ROAT Observatory / Legal questions / 03
ROAT Legislative Tracker · Slovakia
Automated vehicles 2026
What does parliamentary print 1329 propose?
From a test facility to regular operation. The bill proposes new institutions; ROAT assesses whether they form a coherent system.
Current legislative process
Committee consideration
Checked 8 September 2026. The bill has not been adopted by Parliament or promulgated in the Collection of Laws. Its proposed rules are not enacted or effective law.
Government / Ministry of Transport · received 7 May 2026. First reading: 52nd sitting, 3 June 2026, resolution No. 1571; referral to second reading. Stage result: preparation of information on the bill.
Current process at the Slovak ParliamentAssessment cut-off
19. 7. 2026
The assessment below concerns the analysed text. Updating the procedural stage does not constitute reassessment or resolution of the issues.
01
What would change?
Nine elements proposed for Act No. 106/2018. Short paraphrases, not the wording of law in force.
Controlled testing
Testing in a secured space outside roads accessible to the public, with a report of the results.
Operator licence
A new authorisation for the operator of a fully automated vehicle, including operation and oversight conditions.
Operation approval
Under the bill, approval for passenger or goods transport services would address a vehicle type or group, ADS, ODD and operating area.
Roads and areas
The Ministry of Transport would be able to designate and publish roads or areas suitable for trials or regular operation.
Control centre
Operating documentation and a facility for technical oversight, operator identification and communication with authorities.
Operational design domain
ODD defines the conditions in which the ADS is intended to perform the dynamic driving task.
Minimum safe state
The bill would require the ability to reach a safe state even after a fault or when timely operator intervention is unavailable.
Oversight operator
A distinct human role with requirements for qualification, training and oversight from a control centre.
Data and events
Records of driving mode, interventions and safety events, accident reporting and authority access to data.
The bill also proposes amendments to Act No. 8/2009 (takeover) and Act No. 56/2012 (use of fully automated vehicles in transport services).
02
How does testing lead to operation?
A map of regulatory layers in the analysed bill. Their sequencing and legal effects are under scrutiny; this is not an authorisation checklist.
- 01
Development
Simulations, components and technical tests.
- 02
Controlled testing
Secured space outside publicly accessible roads.
- 03
Public-road trials
Public-road operation under a trial permit.
- 04
Licence
Authorisation of a fully automated vehicle operator.
- 05
Operation approval
Under section 49b for passenger or goods transport services.
- 06
Transport service
A separate layer under Act No. 56/2012.
03
10 unresolved questions
Editorial assessment of the text as of 19 July 2026. “Partly addressed” means the analysed bill already contains a foundation; it does not indicate a later amendment. Critical priority is separate from status.
Open: 9Partly addressed: 1Resolved: 0
01Who is the driver while ADS is driving?Open
8/2009: § 5 ods. 6 · 106/2018: § 2 ods. 2 písm. ak), § 49a ods. 7–8
Bill / starting framework
The bill anticipates remote takeover while defining oversight as a role without direct driving.
Why the issue remains
The transition between oversight, assistance and performance of the dynamic driving task is unclear, although their legal consequences differ.
ROAT recommendation
Separate the driver, standby driver, remote driver and oversight operator. Tie role transitions to actual takeover of the DDT and record them.
02Which driver duties remain?Open
8/2009: § 4 a navrhovaný § 5 ods. 6
Bill / starting framework
Traffic rules continue to centre on a human driver; the bill changes the duty to take over.
Why the issue remains
Compliance by the ADS is not sufficiently separated from the human’s own duties. Accident duties for an unoccupied vehicle also need clarification.
ROAT recommendation
Specify duties during ADS operation, following a valid transition demand and after takeover. Address accidents, cooperation and proof of driving mode separately.
03How will safety in real traffic be demonstrated?Critical priorityOpen
106/2018: § 49 a navrhovaný § 49a ods. 1
Bill / starting framework
The proposed licence would follow successful controlled testing and obtaining a public-road trial permit.
Why the issue remains
Obtaining a permit is not successful completion of a trial. ROAT identifies this as the main systemic gap.
ROAT recommendation
Require supervised public-road validation: predefined criteria, incident and intervention records, a final report and assessment of results before regular operation.
04What counts as successful controlled testing?Open
106/2018: navrhovaný § 48a a § 49a ods. 1
Bill / starting framework
Section 48a requires a secured space and a report; section 49a refers to successful testing.
Why the issue remains
Acceptance criteria, mandatory scenarios, eligible testers and confirmation of success are insufficiently specified.
ROAT recommendation
Establish a plan, risk analysis, scenarios and verifiable results. Reuse relevant technical evidence without unnecessarily repeating type approval.
05What does the licence assess, and what does operation approval assess?Open
106/2018: navrhované § 49a–49c · 56/2012: navrhovaný § 32a
Bill / starting framework
The bill proposes an operator licence, operation approval for transport services and permission to use the vehicle in road transport.
Why the issue remains
Vehicles, ODD and territory recur across procedures. The scope and dependencies of decisions are insufficiently separated.
ROAT recommendation
Focus the licence on organisational competence, deployment approval on vehicles, ADS, ODD and location, and transport permission on the service. Define sequencing and legal effects.
06Who is responsible for organising operation?Open
106/2018: navrhovaný § 49a ods. 6 · 56/2012: navrhovaný § 32a
Bill / starting framework
The bill would assign duties to the licence holder, oversight operator and road transport operator.
Why the issue remains
The owner, registered keeper, manufacturer, ADS provider and carrier may be different persons. A control centre is a facility, not itself a legal person.
ROAT recommendation
Assign primary public-law responsibility for organisation to the licence holder, including outsourced services. Preserve other actors’ own duties and access to safety information.
07What may an oversight operator do remotely?Open
106/2018: navrhovaný § 49a ods. 6–8, § 49d
Bill / starting framework
Oversight is provided from a control centre; the bill permits oversight of several vehicles subject to specified conditions.
Why the issue remains
Monitoring, assistance, a safety intervention and remote driving demand different capabilities. Availability, response times, capacity and simultaneous requests need clearer rules.
ROAT recommendation
Define each activity’s legal regime, handover and centre resilience. Direct driving of one vehicle must not create unsafe gaps in oversight of the others.
08What should happen when ODD conditions are lost?Partly addressed
106/2018: navrhovaný § 49e
Bill / starting framework
The bill restricts operation to the ODD and requires reaching a minimum safe state even without timely operator intervention.
Why the issue remains
The foundation exists, but approaching a boundary, loss of conditions and a fault need differentiation. A manoeuvre is a process; the safe state is its outcome.
ROAT recommendation
Clarify detection and the ADS’s independent safe response. The operator is an additional layer, not the sole safety fallback.
09Where exactly may vehicles operate?Open
106/2018: navrhovaný § 49c
Bill / starting framework
The ministry is to designate suitable roads or areas and maintain a public list.
Why the issue remains
The nature of the decision, effects of listing and approval outside the list are insufficiently defined. Suitability depends on the ADS and ODD.
ROAT recommendation
Maintain a geographic register with criteria and suspension mechanisms. Listing a road should not replace approval of a specific operation.
10What data are recorded, and who may access them?Open
106/2018: navrhované § 49d, § 49f
Bill / starting framework
The bill would impose recording and reporting duties and enables authorities to request data and explanations.
Why the issue remains
Data categories, purposes, retention, access rights and links to technical records are insufficiently distinguished.
ROAT recommendation
Separate operational, event and oversight data; align with EDR/DSSAD and ADS rules. Protect original records, audit trails, personal data and software-version traceability.
04
Who is driving right now?
The functional model recommended by ROAT. These are not four fully established statutory categories. DDT means the dynamic driving task: vehicle control and response to the traffic environment.
Driver
The human drives directly
DDT → Human inside the vehicle
Driving rules and own duties
The driver performs the DDT and complies with driving rules. The operator’s and manufacturer’s own duties remain.
Intervention and role transition
Controls direction and speed, monitors the surroundings and responds to traffic.
Standby driver
ADS drives in a mode requiring human fallback
DDT → ADS; the human is ready to take over
Driving rules and own duties
Under the recommended model, the human must remain ready and respond to a valid transition demand; not every breach during ADS driving is automatically attributed to them.
Intervention and role transition
The human performs the DDT after effective takeover. This role does not automatically apply to every fully automated vehicle.
Remote driver
Direct remote driving
DDT → Human outside the vehicle
Driving rules and own duties
The human actually performs the DDT. Specific rules are needed for qualifications, connectivity, the workstation and transition into this role.
Intervention and role transition
Drives directly; selecting a destination or authorising an ADS-proposed manoeuvre does not by itself constitute remote driving.
Oversight operator
The human oversees; ADS performs the driving task
DDT → ADS
Driving rules and own duties
The operator has their own oversight, assistance and safety-intervention duties. ADS does not become a bearer of legal liability.
Intervention and role transition
Intervention must stay within its authorised scope. If the human takes over the DDT directly, they function as a remote driver; the transition needs legal recognition and a record.
Performance of the DDT does not alone determine every form of liability. ROAT separates personal human duties, organisation of operation and technical conformity. ·
Must a vehicle have a driver? · Vienna Convention and Article 34 bis
05
When may ADS continue?
ODD is a set of conditions, not just a line on a map. Distinguish the system’s capability limits from the area and conditions authorised for operation.
Illustrative model · not an approved ODD
Urban driving, 0–50 km/h
Daylight, no snowfall, localisation available. Connectivity is a condition of this illustrative operation, not a universal requirement for all ADS.
WITHIN ODD
Illustrative conditions are met
ADS may continue in this illustration, provided it can handle the current situation and complies with authorisation conditions.
ODD / FALLBACK
A safe response takes priority
When the illustrative conditions are lost, continued driving must be brought to a safe end. Loss of connectivity must not leave the vehicle waiting solely for the operator.
- Detect boundary, loss of conditions or fault
- Minimal risk manoeuvre (MRM) · process
- Minimum safe state · outcome
“Minimum safe state” is the bill’s terminology; international sources also use MRC (minimal risk condition). Compare the scope within each source. A safe stop and its location depend on circumstances; this is not an instruction to stop immediately anywhere. ·
ODD and related terms in the glossary →
06
Licence, approval, transport service
Recommended separation by the purpose of each decision. Overlap between these layers is an unresolved issue in the bill.
Technical conformity ≠ operator competence ≠ deployment approval ≠ entitlement to provide a transport service.
· Vehicle approved. Can it go on the road?
07
Recommended ROAT model
A conceptual recommendation from ROAT, not a statement of the current authorisation procedure.
- 01
Development
Development results and identified risks.
- 02
Controlled testing
Test plan, scenarios and demonstrable results.
- 03
Supervised public-road validation
Acceptance criteria, evaluated incidents and interventions, a final report.
- 04
Licence
Verified competence to organise safe operation.
- 05
Operation approval
Specified vehicles, ADS configuration, ODD and local conditions.
- 06
Transport service
Separate compliance with requirements for a transport service, where provided.
08
ROAT assessment
Assessment of the analysed bill · 19 July 2026
A significant step. The system needs further work.
Contribution
The bill would establish necessary legal and organisational foundations for regular deployment of fully automated vehicles, including ODD, oversight, safe response and data.
Main risk
Unclear links between trials, licensing, approval and transport services may cause duplicate procedures, uncertain allocation of duties and inconsistent administrative practice.
Next step
Develop a connected, evidence-based and risk-proportionate system with clear roles, legal effects of decisions, change management, supervision and proportionate sanctions.
Legislative process
- 7. 5. 2026Received by Parliament
- 3. 6. 2026First reading · resolution 1571
- 8. 9. 2026Verified status: committee consideration
- 11. 9. 2026Deadline: economic affairs and constitutional committees
- 14. 9. 2026Deadline: lead economic affairs committee
- Possible subsequent stagesSecond and third readings, outcome, possible promulgation and entry into force. Not yet confirmed.
Deadlines do not confirm that deliberations occurred or that the bill was adopted. Source: Slovak Parliament
Sources and assessment history
- Parliament: submitted text of print 1329 · process status .
- Related explanation: Vienna Convention, Articles 8, 13 and 34 bistechnical approval and operation.
8. 9. 2026: Assessment of the text as of 19 July 2026 and separate verification of the legislative process. Issue statuses will require substantive comparison with new text; the page does not update automatically.