The regulatory journey · ROAT Observatory

The regulatory journey draft

Testing, approval, deployment and in-use oversight, and where the law changes hands. Position as of 2026-08-27.

Nine stages take an automated driving system from safety engineering to incident response. The function column marks whether a stage answers a type-approval question or an operational one. The break between stage 5 and stage 6 is the Second Gate: technical approval ends there and a separate legal permission to operate begins.

Research, development and safety engineering

type approval International and standards

Key instruments: ISO 26262; ISO 21448; ISO/SAE 21434
Main actors: Manufacturer and automated driving system developer
Regulatory question: Safety architecture, safety of the intended functionality, cybersecurity, data governance
Why it matters: Evidence starts here

Closed-track and scenario testing

type approval UNECE, EU and standards

Key instruments: NATM; ADS GTR; Regulation (EU) 2022/1426; ISO 34503
Main actors: Manufacturer; technical service
Regulatory question: Scenario coverage, credibility of simulation, controlled validation
Why it matters: Feeds the safety case

Public-road trial authorisation

operation National

Key instruments: Slovakia § 49; UK trialling framework; Croatian service testing
Main actors: Ministry, road authority, police
Regulatory question: Permit, operational design domain, route, safety operator, incident plan
Why it matters: National law governs access to roads

Safety case and conformity assessment

type approval UNECE and EU

Key instruments: UN ADS Regulation; ADS GTR; Regulation (EU) 2022/1426 with JRC guidance
Main actors: Manufacturer; technical service; approval authority
Regulatory question: Audit, safety case, track, simulation and real-world evidence
Why it matters: The technical approval threshold

Vehicle and system type approval

type approval UNECE and EU

Key instruments: UN Regulations; Regulation (EU) 2018/858; 2019/2144; 2022/1426; 2026/481
Main actors: Type-approval authority
Regulatory question: Approval of the vehicle and system against technical rules
Why it matters: Type approval is not permission to run a road service

Second Gate — technical approval ends, legal permission to operate begins

Operational authorisation and deployment

operation National

Key instruments: UK Automated Vehicles Act; German StVG and AFGBV; French STRA; the Croatian framework. In Slovakia the only non-test deployment gate today is the § 52 operational permit for automated delivery vehicles, with a general regime still in the print 1329 reform
Main actors: National or local operational authority
Regulatory question: Operating area, operator, remote support, service conditions
Why it matters: A separate operational gate

Commercial passenger or goods service

operation National and sectoral

Key instruments: Automated passenger service rules; road transport law; insurance; consumer and accessibility rules
Main actors: Service regulator; operator
Regulatory question: Service licence, insurance, accessibility, marketing
Why it matters: The commercial deployment layer

In-use monitoring and software change

approval and operation UNECE, EU and national

Key instruments: Regulation (EU) 2022/1426 in-service monitoring; UN R155 and R156; NHTSA standing general order
Main actors: Manufacturer; operator; surveillance authority
Regulatory question: Occurrence reporting, software updates, maintenance, performance
Why it matters: Continuous compliance

Incident response and corrective action

approval and operation National, EU and UNECE

Key instruments: Event data recording; eCall; incident reporting; market surveillance
Main actors: Police; emergency services; investigators; approval authority
Regulatory question: Investigation, data access, recall or withdrawal, lessons learned
Why it matters: Closes the feedback loop

Provenance

ROAT Regulatory Map 2026 – Reconstructed Draft v0.7.1 (PraF UK), sheet "Regulatory Journey v0.3", cut-off 2026-08-27. Conceptual bridge between type approval and road or service operation. Module 02 codes what actually stands at the operational gate in eight regimes.