Automated vehicles 2026 / Original bill and comparison
Historical context · parliamentary print 1329
Original bill and legislative development
Analysis of the original bill as of 19 July 2026 and comparison with the text adopted on 16 September 2026.
Update · 16 September 2026 · adopted amendments
How has the assessment of the original ten issues changed?
The adopted bill clarifies the legal status of drivers and oversight operators, authorisation conditions, operator duties and the data regime. The following comparison assesses the extent to which these changes address concerns identified in the original bill.
The adopted amendments partly develop six of the ten assessed areas. In four, the core July concerns remain unchanged. This is ROAT’s substantive assessment: adopting an amendment does not by itself fully resolve the entire legal issue.
01Who is the driver while ADS is driving?Partial solution adopted
Joint report / items and provisions: 1 · § 2(2)(x), § 3(4–5), § 5(6), 8/2009 [3]
Content of the adopted amendment
The adopted text expressly distinguishes the driver from the oversight operator. A driver includes a person driving directly or remotely and an occupant who activated the ADS (automated driving system) being used for driving. Under the new rules, a moving vehicle must have a driver or an oversight operator.
ROAT assessment: what remains open
The distinction responds to the July concern. Oversight, remote assistance and actual driving still need precise boundaries and an identifiable, recorded transition. Activating the ADS is not the same as continuously performing the driving task.
02Which driver duties remain?Partial solution adopted
Joint report / items and provisions: 1 · § 3(5), § 4(1)(c), § 5(6), 8/2009 [3]
Content of the adopted amendment
Adopted section 3(5) requires the oversight operator to comply correspondingly with driver duties under section 4. During ADS driving, the driver may undertake other activities that do not prevent timely and safe takeover. The person who activated the ADS must take over on request or, if circumstances require it, without a request, including remotely where appropriate.
ROAT assessment: what remains open
This is not a general exemption from driver duties. Corresponding application leaves open which specific duties the operator performs and how. Duties after an unoccupied vehicle crashes and the relationship between takeover duties and the capabilities of the particular ADS need further work.
03How will safety in real traffic be demonstrated?Core concern unchanged
Joint report / items and provisions: 7–9 · § 49a(4–6), 106/2018; § 49a(1) [3]
Content of the adopted amendment
Items 7–9 amend licence refusal following earlier revocation, guidance and operator duties. They do not amend section 49a(1): obtaining a public-road trial permit remains different from actually completing and successfully evaluating those trials.
ROAT assessment: what remains open
The critical July concern remains open. Periodic safety reports do not replace an express requirement for evidence from successful public-road trials before licensing.
04What counts as successful controlled testing?Core concern unchanged
Joint report / items and provisions: 12 · § 136(3)(l); § 48a, 106/2018 [3]
Content of the adopted amendment
The adopted amendments do not amend controlled testing under section 48a. Item 12 changes the fourth limb of the implementing-power provision to cover safety-report particulars. The existing power to specify controlled-testing report particulars remains.
ROAT assessment: what remains open
It would be incorrect to say the bill provides neither a report nor implementing rules. The adequacy of success criteria, scenarios, the verifying party and confirmation of results remains open.
05What does the licence assess, and what does operation approval assess?Partial solution adopted
Joint report / items and provisions: 3–5 · § 32a(2–4), 56/2012; 7 · § 49a(4), 106/2018 [3]
Content of the adopted amendment
The adopted amendment to section 32a(3) requires permission to be granted when the statutory conditions are met. It makes EU-law references more specific. Section 49a(4) limits the licensing bar following revocation for specified reasons to the three years preceding the application.
ROAT assessment: what remains open
These changes improve individual conditions but do not fully define the relationship between the section 49a licence, section 49b operation approval and section 32a transport permission. A footnote referring to Articles 39 and 41 of Regulation 2018/858 does not itself establish an applicable exemption or EU-law compliance of the entire system.
06Who is responsible for organising operation?Partial solution adopted
Joint report / items and provisions: 6, 8–9, 12–15 · § 32a(5), 56/2012; § 49a, § 136, § 148, § 150, 106/2018 [3]
Content of the adopted amendment
The adopted items add continuing cooperation, operator guidance and safety reports at intervals specified in the licence. A cyber incident that affected or could have affected operational safety must be notified to the Ministry of Transport within 24 hours. A routine ADS update without an effect on safety or ODD (operational design domain) is notified through updated documentation within 15 days of implementation. Penalties are added, including for operation without section 49b approval.
ROAT assessment: what remains open
These are more specific duties and enforcement measures, not a complete allocation of responsibility among the licence holder, carrier, centre, manufacturer and ADS provider. Organisational responsibility when outsourcing and the treatment of updates affecting safety or ODD remain open.
07What may an oversight operator do remotely?Partial solution adopted
Joint report / items and provisions: 1 · § 3(5), 8/2009; 10 · § 49f(5)(c), 106/2018 [3]
Content of the adopted amendment
Adopted section 3(5) permits an operator who has taken over driving to drive only one vehicle at a time and prohibits simultaneous oversight of another. New section 49f(5)(c) covers oversight data, all centre commands and the operator’s response time.
ROAT assessment: what remains open
The concurrency prohibition directly addresses one concern. It does not specify who takes over oversight of the other vehicles, centre capacity for simultaneous requests or permissible response times. Recording response time does not establish a safe response-time limit.
08What should happen when ODD conditions are lost?Core concern unchanged
Joint report / items and provisions: 9 · § 49a(6)(k); § 49e, 106/2018 [3]
Content of the adopted amendment
Item 9 distinguishes routine updates with no effect on safety or ODD but does not amend section 49e. The foundation for restricting operation to the ODD and reaching a safe state already existed in the original bill.
ROAT assessment: what remains open
The July “partly addressed” label remains historically accurate; the adopted amendments do not newly resolve the issue. The ODD boundary, departure from it and a fault need distinguishing, as do the manoeuvre used to reach a safe state and the resulting state.
09Where exactly may vehicles operate?Core concern unchanged
Joint report / items and provisions: § 49c, 106/2018 · bez priamej zmeny / no direct amendment [3]
Content of the adopted amendment
The adopted amendments do not amend section 49c on designating and publishing suitable roads or areas. Changes to section 32a transport permission do not themselves change the legal effect of that list.
ROAT assessment: what remains open
The relationship between listing and an individual permission, operation outside listed areas, and suitability for a particular ADS and its ODD still need clarification.
10What data are recorded, and who may access them?Partial solution adopted
Joint report / items and provisions: 10, 12–15 · § 49f, § 136, § 148, § 150, 106/2018 [3]
Content of the adopted amendment
Adopted section 49f distinguishes telemetry throughout the journey, an event record covering 30 seconds before a safety event and 10 seconds after it, and oversight data including commands and response time. Operational data are retained for 30 days after the journey and event and oversight data for two years, extended until final conclusion of administrative or criminal proceedings that have begun. Each record must be traceable to the active ADS version. The rules address integrity, machine-readable provision to the ministry and anonymisation of third-party camera records for regulatory supervision, except where identification is necessary to clarify an accident or safety event.
ROAT assessment: what remains open
This is a substantial addition, not confirmation that the entire data regime is proportionate. Necessary telemetry scope and preservation for civil disputes need assessment. Compared with original section 49f(3–4), express references to the Police Force and accident investigation are removed; this does not establish repeal of powers under other laws. The relationship with EDR (event data recorder)/DSSAD (data storage system for automated driving) and purposes of individual access rights need further work.
The comparison draws on the analysis of the original bill as of 19 July 2026. The English version is ROAT’s translation and interpretation, not an official translation.
01
July analysis: the original 10 issues
ROAT assessment of the text as of 19 July 2026. “What needs further work” briefly summarises ROAT recommendations. “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: section 5(6) · 106/2018: section 2(2)(ak), section 49a(7)–(8)
What needs further work
Clearly define the transition from oversight to direct driving and how it is recorded.
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: section 4 and proposed section 5(6)
What needs further work
Allocate human duties during ADS driving, takeover and an accident involving an unoccupied vehicle.
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: section 49 and proposed section 49a(1)
What needs further work
Link licensing to evidence of successful completion and evaluation of public-road trials.
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: proposed section 48a and section 49a(1)
What needs further work
Specify testing success criteria, mandatory scenarios and how results are confirmed.
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: proposed sections 49a–49c · 56/2012: proposed section 32a
What needs further work
Separate the scope, sequence and legal effects of licensing, operation approval and transport-service permission.
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: proposed section 49a(6) · 56/2012: proposed section 32a
What needs further work
Define the licence holder’s responsibility for organising operation, including outsourced services.
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: proposed section 49a(6)–(8), section 49d
What needs further work
Clarify intervention limits, response times and oversight capacity for simultaneous requests from several vehicles.
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: proposed section 49e
What needs further work
Distinguish an ODD boundary, loss of operating conditions and a fault, and define an independent safe ADS response.
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: proposed section 49c
What needs further work
Clarify the legal effect of listing a road and its relationship to approval of a specific operation.
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: proposed sections 49d and 49f
What needs further work
Specify data categories, purposes, retention periods and access rights, linked to technical records.
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.
02
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 in time 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
03
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 →
04
Licence, approval, transport service
Recommended separation by the purpose of each decision. The relationship between individual authorisations remains an unresolved issue in the adopted bill.
Technical conformity ≠ operator competence ≠ deployment approval ≠ entitlement to provide a transport service.
· Vehicle approved. Can it go on the road?
05
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.
Legislative history of print 1329
- 7. 5. 2026Bill received by Parliament.
- 3. 6. 2026First reading · resolution No. 1571, referral to second reading.
- 9. 9. 2026Constitutional committee · resolution No. 497 with amendments.
- 14. 9. 2026Economic affairs committee · resolution No. 287; joint report 1329a approved by resolution No. 302.
- 16. 9. 2026Parliament adopted the bill incorporating the approved amendments.
- PromulgationNot yet confirmed in the checked sources.
- 1. 12. 2026Proposed commencement of the Act.
Legislative sources
Adopted changes to the original bill
Adopted amendments
| Item | Affected provision | Adopted change and significance |
|---|---|---|
| 1 | Art. I · 8/2009 | Entire article replaced: driver and oversight roles, other activities during ADS driving, takeover and a penalty for record duties under section 6(6–7). |
| 2 | Art. II · 4a | The driver-definition reference changes from (w) to (x) following Act No. 131/2026. |
| 3 | Art. II · § 32a, 46j | More specific reference to Articles 39 and 41 of Regulation 2018/858; applicability of an exemption requires separate assessment. |
| 4 | Art. II · § 32a, 46k | More specific reference to Articles 4(3) and 12 of Regulation 1073/2009 concerning passenger-transport documents. |
| 5 | Art. II · § 32a subsection 3 | The authority must grant permission when specified conditions are met; an application remains necessary. |
| 6 | Art. II · § 32a subsection 5 | The transport manager must provide ongoing cooperation, rather than a one-off act. |
| 7 | Art. III · § 49a subsection 4 | Refusal following revocation for specified reasons is limited to the three years preceding the application. |
| 8 | Art. III · § 49a subsection 5 | The ministry may guide the operator in complying with licence conditions. |
| 9 | Art. III · § 49a subsection 6 | Periodic safety reports, relevant cyber incidents within 24 hours and documentation of routine ADS updates within 15 days of implementation. |
| 10 | Art. III · § 49f | Entire section replaced: records, ministry notification, data categories, integrity, ADS version, retention, access and personal-data safeguards. |
| 11 | Art. III · § 49a subsection 10 | Footnote and reference 48a become 48b. The dangerous-goods transport prohibition remains. |
| 12 | Art. III · § 136 subsection 3 letter l) | The fourth implementing-power limb now covers safety-report particulars. Data rules are addressed directly in section 49f. |
| 13 | Art. III · § 148 subsection 10 | Penalty coverage extended to data integrity, retention and provision, and operation without required approval. |
| 14 | Art. III · item 12, § 148 | Internal reference corrected to subsection 14 following insertion of a new subsection. |
| 15 | Art. III · § 150 | Procedural fine for failure to provide documentation and explanations needed for supervision under section 49f(4). |
| 16 | Commencement | Proposed commencement on 1 December 2026, replacing the originally proposed date of 1 November 2026. |
Legislative drafting note: item 16 of the joint report refers to Article V, while the submitted bill places commencement in Article IV. The substance of the adopted change specifies 1 December 2026.[3][4]