Practical case · Safety and incident reporting
No reports. Does that mean safe operation?
A bonus for a month with no reports
A service provider operates a fully automated category M minibus for a city. It carries passengers along a predefined route with fixed start and end points. An automated driving system (ADS) performs the driving. A separate company manufactures the vehicle. We assume that the minibus ADS has been type-approved under Regulation (EU) 2022/1426.
The city wants to improve service safety. It therefore proposes adding a bonus to the contract for every month in which the provider reports no safety incidents to the city. You are asked to assess this condition before it is adopted.
A fictional teaching case. The bonus is a proposed contractual condition. The scenario does not state that an incident has occurred or been concealed.
Rule for your analysis
Regulation (EU) 2022/1426 · paraphrased
How would you revise the bonus condition to support both safety and proper reporting of problems?
Think of one change and the reason for it, then open the analysis.
Show the analysis and recommendation
What does a zero report count tell us?
It may have been an incident-free month. The same number can also result from fewer journeys, inadequate detection of events or non-reporting. We need to know the extent and conditions of operation, how events are detected and what the contract means by an incident.
Under the proposed bonus, proper reporting could mean losing a reward. This creates a problematic incentive. The existence of the bonus alone does not prove concealment or automatically make the contractual condition unlawful.
What does ADS regulation add?
These obligations are addressed to the manufacturer. The provider's contractual reporting to the city is a separate relationship. In this case, we need to establish how information about events also reaches the manufacturer and whether the bonus undermines that flow. These provisions do not require the provider to report every incident to the city immediately.
A possible recommendation to the city
Link the bonus to predefined, verifiable safety results, taking account of the extent and conditions of operation. Require complete reporting of agreed events, investigation and necessary corrective action. Properly reporting a problem should not, by itself, cause the bonus to be lost.
This is an example proposal for the contract, not a quotation from the Regulation. The indicators, verification method and access to supporting material still need to be agreed. The report count can remain one source of information if considered together with its reliability and context.
More reports can also mean better detection of problems. Without further evidence, the report count is insufficient to assess safety.