Modules › Human roles › 2026-09-05

Module 03 · ROAT-MOD-ROLES

Human roles in automated driving draft snapshot

Name: Human roles in automated driving — snapshot 2026-09-05
Creator: Jozef Andraško
License: https://creativecommons.org/licenses/by/4.0/

Which human and organisational roles do automated-driving frameworks recognise, which driving and safety functions does each perform, and which must not be conflated?

Snapshot 2026-09-05 (frozen)Rows 20Coder JADOI not yet mintedSource dataset Role Function Matrixdata.csv · data.json

This snapshot has been superseded by snapshot 2026-09-06 (27 cells recoded). It stays addressable and citable as published.

The failure mode this module exists to prevent is collapsing distinct functions into one generic "operator". Each row is one role as a framework defines it; each column is one function it may or may not perform. Remote assistance, remote intervention and remote driving are kept apart because the legally decisive question is whether the automated driving system continues to perform the dynamic driving task or a human takes over part of it.

This module is published as a draft snapshot until its companion article has been submitted.

A concept register of roles across UNECE, EU, German, British, French and Slovak frameworks, and a role–function matrix coding each role against DDT, fallback, monitoring, remote assistance, remote intervention, remote driving, dispatch, service operation, lifecycle compliance, testing responsibility and keeper responsibility.

The table

Coded rows

Select a row for every coded dimension, the rationale and the ROAT records behind it.

Role / function	Framework	DDT	Fallback / MRM	Monitoring / supervision	Remote assistance	Remote intervention	Remote driving	Dispatch / trip strategy	Service operation	ADS lifecycle compliance	Testing permit / trial responsibility	Ownership / keeper responsibility
ADS as functional substitute for driver requirement RC-002	UNECE / 1968 Vienna Convention	System	System-dependent	Self-monitoring	Possible interface	Possible interface	No human remote dr…	No	No	Technical compliance	No	No
ADS as functional substitute for driver requirement DDT System Fallback / MRM System-dependent Monitoring / supervision Self-monitoring Remote assistance Possible interface Remote intervention Possible interface Remote driving No human remote driving Dispatch / trip strategy No Service operation No ADS lifecycle compliance Technical compliance Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Critical ontology distinction: a technical system may perform the driving task without becoming the person legally responsible for service operation, compliance or supervision. Verification status Primary-source checked Term Automated driving system satisfying Article 34 bis conditions Framework UNECE / 1968 Vienna Convention Actor type Technical system Core function Performs dynamic driving in a manner that can satisfy the Convention's driver requirement when conforming to applicable technical rules or domestic legislation. Primary legal / technical source 1968 Convention on Road Traffic, Article 34 bis Slovak current-law equivalent No general autonomous legal person; ADS is treated as vehicle/system functionality Slovak draft 1329 equivalent ADS remains distinct from operator and supervision roles Functional equivalence Conceptual only; do not equate system with legal operator Slovak drafting implication ADS can perform DDT without becoming the legal operator. Core ROAT records ROAT-2026-0300
Remote assistance / remote interaction RC-003	UNECE ADS work / technical interpretation	No	Support only	Yes	Yes	Limited	No	Possible	No	No	No	No
Remote assistance / remote interaction DDT No Fallback / MRM Support only Monitoring / supervision Yes Remote assistance Yes Remote intervention Limited Remote driving No Dispatch / trip strategy Possible Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Must remain distinct from remote driving. Advice/assistance does not automatically mean takeover of lateral and longitudinal control. Verification status ROAT verified source Term Remote assistance / remote interaction Framework UNECE ADS work / technical interpretation Actor type Human-supported function Core function Provides information or support to the ADS without necessarily assuming continuous DDT control. Primary legal / technical source UNECE ADS Guidance and Interpretation work on remote intervention / interaction Slovak current-law equivalent No settled general statutory category in current Slovak law Slovak draft 1329 equivalent Closest candidates: control-centre and supervision functions; exact mapping unresolved Functional equivalence Partial Slovak drafting implication Keep remote assistance distinct from remote driving. Core ROAT records ROAT-2026-0193
Transport / service operator RC-004	European Union – Regulation (EU) 2022/1426	No	Organisational	Entity-level	Arranged	Arranged	No	Yes	Yes	Possible	No	No
Transport / service operator DDT No Fallback / MRM Organisational Monitoring / supervision Entity-level Remote assistance Arranged Remote intervention Arranged Remote driving No Dispatch / trip strategy Yes Service operation Yes ADS lifecycle compliance Possible Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Do not conflate with vehicle owner, ADS manufacturer/provider or remote human supervisor. Verification status Primary-source checked via ROAT Term Transport service operator Framework European Union – Regulation (EU) 2022/1426 Actor type Legal or organisational entity Core function Organises or operates the transport service in which fully automated vehicles are deployed. Primary legal / technical source Commission Implementing Regulation (EU) 2022/1426, as amended Slovak current-law equivalent No complete general current-law equivalent for commercial FAV operation Slovak draft 1329 equivalent Closest: prevádzkovateľ plne automatizovaného vozidla / licence-holder architecture Functional equivalence Partial to strong at service-operator level, subject to exact statutory text Slovak drafting implication Potential comparator for Slovak licensed FAV operator. Core ROAT records ROAT-2026-0040 ROAT-2026-0218 ROAT-2026-0311 ROAT-2026-0312
Remote management function RC-005	European Union – Regulation (EU) 2022/1426 / JRC interpretation	No	Support	Yes	Yes	Yes	Not necessarily	Yes	Supports	Possible	No	No
Remote management function DDT No Fallback / MRM Support Monitoring / supervision Yes Remote assistance Yes Remote intervention Yes Remote driving Not necessarily Dispatch / trip strategy Yes Service operation Supports ADS lifecycle compliance Possible Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Ontology should model this primarily as a function or organisational capability, not automatically as one named natural person. Verification status Primary / official interpretation checked Term Remote management Framework European Union – Regulation (EU) 2022/1426 / JRC interpretation Actor type Organisational / technical function Core function Supports fleet/vehicle operation remotely within the approved system architecture, including defined interaction with vehicles and operational management. Primary legal / technical source Regulation (EU) 2022/1426 and JRC interpretation addendum on Safety Management System and Remote Management Slovak current-law equivalent No general fully developed current-law equivalent Slovak draft 1329 equivalent Closest: riadiace centrum / control-centre functions Functional equivalence Partial Slovak drafting implication Model as function/capability, not automatically as a person. Core ROAT records ROAT-2026-0311 ROAT-2026-0040
Authorised self-driving entity / ADS legal-responsibility entity RC-006	Great Britain – Automated Vehicles Act 2024	No	No direct	Entity-level	Possible	Possible	No	No	No / distinct	Yes	No	No
Authorised self-driving entity / ADS legal-responsibility entity DDT No Fallback / MRM No direct Monitoring / supervision Entity-level Remote assistance Possible Remote intervention Possible Remote driving No Dispatch / trip strategy No Service operation No / distinct ADS lifecycle compliance Yes Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale High-value comparison for Slovak drafting: UK separates the entity responsible for the authorised self-driving feature from individual users and service-operation roles. Verification status Primary-source checked Term Authorised self-driving entity (ASDE) Framework Great Britain – Automated Vehicles Act 2024 Actor type Legal person / entity Core function Legally responsible for ensuring an authorised automated vehicle continues to meet self-driving requirements and other statutory obligations. Primary legal / technical source Automated Vehicles Act 2024 Slovak current-law equivalent No direct current-law equivalent Slovak draft 1329 equivalent Closest: licensed FAV operator, but functions are not necessarily identical Functional equivalence Partial Slovak drafting implication Separate ADS safety-responsibility entity from service operator. Core ROAT records ROAT-2026-0171
User with limited in-vehicle legal duties during self-driving RC-007	Great Britain – Automated Vehicles Act 2024	No while engaged	Transition	Readiness duties	No	No	No	Limited	No	No	No	No
User with limited in-vehicle legal duties during self-driving DDT No while engaged Fallback / MRM Transition Monitoring / supervision Readiness duties Remote assistance No Remote intervention No Remote driving No Dispatch / trip strategy Limited Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Useful to prevent collapsing 'driver', 'user' and 'operator' into one category. Verification status Primary-source checked Term User-in-charge Framework Great Britain – Automated Vehicles Act 2024 Actor type Natural person Core function Occupies the vehicle and retains specified non-driving legal duties while not responsible for the manner of driving during authorised self-driving. Primary legal / technical source Automated Vehicles Act 2024 Slovak current-law equivalent Partly comparable to driver / person required to take over under selected automated-driving rules Slovak draft 1329 equivalent Draft role allocation should be checked; not equivalent to supervision operator Functional equivalence Partial Slovak drafting implication Do not conflate in-vehicle user with supervision operator. Core ROAT records ROAT-2026-0171
No-user-in-charge operational entity RC-008	Great Britain – Automated Vehicles Act 2024	No	Organisational	Entity-level	Arranged	Arranged	No	Yes	Yes	Possible	No	No
No-user-in-charge operational entity DDT No Fallback / MRM Organisational Monitoring / supervision Entity-level Remote assistance Arranged Remote intervention Arranged Remote driving No Dispatch / trip strategy Yes Service operation Yes ADS lifecycle compliance Possible Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Potential model for commercial driverless operation in Slovakia where no human user-in-charge is present. Verification status Primary-source checked Term No-user-in-charge operator (NUIC operator) Framework Great Britain – Automated Vehicles Act 2024 Actor type Licensed legal entity Core function Undertakes responsibilities that cannot be allocated to an in-vehicle user where the vehicle operates without a user-in-charge. Primary legal / technical source Automated Vehicles Act 2024 Slovak current-law equivalent No current-law equivalent Slovak draft 1329 equivalent Closest: licensed operator of fully automated vehicle/service Functional equivalence Moderate to strong at organisational level Slovak drafting implication Strong model for driverless commercial operation entity. Core ROAT records ROAT-2026-0171 ROAT-2026-0301
Technical remote supervisor RC-009	Germany – StVG / AFGBV	No continuous	Support	Yes	Yes	Legally constrained	No	No	No	No	No	No
Technical remote supervisor DDT No continuous Fallback / MRM Support Monitoring / supervision Yes Remote assistance Yes Remote intervention Legally constrained Remote driving No Dispatch / trip strategy No Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale A key warning against translating Technische Aufsicht simply as remote driver: German law deliberately separates supervision/authorisation from continuous vehicle control. Verification status Primary-source checked Term Technische Aufsicht Framework Germany – StVG / AFGBV Actor type Natural person Core function Performs legally defined remote technical-supervision functions, including assessment and enabling/authorising specified manoeuvres or measures when the automated vehicle requests support. Primary legal / technical source German Road Traffic Act (StVG), §§ 1d–1f; Autonomous Vehicles Approval and Operation Ordinance (AFGBV) Slovak current-law equivalent No settled current-law general equivalent Slovak draft 1329 equivalent Closest: operátor dohľadu / technický dohľad, but scope must be compared provision-by-provision Functional equivalence Partial Slovak drafting implication Closest supervision comparator; not remote driver. Core ROAT records ROAT-2026-0170 ROAT-2026-0205
Automated road transport system operator RC-010	France – STRA framework	No	Organisational	Entity-level	Arranged	Arranged	No	Yes	Yes	Possible	No	No
Automated road transport system operator DDT No Fallback / MRM Organisational Monitoring / supervision Entity-level Remote assistance Arranged Remote intervention Arranged Remote driving No Dispatch / trip strategy Yes Service operation Yes ADS lifecycle compliance Possible Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale France structures responsibility around the transport system/service, not only around the individual vehicle. Verification status Primary-source checked via ROAT Term Exploitant du système de transport routier automatisé Framework France – STRA framework Actor type Legal / organisational entity Core function Operates the automated road transport system under the French service-level safety and commissioning framework. Primary legal / technical source Ordonnance n° 2021-443 and Décret n° 2021-873 Slovak current-law equivalent No complete current-law equivalent Slovak draft 1329 equivalent Closest: licensed operator / service operator architecture Functional equivalence Partial to strong at service-system level Slovak drafting implication Service/system operator model; distinct from remote human role. Core ROAT records ROAT-2026-0307 ROAT-2026-0308
Authorised remote intervention person RC-011	France – STRA / automated-driving framework	Limited intervention	Support	Yes	Yes	Yes	Not ordinary	No	No	No	No	No
Authorised remote intervention person DDT Limited intervention Fallback / MRM Support Monitoring / supervision Yes Remote assistance Yes Remote intervention Yes Remote driving Not ordinary Dispatch / trip strategy No Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale French law is useful because it expressly links remote intervention to personal legal responsibility; this is a distinct design choice from pure technical supervision. Verification status Primary-source checked via ROAT Term Personne habilitée à intervenir à distance Framework France – STRA / automated-driving framework Actor type Natural person Core function Performs legally authorised remote intervention within the conditions laid down for the automated road transport system. Primary legal / technical source Ordonnance n° 2021-443; Code des transports / implementing decree Slovak current-law equivalent No explicit general current-law equivalent Slovak draft 1329 equivalent Closest: operátor dohľadu or a future remote-intervention role, depending on draft wording Functional equivalence Partial Slovak drafting implication Good comparator for explicit remote-intervention powers. Core ROAT records ROAT-2026-0307 ROAT-2026-0308
In-vehicle operator during automated operation RC-012	Croatia – Road Traffic Safety Act	No	MRM request	Yes	No remote	In-vehicle commands	No	Route / stops	No	No	No	No
In-vehicle operator during automated operation DDT No Fallback / MRM MRM request Monitoring / supervision Yes Remote assistance No remote Remote intervention In-vehicle commands Remote driving No Dispatch / trip strategy Route / stops Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Useful counter-example: Croatia explicitly names an in-vehicle operator separately from a remote intervention operator. Verification status Primary-source checked via ROAT Term Operator u vozilu Framework Croatia – Road Traffic Safety Act Actor type Natural person Core function Human role located in the vehicle under the Croatian statutory architecture for automated vehicle operation. Primary legal / technical source Croatia Road Traffic Safety Act amendments, NN 145/2024 Slovak current-law equivalent No dedicated equivalent in current Slovak general framework Slovak draft 1329 equivalent Could overlap with a readiness/supervision person depending on final draft design Functional equivalence Weak to partial Slovak drafting implication Useful in-vehicle operator comparator; ADS retains DDT. Core ROAT records ROAT-2026-0303ROAT-2026-0262
Remote intervention operator RC-013	Croatia – Road Traffic Safety Act	No	MRM support	Yes	Yes	Yes	No	Possible	No	No	No	No
Remote intervention operator DDT No Fallback / MRM MRM support Monitoring / supervision Yes Remote assistance Yes Remote intervention Yes Remote driving No Dispatch / trip strategy Possible Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Strong comparative candidate for Slovak legislative drafting because Croatia separates remote intervention from in-vehicle operation. Verification status Primary-source checked via ROAT Term Operator intervencije na daljinu Framework Croatia – Road Traffic Safety Act Actor type Natural person Core function Performs remote intervention functions for a fully automated vehicle under Croatian law. Primary legal / technical source Croatia Road Traffic Safety Act amendments, NN 145/2024 Slovak current-law equivalent No explicit general current-law equivalent Slovak draft 1329 equivalent Closest: operátor dohľadu, but remote-intervention powers need separate analysis Functional equivalence Partial Slovak drafting implication Strong comparator if Slovak role intervenes but ADS remains DDT performer. Core ROAT records ROAT-2026-0303ROAT-2026-0262
Licensed fully automated vehicle operator RC-014	Slovakia – parliamentary print 1329 (draft)	No	Organisational	Entity-level	Arranged	Arranged	No	Yes	Yes	Possible	No	No
Licensed fully automated vehicle operator DDT No Fallback / MRM Organisational Monitoring / supervision Entity-level Remote assistance Arranged Remote intervention Arranged Remote driving No Dispatch / trip strategy Yes Service operation Yes ADS lifecycle compliance Possible Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Status flag is essential: as of 26 August 2026 this is not effective law and should never be returned as a current Slovak legal role without qualification. Verification status Draft text checked; not in force Term Prevádzkovateľ plne automatizovaného vozidla – proposed licence-holder role Framework Slovakia – parliamentary print 1329 (draft) Actor type Licensed operator / legal subject Core function Would hold the licence and carry central organisational and operational obligations for fully automated vehicle operation. Primary legal / technical source Government bill, parliamentary print 1329 Slovak current-law equivalent No general current-law commercial-operation equivalent; §49 Act 106/2018 is test-operation permit architecture Slovak draft 1329 equivalent Exact draft role Functional equivalence N/A – Slovak reference point Slovak drafting implication Draft reference point for commercial-operation responsibility. Core ROAT records ROAT-2026-0159
Supervision operator RC-015	Slovakia – parliamentary print 1329 (draft)	No continuous	Support	Yes	Possible	Possible	Potential boundary	No	No	No	No	No
Supervision operator DDT No continuous Fallback / MRM Support Monitoring / supervision Yes Remote assistance Possible Remote intervention Possible Remote driving Potential boundary Dispatch / trip strategy No Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Key research issue: determine whether the draft function is closer to German Technische Aufsicht, French authorised remote intervener, Croatian remote intervention operator, or an EU remote-management function. It may improperly combine several models. Verification status Draft text checked; not in force Term Operátor dohľadu Framework Slovakia – parliamentary print 1329 (draft) Actor type Natural person / operational role Core function Would perform supervision functions assigned by the proposed Slovak framework within the control-centre/operator structure. Primary legal / technical source Government bill, parliamentary print 1329 Slovak current-law equivalent No settled general equivalent in current law Slovak draft 1329 equivalent Exact draft role Functional equivalence N/A – Slovak reference point Slovak drafting implication Core Slovak issue: define boundary between supervision, intervention and remote driving. Core ROAT records ROAT-2026-0159
Level 3 fallback-ready user RC-016	SAE J3016	After takeover	Yes	Readiness	No	No	No	No	No	No	No	No
Level 3 fallback-ready user DDT After takeover Fallback / MRM Yes Monitoring / supervision Readiness Remote assistance No Remote intervention No Remote driving No Dispatch / trip strategy No Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Critical distinction for Level 3: fallback-ready user is not a remote supervisor and is not the service operator. Verification status Primary technical standard checked via ROAT Term DDT fallback-ready user Framework SAE J3016 Actor type Natural person / user Core function Remains receptive to a request to intervene and performs the DDT fallback when the Level 3 ADS can no longer continue. Primary legal / technical source SAE J3016_202104 – Taxonomy and Definitions for Terms Related to Driving Automation Systems for On-Road Motor Vehicles Slovak current-law equivalent Closest to a driver/person subject to takeover duties in automated-driving rules; no general standalone statutory category Slovak draft 1329 equivalent Should remain distinct from operátor dohľadu; check whether draft allocates any takeover role to an in-vehicle user Functional equivalence Partial Slovak drafting implication Keep Level 3 fallback user outside remote-supervision category. Core ROAT records ROAT-2026-0120
Remote human driver RC-017	SAE J3016	Yes	Possible	Yes	No	Yes – direct	Yes	No	No	No	No	No
Remote human driver DDT Yes Fallback / MRM Possible Monitoring / supervision Yes Remote assistance No Remote intervention Yes – direct Remote driving Yes Dispatch / trip strategy No Service operation No ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale This is the cleanest comparator for testing whether Slovak supervision powers cross the line into actual remote driving. Verification status Primary technical standard checked via ROAT Term Remote driver Framework SAE J3016 Actor type Natural person Core function Performs part or all of the dynamic driving task from outside the conventional in-vehicle driving position. Primary legal / technical source SAE J3016_202104 Slovak current-law equivalent No explicit general remote-driver category in current Slovak road-traffic framework Slovak draft 1329 equivalent No clearly separate remote-driver role; must not be presumed identical to operátor dohľadu Functional equivalence Weak / no direct equivalent Slovak drafting implication Explicit separate remote-driver role is needed if direct DDT is ever intended. Core ROAT records ROAT-2026-0120
Trip-dispatch / strategic user RC-018	SAE J3016	No	No	No	Possible	No	No	Yes	Support	No	No	No
Trip-dispatch / strategic user DDT No Fallback / MRM No Monitoring / supervision No Remote assistance Possible Remote intervention No Remote driving No Dispatch / trip strategy Yes Service operation Support ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility No Primary current-law rationale Useful reminder that strategic trip management, DDT performance and remote supervision are separate functions. Verification status Primary technical standard checked via ROAT Term Dispatcher Framework SAE J3016 Actor type Natural person / user Core function Dispatches an ADS-operated vehicle and performs strategic trip functions without performing the DDT. Primary legal / technical source SAE J3016_202104 Slovak current-law equivalent No standalone statutory equivalent Slovak draft 1329 equivalent Possible control-centre dispatch function, but not necessarily a named legal role Functional equivalence Functional only Slovak drafting implication Separate dispatch/strategic functions from safety supervision. Core ROAT records ROAT-2026-0120
Safety driver in public-road AV testing RC-022	California – DMV testing regime	Conditional	Yes	Yes	No	In-vehicle takeover	No	No	No	No	Testing driver role	No
Safety driver in public-road AV testing DDT Conditional Fallback / MRM Yes Monitoring / supervision Yes Remote assistance No Remote intervention In-vehicle takeover Remote driving No Dispatch / trip strategy No Service operation No ADS lifecycle compliance No Testing permit / trial responsibility Testing driver role Ownership / keeper responsibility No Primary current-law rationale California 2026 rules retain a distinct permitting pathway for testing with a safety driver, separate from driverless testing and deployment. Verification status Official California current regulations checked Term Autonomous vehicle test driver / safety driver Framework California – DMV testing regime Actor type Natural person / licensed test driver Core function Provides the human driving and safety fallback required for AV testing under the drivered-testing permit category. Primary legal / technical source California Code of Regulations, title 13, AV testing regulations; DMV 2026 framework Slovak current-law equivalent Functional analogue of the human safety driver used under a Slovak test-operation permit Slovak draft 1329 equivalent Not a necessary deployment role for fully driverless operation Functional equivalence Strong in testing context Slovak drafting implication Testing-only human safeguard. Core ROAT records ROAT-2026-0172
AV testing permit holder RC-023	California – DMV AV program	No	Organisational	Entity-level	Arranged	Arranged	No	Yes	Testing programme	Possible	Yes	No
AV testing permit holder DDT No Fallback / MRM Organisational Monitoring / supervision Entity-level Remote assistance Arranged Remote intervention Arranged Remote driving No Dispatch / trip strategy Yes Service operation Testing programme ADS lifecycle compliance Possible Testing permit / trial responsibility Yes Ownership / keeper responsibility No Primary current-law rationale Useful for separating testing authorisation from commercial/deployment operator licensing in Slovak law. Verification status Official California permit framework checked Term Manufacturer / autonomous vehicle testing permit holder Framework California – DMV AV program Actor type Legal entity / manufacturer Core function Holds DMV authority to test or deploy AVs subject to the applicable permit category, ODD, reporting and compliance conditions. Primary legal / technical source California DMV Autonomous Vehicle Regulations and Permit Program Slovak current-law equivalent Closest current comparator: holder/applicant of a §49 Act No. 106/2018 test-operation permit Slovak draft 1329 equivalent Draft licensed FAV operator is closer for deployment, but not identical to California testing permit holder Functional equivalence Strong for testing permit; partial for deployment Slovak drafting implication Separate Slovak §49 permit holder from eventual deployment licence holder. Core ROAT records ROAT-2026-0172 ROAT-2026-0183 ROAT-2026-0185
Vehicle owner as statutory responsibility holder RC-030	Croatia – Road Traffic Safety Act	No	No	No	No	No	No	No	Distinct	No	No	Yes
Vehicle owner as statutory responsibility holder DDT No Fallback / MRM No Monitoring / supervision No Remote assistance No Remote intervention No Remote driving No Dispatch / trip strategy No Service operation Distinct ADS lifecycle compliance No Testing permit / trial responsibility No Ownership / keeper responsibility Yes Primary current-law rationale Croatia is a useful warning against conflating owner, service operator and remote human roles: the owner carries specific offence and data duties even though intervention roles are separately defined. Verification status Primary-source checked via ROAT Term Vlasnik potpuno automatiziranog vozila Framework Croatia – Road Traffic Safety Act Actor type Natural or legal person / owner Core function Bears statutory responsibility for traffic offences committed by the fully automated vehicle subject to exceptions, and has data-preservation/disclosure duties. Primary legal / technical source Croatia Road Traffic Safety Act amendments, NN 145/2024, Articles 281.d–281.e Slovak current-law equivalent Vehicle owner/holder concepts exist, but Slovak AV law does not currently use ownership as a complete substitute for driver/operator responsibility Slovak draft 1329 equivalent Draft operator/licence-holder should remain distinct from vehicle owner unless the law expressly combines them Functional equivalence Partial – ownership is a separate legal axis Slovak drafting implication Keep owner/holder liability axis separate from operator and supervisor roles. Core ROAT records ROAT-2026-0303ROAT-2026-0262

yesYes — the role performs this functionnoNo — it does notsysSystem — performed by the ADS, not a person…Qualified — the cell states the condition–Not codedYes …An outlined chip is a qualified answer: read the cell text, not the colour.

10 of 30 coded rows are not published: their evidence is entirely below the evidence gate. They are listed under Pending evidence below.

Pending evidence

Coded but not published

These rows exist in the Source dataset and are coded, but every record behind them is below the evidence gate — Research Stage below Verified, or Evidence Level 5 to 6. They are published once the primary source named here is captured and verified.

Row	Framework	Primary source it needs	Records held today
Human driver RC-001	UNECE / 1968 Vienna Convention	1968 Convention on Road Traffic, as amended by Article 34 bis	ROAT-2026-0317
Prototype ADS fallback test driver RC-019	SAE J3018	SAE J3018_202012 – Safety-Relevant Guidance for On-Road Testing of Prototype ADS-Operated Vehicles	ROAT-2026-0317
In-vehicle prototype fallback test driver RC-020	SAE J3018	SAE J3018_202012	ROAT-2026-0317
Remote prototype fallback test driver RC-021	SAE J3018	SAE J3018_202012	ROAT-2026-0317
Automated-vehicle trial permit holder RC-024	Sweden – Swedish Transport Agency	Swedish ordinance on trial operation with automated vehicles and TSFS 2021:4 permit process	ROAT-2026-0317
ADS lifecycle safety entity RC-025	Australia – proposed Automated Vehicle Safety Law framework	Australian NTC automated-vehicle regulatory framework; proposed Automated Vehicle Safety Law	ROAT-2026-0317
Driverless-operation permission holder RC-026	Japan – Road Traffic Act SAO framework	Japan Road Traffic Act, as amended by Act No. 32 of 2022 – SAO permission framework	ROAT-2026-0317
Remote operational supervisor RC-027	Japan – Road Traffic Act SAO framework	Japan Road Traffic Act SAO permission framework	ROAT-2026-0317
Automated commercial vehicle pilot participant RC-028	Ontario, Canada – ACMV Pilot Program	Ontario Automated Commercial Motor Vehicle Pilot Program Conditions / applicable HTA pilot regulation	ROAT-2026-0317
Driverless-test oversight assistant RC-029	Ontario, Canada – ACMV Pilot Program	Ontario Automated Commercial Motor Vehicle Pilot Program Conditions	ROAT-2026-0317

Snapshot record

Provenance

Snapshot

ROAT-SNAP-ROLES-2026-09-05 · legal snapshot date 2026-09-05 · data exported 2026-09-05

Coder · second pass

JA · No second pass recorded yet.

Caveats

First export of Roles & Concepts + Role Function Matrix; coding date per row is the 'Last checked' column in the research register.

Related modules

Post-type-approval deployment models

Concepts

DDT fallback and minimal risk condition (Fallback / MRM); Dynamic driving task (DDT) (DDT); Remote assistance (Remote assistance); Remote driving (Remote driving); Remote intervention (Remote intervention); Technical supervision (remote supervisor) (Monitoring / supervision)

All snapshots

2026-09-05 (superseded) · 2026-09-06 (superseded) · 2026-09-07

Sources cited in this snapshot

ROAT-2026-0040

Commission Implementing Regulation (EU) 2022/1426 on type-approval of automated driving systems

ROAT-2026-0120

SAE J3016_202104 – Taxonomy and Definitions for Terms Related to Driving Automation Systems for On-Road Motor Vehicles

ROAT-2026-0159

Government Bill amending laws in connection with expanding the framework for introducing and using automated vehicles in the Slovak Republic (Parliamentary Print 1329)

ROAT-2026-0170

German Road Traffic Act (StVG) § 1a – Motor vehicles with an automated driving function (Straßenverkehrsgesetz § 1a)

ROAT-2026-0171

Automated Vehicles Act 2024

ROAT-2026-0172

California Vehicle Code § 38750 – Autonomous vehicles: definitions, testing and deployment

ROAT-2026-0183

California DMV Autonomous Vehicles Incident Reporting

ROAT-2026-0185

California DMV 2024–2025 Autonomous Vehicle Disengagement and Mileage Reports

ROAT-2026-0193

Interpretation of remote intervention and remote interaction (ADS-21-71/Rev.3)

ROAT-2026-0205

Technical Report of the Working Group “Research Needs in Teleoperation” (BASt F 166b)

ROAT-2026-0218

Commission Implementing Regulation (EU) 2026/481 amending Regulation (EU) 2022/1426

ROAT-2026-0262

Report · Analysed · Level 4 - Conference or institutional source — not yet in the public Source Library

ROAT-2026-0300

Proposal for a new UN Global Technical Regulation on Automated Driving Systems (ECE/TRANS/WP.29/2026/139)

ROAT-2026-0301

The Automated Vehicles (Permits for Automated Passenger Services) Regulations 2026

ROAT-2026-0303

Act amending the Road Traffic Safety Act, NN 145/2024 (Zakon o izmjenama i dopunama Zakona o sigurnosti prometa na cestama)

ROAT-2026-0307

Ordonnance No. 2021-443 of 14 April 2021 on criminal liability and conditions of use for vehicles with delegated driving (Ordonnance n° 2021-443)

ROAT-2026-0308

Decree No. 2021-873 of 29 June 2021 implementing Ordonnance No. 2021-443 (Décret n° 2021-873)

ROAT-2026-0311

Interpretation of EU Regulation 2022/1426 on the Type Approval of Automated Driving Systems: Addendum for Safety Management System and Remote Management

ROAT-2026-0312

Interpretation of EU Regulation 2022/1426 on the Type Approval of Automated Driving Systems

Cite this snapshot

ROAT Observatory, Human roles in automated driving [ROAT-MOD-ROLES], snapshot 2026-09-05 [ROAT-SNAP-ROLES-2026-09-05], no DOI yet. Jozef Andraško. /modules/human-roles/2026-09-05/

Human roles in automated driving draft snapshot

Coded rows

ADS as functional substitute for driver requirement

Remote assistance / remote interaction

Transport / service operator

Remote management function

Authorised self-driving entity / ADS legal-responsibility entity

User with limited in-vehicle legal duties during self-driving

No-user-in-charge operational entity

Technical remote supervisor

Automated road transport system operator

Authorised remote intervention person

In-vehicle operator during automated operation

Remote intervention operator

Licensed fully automated vehicle operator

Supervision operator

Level 3 fallback-ready user

Remote human driver

Trip-dispatch / strategic user

Safety driver in public-road AV testing

AV testing permit holder

Vehicle owner as statutory responsibility holder

Coded but not published

Provenance