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Safety and its demonstration

Compare safety evidence requirements and follow sources on technical approval and operation.

Answers from the practical comparison · selected sources checked on 7 September 2026 · Working research overview · targeted review of provisions

Slovakia

Scope: Testing route + specific delivery vehicles

Who bears operational duties?

The applicant ensures the technical, staffing and organisational prerequisites. The permit holder is responsible for fulfilling operational duties and testing conditions.

Review scope and open issues

The reference to § 49 has been updated following the amendment effective from 1 September 2026. The finding that a general route is absent is limited to the provisions checked and the status of parliamentary bill 1329. The guide does not cover the entire implementing legislation, all road traffic rules or individual permits.

Germany

Scope: Autonomous vehicle in an approved area

What safety evidence is needed?

Safe performance of driving and risk management must be demonstrated; the area must have appropriate suitability, infrastructure and staffing. For testing, AFGBV requires a development concept, a description of changes, supervision and the ability to deactivate and intervene on site.

Who bears operational duties?

The Halter ensures safety, maintenance and performance of technical supervision tasks. Manufacturers have separate duties concerning risks, cybersecurity, documentation and training.

Review scope and open issues

Compared with the original snapshot, the alternative of European type approval in the current § 1e(1), point 2, is clarified. Permanent supervision during testing remains distinct from ordinary autonomous operation. The relationship between the current StVG and AFGBV procedural requirements must be resolved for an individual application; this comparison does not treat it as settled.

France

Scope: Testing + automated passenger transport system

Review scope and open issues

The testing regime was checked in the consolidated text as of 7 September 2026, including the 2020 amendment. The operational branch is limited to passenger transport. The current text of R3152-3 was confirmed directly on Légifrance. This review concerns specific provisions; freight transport, full civil liability and all implementing requirements remain outside its scope.

Great Britain

Scope: Testing with a driver + driverless pilot + APS

What safety evidence is needed?

For testing, the guidance expects an appropriate safety case. Pilot guidance requires a documented safety case, a safety management system and evidence of operator capability.

These are guidance and assessment requirements; legally binding restrictions for a specific journey must be read in the VSO and APS permit.

Who bears operational duties?

The trialling organisation ensures test safety. Pilot guidance separately considers the operator; the APS holder fulfils service conditions. One or several persons may perform these roles.

The relevant national authority has power to grant APS permits. SI 2026/439 governs the Secretary of State’s competence only within its material and territorial scope.

Review scope and open issues

The transitional nature of the framework is retained. Driverless pilots, testing with a driver and passenger service permits are distinguished. Earlier guidance describing planned APS commencement is read against the adopted SI 2026/437 and 439. Individual VSOs, specific permits and full civil liability remain outside the review.

Articles and studies on this topic →

Related sources

A thematic selection from the public library. It includes published research register data and ROAT editorial additions; it is not a complete inventory of the law in this area.

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