Regulatory objectAPS permit holder and pilot-operator architecture as the 2026 transitional route; authorised self-driving vehicle / responsible-entity architecture enacted but not yet commencedTechnical approval baselineUK vehicle approval/self-driving authorisation architecture under AV Act implementation programmeAdditional deployment / road-use gateAutomated 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 snapshotODD / operating-area legalisationDeployment area fixed through APS permit and pilot conditions; authorised domain under Part 1 of the AV Act not yet in forceCompetent authority / decision makerSecretary of State / DVSA and relevant local transport authority for APS consentPrimary accountable organisational actorAPS permit holder / pilot operator; ASDE and NUiC-operator architecture in Part 1 of the AV Act not yet in forceRemote human roleNo German-style technical supervisor as universal core role; remote functions depend on operating modelDDT / fallback allocationAuthorised ADS performs self-driving task; user-in-charge duties are separated where relevantTraffic-offence allocationNo 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 infractionsCivil liability / insuranceDedicated: 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 pendingData / loggingReporting under APS permit conditions and pilot conditions (collisions, infractions); information duties of Part 1 of the AV Act not yet in forcePost-market / in-use oversightOversight through APS permit monitoring and pilot conditions; in-use regulation under Part 1 planned for full implementationMaterial change / software updateAPS 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 commencedRetesting / revalidationPermit-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 2027Commercial service pathwayAPS permit enables staged commercial passenger deployment in 2026Dominant deployment modelStaged-permit model (APS permits and pilots ahead of Part 1 authorisation)Legal statusPartly in force: Part 5 (APS permits) from 15 May 2026; Part 1 authorisation and Part 4 marketing restrictions commence in 2027Primary-source anchorAutomated 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 programmePrimary current-law rationaleUK is a control case showing that actor/institution design can legally precede full ordinary deployment.ConfidenceHigh