation programme | Conditional product admission; GB 44721-2026 adopted but effective from 1 July 2027 | Road-traffic-rule conformity test + technical/product admission; GB 44721-2026 technical pillar | EU/UNECE type-approval framework can provide high technical maturity | EU/UNECE technical approval remains baseline |
|---|
| Additional deployment / road-use gateOdlišná odpoveď | Vehicle operating permit + authority approval of defined operating area + registration before autonomous road use | Prior system safety demonstration + qualified independent opinions + formal mise-en-service decision | Dedicated road-traffic rules plus mandatory real-world service validation before passenger-service deployment | Automated Passenger Service permit under Part 5 of the AV Act 2024 (in force 15 May 2026) for eligible passenger services; other deployments run as pilots under vehicle special orders; Part 1 authorisation not yet commenced at snapshot | Product admission is followed by geographically/functionally limited road-access pilot rather than unrestricted deployment | Registered AV may activate ADS only within design operating conditions; national road-use rules sit above technical conformity | Predominantly § 49 test-operation permit; the only non-test deployment gate is the operational permit for automated delivery vehicles under § 52 of Act 106/2018; no general dedicated commercial FAV deployment gate | Operator licence + specific operation approval would create a genuine second gate |
|---|
| ODD / operating-area legalisationOdlišná odpoveď | ODD is translated into a geographically defined and authority-approved 'festgelegter Betriebsbereich' | Safety case is tied to intended route or zone and service configuration | Operating area / territory forms part of deployment validation and service conditions | Deployment area fixed through APS permit and pilot conditions; authorised domain under Part 1 of the AV Act not yet in force | Specified road segments, speed limits and operating conditions function as legally bounded ODD/geofence | Manufacturer/importer must ensure ADS cannot activate outside design operating conditions | ODD reflected in permit/test conditions; for automated delivery vehicles the operational permit fixes territory, route and time (§ 52(6)); not yet a general autonomous-operation authorisation object | ODD and defined roads/territory become part of operational documentation / approval |
|---|
| Competent authority / decision makerOdlišná odpoveď | KBA / competent road authority depending on decision layer | Service organiser / competent transport and road authorities within statutory framework | Transport/road authorities; licensing authority under national transport framework | Secretary of State / DVSA and relevant local transport authority for APS consent | MIIT and participating local authorities under pilot framework | Public-security / product / transport authorities under State Council allocation | Ministry of Transport / road and police authorities depending on permit | Ministry of Transport with police/other authority inputs |
|---|
| Primary accountable organisational actorOdlišná odpoveď | Halter (vehicle keeper), with manufacturer duties and Technische Aufsicht functions separately allocated | Automated transport-system/service operator architecture rather than vehicle owner alone | Vehicle owner is a central road-traffic accountability actor; service operator duties exist at transport layer | APS permit holder / pilot operator; ASDE and NUiC-operator architecture in Part 1 of the AV Act not yet in force | Designated user entity + manufacturer within monitored pilot architecture | Manufacturer/importer becomes direct central accountability actor for ADS-active traffic violations | Permit holder / owner / driver-type roles; operator holding an operational permit for automated delivery vehicles (§ 52); no general licensed FAV operator architecture in force | Licensed FAV operator becomes organisational centre of responsibility |
|---|
| Remote human roleOdlišná odpoveď | Technische Aufsicht – may deactivate and release specified manoeuvres; not ordinary continuous remote driving | Qualified remote intervention personnel integrated into system operation | Remote intervention role recognised; boundaries and concurrency remain implementation questions | No German-style technical supervisor as universal core role; remote functions depend on operating model | No mature national standalone technical-supervisor/remote-operator role architecture yet | Remote human role remains underdeveloped in the draft | No general commercial FAV technical-supervision/control-centre role in force; supervising driver (dohliadajúci vodič) with remote takeover for automated delivery vehicles (Act 8/2009 § 2(2)(w), § 5(6)) | Operátor dohľadu + riadiace centrum; current draft boundary with remote driving needs correction |
|---|
| DDT / fallback allocationOdlišná odpoveď | ADS performs DDT; system must comply with road rules and achieve minimum-risk condition where necessary | ADS performs DDT; remote intervention supports defined situations without collapsing into ordinary remote driving | ADS performs driverless operation; remote intervention supports defined operational/safety functions | Authorised ADS performs self-driving task; user-in-charge duties are separated where relevant | L3 ADS performs DDT within approved conditions; human fallback remains relevant to L3 design | ADS continuously performs full DDT within design operating conditions; L2 assistance is expressly distinguished | Current framework remains structurally driver/test oriented; dedicated driverless DDT allocation is incomplete | ADS should remain DDT performer; current wording risks transferring DDT remotely to supervisor in some clauses |
|---|
| Traffic-offence allocationOdlišná odpoveď | Dedicated AV behavioural architecture; legal duties are distributed among ADS framework, keeper and supervisor rather than simply retained by an onboard driver | Dedicated criminal-responsibility adaptations exist; detailed allocation depends on operating mode and legal actor | Owner bears dedicated responsibility for traffic offences of fully automated vehicle in driverless operation | No general rule in force at snapshot: Part 1 reallocation of legal responsibility away from the user not yet commenced; pilot and permit conditions require reporting of infractions | Current pilot arrangements do not yet equal the proposed national manufacturer-centric offence rule | Manufacturer/importer 'accepts handling' for violation while ADS active and bears burden of proof if claiming it was unrelated to ADS | No complete general rule for traffic offences committed by driverless FAV | Still requires explicit rule for offences committed by FAV while ADS is active |
|---|
| Civil liability / insuranceOdlišná odpoveď | General StVG keeper-liability / insurance architecture remains central; not wholly replaced by AV-specific civil liability | Compulsory insurance/general civil-liability rules supplemented by dedicated automated-driving responsibility provisions; civil layer less comprehensive than deployment layer | Traffic-offence allocation is clear; broader AV-specific civil-liability architecture is less complete | Dedicated: Automated and Electric Vehicles Act 2018 s. 2 makes the insurer liable for accidents caused by a listed automated vehicle driving itself; AV Act 2024 insurance and liability provisions pending | Existing compulsory insurance/general rules apply; national AV-specific insurance provisions are proposed, not yet enacted | Compulsory motor-vehicle liability insurance required; commercial insurance encouraged; detailed regime delegated | General motor insurance/civil liability; no mature FAV-specific allocation | Insurance/organisational requirements improve, but full civil/product/service allocation remains to be clarified |
|---|
| Data / loggingOdlišná odpoveď | Statutory event/data duties; AFGBV data-storage requirements | System/event recording and safety-management evidence required | Strong telemetry/event-data access and video-surveillance duties | Reporting under APS permit conditions and pilot conditions (collisions, infractions); information duties of Part 1 of the AV Act not yet in force | Pilot monitoring and safety evidence required | Strong accident evidence/data duties and manufacturer data-provision obligations | Test-operation documentation and technical rules; supervision log and permit-conditioned operational data for automated delivery vehicles (Act 8/2009 § 6(7); Act 106/2018 § 52(6)–(7)); no general FAV logging architecture equivalent to CPT 1329 | Dedicated recording system proposed |
|---|
| Post-market / in-use oversightOdlišná odpoveď | KBA/authority market surveillance and permit supervision | In-use system safety management and authority oversight tied to service operation | Service/deployment oversight, incident management and licence conditions | Oversight through APS permit monitoring and pilot conditions; in-use regulation under Part 1 planned for full implementation | Government monitoring and conditional product/road-access controls | National road-safety risk assessment can support suspension/prohibition, recall, repair, replacement/refund/compensation measures | Primarily permit/test supervision rather than mature in-use driverless market oversight | Operator/licence supervision and operational duties create stronger in-use layer |
|---|
| Material change / software updateOdlišná odpoveď | AFGBV § 4(5) expressly requires KBA approval before post-permit changes to an autonomous vehicle are used; § 6 allows withdrawal/suspension of the vehicle operating permit where approval conditions cease to be met. | Code des transports R3151-1 defines a substantial modification as one that changes the safety assessment; R3152-18 requires notification and, for a substantially modified system, suspension of operation. | Partial change-control only: a new special-conditions certificate is required within 15 days if certificate data change; general testing applies to converted/modified vehicle hardware under Road Safety Act Art 276. | APS Regulations 2026 treat a material change in circumstances as a ground for permit variation, suspension or withdrawal; AV Act ss 5, 8 and 9 authorisation powers not yet commenced | Pilot/product approval is version- and condition-sensitive; exact general change-control rule is still evolving | Unauthorised ADS modification prohibited and sanctioned; post-market risk layer is explicit | Handled through technical approval/test permit changes; no general deployment change-control regime | Draft requires clearer material-change / software-version triggers |
|---|
| Retesting / revalidationOdlišná odpoveď | Explicit lifecycle control: KBA approval for vehicle changes; suspension/withdrawal pending clarification under § 6; operating-area approval can be suspended/withdrawn under § 10 when safety assumptions or infrastructure conditions cease to hold. | Explicit re-commissioning: after a substantial modification the organiser suspends operation and a new mise-en-service decision is taken under R3152-10 to R3152-12; R3152-11 applies to new or substantially modified systems. | No equally explicit rule located that a material ADS/ODD/software/service change automatically re-triggers the Art 13b–13d real-world service-validation procedure. Serious incidents can trigger temporary prohibition of a FAV type under Art 290a. | Permit-level: variation, suspension or withdrawal of an APS permit or pilot on breach or incident; general authorisation lifecycle under Part 1 remains implementation-stage through 2027 | Road-access pilots and reassessment provide staged evidence before expansion | Implementing rules still required; change/revalidation mechanics not fully specified | Retesting tied mainly to test-operation context | Local validation/testing is structurally present but should be proportionate and recognise existing type-approval/foreign evidence |
|---|
| Commercial service pathwayOdlišná odpoveď | Possible within approved operating area and applicable transport/service law | Yes. Passenger automated-road-transport-system pathway extended to automated road freight by Décret 2024-1063, effective 28 Nov 2024. | Yes, through transport licensing after service-level real-world validation | APS permit enables staged commercial passenger deployment in 2026 | Limited pilot deployment; not unrestricted nationwide commercial L3 operation | Supports ordinary national road operation once enacted and implementing rules exist | No general pathway from EU type approval to ordinary commercial driverless operation; goods delivery by automated delivery vehicles is the only permitted service use (Act 8/2009 § 55b; Act 106/2018 § 52) | Potential general commercial pathway if enacted and separated from test-only logic |
|---|
| Dominant deployment modelOdlišná odpoveď | Operating-area + technical-supervision model | System/service safety-assurance model | Owner-centred deployment-validation model | Staged-permit model (APS permits and pilots ahead of Part 1 authorisation) | Manufacturer/user-entity conditional deployment model | Manufacturer-centred road-use and enforcement model | Testing-permit / technical-leading model | Licensed-operator + control-centre deployment model |
|---|
| Legal statusOdlišná odpoveď | In force | In force | In force | Partly in force: Part 5 (APS permits) from 15 May 2026; Part 1 authorisation and Part 4 marketing restrictions commence in 2027 | In force as pilot / conditional admission architecture | Draft / public consultation | In force | Draft / parliamentary print 1329 |
|---|
| Primary-source anchorOdlišná odpoveď | StVG §§ 1d–1g; AFGBV §§ 4, 7–11, 13–14 | Ordonnance 2021-443; Décret 2021-873; Code des transports R3151/R3152; Décret 2024-1063 / R3251–R3253 | NN 145/2024 Arts 281a–281f; NN 154/2024 Arts 13b–13d / Art 51a framework | Automated Vehicles Act 2024 and Commencement No. 1–3 Regulations (SI 2025/1339, 2026/437, 2026/731); SI 2026/439; AEVA 2018 s. 2; DfT implementation programme | MIIT conditional L3 approvals of 15 Dec 2025; GB 44721-2026 | Road Traffic Safety Law revision draft Arts 95–103 | Act 106/2018 §§ 49, 52; Act 8/2009 §§ 2, 5, 6, 55b; Decree 131/2018; Act 131/2026 effective 1 Sep 2026 only prospectively at snapshot | CPT 1329 §§ 49a–49f and related amendments |
|---|
| Evidence and sources | | | | | | | | |
|---|
