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Modules › Second Gate › 2026-08-31

Module 02 · ROAT-MOD-SECOND-GATE

Post-type-approval deployment models review snapshot

How do national legal orders convert the technical admissibility of a vehicle or ADS into a legal authorisation for real driverless deployment, and which functions does post-type-approval deployment governance perform?

Snapshot 2026-08-31 (frozen)Rows 8Coder JADOI 10.5281/zenodo.22409314Source dataset Post-Type-Approval Deployment Modelsdata.csv · data.json

This snapshot has been superseded by snapshot 2026-09-07 (20 cells recoded). It stays addressable and citable as published, DOI 10.5281/zenodo.22409314.

Type approval answers whether a vehicle and its automated driving system are technically admissible. It does not answer whether the vehicle may lawfully operate without a driver on a given road, for a given service, under a given actor. The Second Gate model codes what stands between the two — the deployment gate, its object, its decision maker, the accountable actor, remote roles, and the lifecycle rules that keep the authorisation honest when the system changes.

Regimes marked as draft or prospective are analytically important but are never coded as current law.

Functional coding of eight regimes across eighteen dimensions: regulatory object, technical baseline, deployment gate, ODD legalisation, authority, accountable actor, remote human role, DDT allocation, offence allocation, liability, data, in-use oversight, material change, revalidation, service pathway, dominant model, legal status. Current law and draft or prospective regimes are kept apart.

The table

Coded rows

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

RegimeDeployment gateRemote human roleDominant deployment modelLegal statusConfidence
Current law · snapshot 2026-08-31
Germany – current lawVehicle operating permit + authority approval of defined operating area + registration before autonomous road useTechnische Aufsicht – may deactivate and release specified manoeuvres; not ordinary continuous remote drivingOperating-area + technical-supervision modelIn forceHigh

Germany – current law

Regulatory object
Autonomous vehicle + approved defined operating area + keeper + technical supervision
Technical approval baseline
EU/UNECE technical baseline plus German autonomous-vehicle operating permit under StVG/AFGBV
Additional deployment / road-use gate
Vehicle operating permit + authority approval of defined operating area + registration before autonomous road use
ODD / operating-area legalisation
ODD is translated into a geographically defined and authority-approved 'festgelegter Betriebsbereich'
Competent authority / decision maker
KBA / competent road authority depending on decision layer
Primary accountable organisational actor
Halter (vehicle keeper), with manufacturer duties and Technische Aufsicht functions separately allocated
Remote human role
Technische Aufsicht – may deactivate and release specified manoeuvres; not ordinary continuous remote driving
DDT / fallback allocation
ADS performs DDT; system must comply with road rules and achieve minimum-risk condition where necessary
Traffic-offence allocation
Dedicated AV behavioural architecture; legal duties are distributed among ADS framework, keeper and supervisor rather than simply retained by an onboard driver
Civil liability / insurance
General StVG keeper-liability / insurance architecture remains central; not wholly replaced by AV-specific civil liability
Data / logging
Statutory event/data duties; AFGBV data-storage requirements
Post-market / in-use oversight
KBA/authority market surveillance and permit supervision
Material change / software update
AFGBV § 4(5) expressly requires KBA approval before post-permit changes to an autonomous vehicle are used; § 6 allows withdrawal/suspension of the vehicle operating permit where approval conditions cease to be met.
Retesting / revalidation
Explicit lifecycle control: KBA approval for vehicle changes; suspension/withdrawal pending clarification under § 6; operating-area approval can be suspended/withdrawn under § 10 when safety assumptions or infrastructure conditions cease to hold.
Commercial service pathway
Possible within approved operating area and applicable transport/service law
Dominant deployment model
Operating-area + technical-supervision model
Legal status
In force
Primary-source anchor
StVG §§ 1d–1g; AFGBV §§ 4, 7–11, 13–14
Primary current-law rationale
Germany most clearly converts a technical ODD into a public-law deployment object: lawful autonomous operation is geographically bounded by an approved operating area.
Confidence
High
France – current lawPrior system safety demonstration + qualified independent opinions + formal mise-en-service decisionQualified remote intervention personnel integrated into system operationSystem/service safety-assurance modelIn forceHigh

France – current law

Regulatory object
Automated road transport system: vehicle + technical system + route/zone + service organisation
Technical approval baseline
EU type approval / relevant vehicle technical approval
Additional deployment / road-use gate
Prior system safety demonstration + qualified independent opinions + formal mise-en-service decision
ODD / operating-area legalisation
Safety case is tied to intended route or zone and service configuration
Competent authority / decision maker
Service organiser / competent transport and road authorities within statutory framework
Primary accountable organisational actor
Automated transport-system/service operator architecture rather than vehicle owner alone
Remote human role
Qualified remote intervention personnel integrated into system operation
DDT / fallback allocation
ADS performs DDT; remote intervention supports defined situations without collapsing into ordinary remote driving
Traffic-offence allocation
Dedicated criminal-responsibility adaptations exist; detailed allocation depends on operating mode and legal actor
Civil liability / insurance
Compulsory insurance/general civil-liability rules supplemented by dedicated automated-driving responsibility provisions; civil layer less comprehensive than deployment layer
Data / logging
System/event recording and safety-management evidence required
Post-market / in-use oversight
In-use system safety management and authority oversight tied to service operation
Material change / software update
Code des transports R3151-1 defines a substantial modification as one that changes the safety assessment; R3152-18 requires notification and, for a substantially modified system, suspension of operation.
Retesting / revalidation
Explicit re-commissioning: after a substantial modification the organiser suspends operation and a new mise-en-service decision is taken under R3152-10 to R3152-12; R3152-11 applies to new or substantially modified systems.
Commercial service pathway
Yes. Passenger automated-road-transport-system pathway extended to automated road freight by Décret 2024-1063, effective 28 Nov 2024.
Dominant deployment model
System/service safety-assurance model
Legal status
In force
Primary-source anchor
Ordonnance 2021-443; Décret 2021-873; Code des transports R3151/R3152; Décret 2024-1063 / R3251–R3253
Primary current-law rationale
France regulates the socio-technical transport system, not merely the vehicle. Technical approval is necessary but not sufficient for service deployment.
Confidence
High
Croatia – current lawDedicated road-traffic rules plus mandatory real-world service validation before passenger-service deploymentRemote intervention role recognised; boundaries and concurrency remain implementation questionsOwner-centred deployment-validation modelIn forceHigh

Croatia – current law

Regulatory object
Fully automated vehicle + owner + operating area + transport service + remote intervention arrangements
Technical approval baseline
EU ADS type approval
Additional deployment / road-use gate
Dedicated road-traffic rules plus mandatory real-world service validation before passenger-service deployment
ODD / operating-area legalisation
Operating area / territory forms part of deployment validation and service conditions
Competent authority / decision maker
Transport/road authorities; licensing authority under national transport framework
Primary accountable organisational actor
Vehicle owner is a central road-traffic accountability actor; service operator duties exist at transport layer
Remote human role
Remote intervention role recognised; boundaries and concurrency remain implementation questions
DDT / fallback allocation
ADS performs driverless operation; remote intervention supports defined operational/safety functions
Traffic-offence allocation
Owner bears dedicated responsibility for traffic offences of fully automated vehicle in driverless operation
Civil liability / insurance
Traffic-offence allocation is clear; broader AV-specific civil-liability architecture is less complete
Data / logging
Strong telemetry/event-data access and video-surveillance duties
Post-market / in-use oversight
Service/deployment oversight, incident management and licence conditions
Material change / software update
Partial change-control only: a new special-conditions certificate is required within 15 days if certificate data change; general testing applies to converted/modified vehicle hardware under Road Safety Act Art 276.
Retesting / revalidation
No equally explicit rule located that a material ADS/ODD/software/service change automatically re-triggers the Art 13b–13d real-world service-validation procedure. Serious incidents can trigger temporary prohibition of a FAV type under Art 290a.
Commercial service pathway
Yes, through transport licensing after service-level real-world validation
Dominant deployment model
Owner-centred deployment-validation model
Legal status
In force
Primary-source anchor
NN 145/2024 Arts 281a–281f; NN 154/2024 Arts 13b–13d / Art 51a framework
Primary current-law rationale
Croatia is especially useful for the bridge from EU type approval to local service validation in real operating conditions.
Confidence
High
Core ROAT records
ROAT-2026-0262ROAT-2026-0303ROAT-2026-0304ROAT-2026-0305
Great Britain – 2026 transitional current lawAutomated Passenger Service permit for eligible passenger services before full 2027 implementation; wider general authorisation framework still being completedNo German-style technical supervisor as universal core role; remote functions depend on operating modelAuthorised-entity / staged-permit modelPartly in force; full AV Act framework planned for 2027High

Great Britain – 2026 transitional current law

Regulatory object
Authorised self-driving vehicle / responsible entity architecture; APS service permits as transitional deployment route
Technical approval baseline
UK vehicle approval/self-driving authorisation architecture under AV Act implementation programme
Additional deployment / road-use gate
Automated Passenger Service permit for eligible passenger services before full 2027 implementation; wider general authorisation framework still being completed
ODD / operating-area legalisation
Authorised domain / territory forms part of self-driving authorisation and safety principles
Competent authority / decision maker
Secretary of State / DVSA and relevant local transport authority for APS consent
Primary accountable organisational actor
ASDE / licensed service operator / NUiC-type actor architecture depending on service and vehicle use
Remote human role
No German-style technical supervisor as universal core role; remote functions depend on operating model
DDT / fallback allocation
Authorised ADS performs self-driving task; user-in-charge duties are separated where relevant
Traffic-offence allocation
AV Act reallocates legal responsibility away from user where vehicle is driving itself, subject to statutory architecture
Civil liability / insurance
Dedicated insurance/liability reforms are part of UK AV framework
Data / logging
Information, incident and in-use regulatory duties form part of full Act architecture
Post-market / in-use oversight
In-use regulation and safety-principles monitoring planned as core of full implementation
Material change / software update
AV Act 2024 ss 5, 8 and 9 provide ongoing authorisation requirements and powers to vary, suspend or withdraw authorisation; conditions may be tailored to features/deployment locations. APS Regulations 2026 additionally treat a material change in circumstances as a ground for permit variation/suspension/withdrawal.
Retesting / revalidation
Strong lifecycle authorisation logic: permanent or temporary variation, suspension and withdrawal; serious incidents, failure of requirements or material changed circumstances can trigger intervention. Full general AV authorisation framework remains implementation-stage through 2027.
Commercial service pathway
APS permit enables staged commercial passenger deployment in 2026
Dominant deployment model
Authorised-entity / staged-permit model
Legal status
Partly in force; full AV Act framework planned for 2027
Primary-source anchor
Automated Vehicles Act 2024; SI 2026/439; DfT implementation programme
Primary current-law rationale
UK is a control case showing that actor/institution design can legally precede full ordinary deployment.
Confidence
High
China – current transitional regimeProduct admission is followed by geographically/functionally limited road-access pilot rather than unrestricted deploymentNo mature national standalone technical-supervisor/remote-operator role architecture yetManufacturer/user-entity conditional deployment modelIn force as pilot / conditional admission architectureHigh

China – current transitional regime

Regulatory object
Conditionally admitted L3 vehicle + designated user entity + specified roads/speeds + road-access pilot
Technical approval baseline
Conditional product admission; GB 44721-2026 adopted but effective from 1 July 2027
Additional deployment / road-use gate
Product admission is followed by geographically/functionally limited road-access pilot rather than unrestricted deployment
ODD / operating-area legalisation
Specified road segments, speed limits and operating conditions function as legally bounded ODD/geofence
Competent authority / decision maker
MIIT and participating local authorities under pilot framework
Primary accountable organisational actor
Designated user entity + manufacturer within monitored pilot architecture
Remote human role
No mature national standalone technical-supervisor/remote-operator role architecture yet
DDT / fallback allocation
L3 ADS performs DDT within approved conditions; human fallback remains relevant to L3 design
Traffic-offence allocation
Current pilot arrangements do not yet equal the proposed national manufacturer-centric offence rule
Civil liability / insurance
Existing compulsory insurance/general rules apply; national AV-specific insurance provisions are proposed, not yet enacted
Data / logging
Pilot monitoring and safety evidence required
Post-market / in-use oversight
Government monitoring and conditional product/road-access controls
Material change / software update
Pilot/product approval is version- and condition-sensitive; exact general change-control rule is still evolving
Retesting / revalidation
Road-access pilots and reassessment provide staged evidence before expansion
Commercial service pathway
Limited pilot deployment; not unrestricted nationwide commercial L3 operation
Dominant deployment model
Manufacturer/user-entity conditional deployment model
Legal status
In force as pilot / conditional admission architecture
Primary-source anchor
MIIT conditional L3 approvals of 15 Dec 2025; GB 44721-2026
Primary current-law rationale
China already demonstrates the second-gate logic in practice even before the new national Road Traffic Safety Law is enacted.
Confidence
High
Slovakia – current law (31 Aug 2026)Predominantly § 49 test-operation permit; no general dedicated commercial FAV deployment gateNo general commercial FAV technical-supervision/control-centre role in forceTesting-permit / technical-leading modelIn forceMedium–High

Slovakia – current law (31 Aug 2026)

Regulatory object
EU-approved vehicle + national test-operation / narrower operational exceptions
Technical approval baseline
EU/UNECE type-approval framework can provide high technical maturity
Additional deployment / road-use gate
Predominantly § 49 test-operation permit; no general dedicated commercial FAV deployment gate
ODD / operating-area legalisation
ODD can be reflected in permit/test conditions but is not yet a general autonomous-operation authorisation object
Competent authority / decision maker
Ministry of Transport / road and police authorities depending on permit
Primary accountable organisational actor
Permit holder / owner / driver-type roles; no general licensed FAV operator architecture in force
Remote human role
No general commercial FAV technical-supervision/control-centre role in force
DDT / fallback allocation
Current framework remains structurally driver/test oriented; dedicated driverless DDT allocation is incomplete
Traffic-offence allocation
No complete general rule for traffic offences committed by driverless FAV
Civil liability / insurance
General motor insurance/civil liability; no mature FAV-specific allocation
Data / logging
Test-operation documentation and technical rules, but no general FAV logging architecture equivalent to CPT 1329
Post-market / in-use oversight
Primarily permit/test supervision rather than mature in-use driverless market oversight
Material change / software update
Handled through technical approval/test permit changes; no general deployment change-control regime
Retesting / revalidation
Retesting tied mainly to test-operation context
Commercial service pathway
No clear general pathway from EU type approval to ordinary commercial driverless operation
Dominant deployment model
Testing-permit / technical-leading model
Legal status
In force
Primary-source anchor
Act 106/2018 § 49; Decree 131/2018; Act 131/2026 effective 1 Sep 2026 only prospectively at snapshot
Primary current-law rationale
The central inter-layer gap remains: technical admissibility does not yet map onto a general legal route for commercial driverless deployment.
Confidence
Medium–High
Sensitivity · prospective law (not current-law scores)
China – 2026 Road Traffic Safety Law draftRegistered AV may activate ADS only within design operating conditions; national road-use rules sit above technical conformityRemote human role remains underdeveloped in the draftManufacturer-centred road-use and enforcement modelDraft / public consultationHigh

China – 2026 Road Traffic Safety Law draft prospective

Regulatory object
Autonomous vehicle/ADS + manufacturer/importer + road-use accountability layer
Technical approval baseline
Road-traffic-rule conformity test + technical/product admission; GB 44721-2026 technical pillar
Additional deployment / road-use gate
Registered AV may activate ADS only within design operating conditions; national road-use rules sit above technical conformity
ODD / operating-area legalisation
Manufacturer/importer must ensure ADS cannot activate outside design operating conditions
Competent authority / decision maker
Public-security / product / transport authorities under State Council allocation
Primary accountable organisational actor
Manufacturer/importer becomes direct central accountability actor for ADS-active traffic violations
Remote human role
Remote human role remains underdeveloped in the draft
DDT / fallback allocation
ADS continuously performs full DDT within design operating conditions; L2 assistance is expressly distinguished
Traffic-offence allocation
Manufacturer/importer 'accepts handling' for violation while ADS active and bears burden of proof if claiming it was unrelated to ADS
Civil liability / insurance
Compulsory motor-vehicle liability insurance required; commercial insurance encouraged; detailed regime delegated
Data / logging
Strong accident evidence/data duties and manufacturer data-provision obligations
Post-market / in-use oversight
National road-safety risk assessment can support suspension/prohibition, recall, repair, replacement/refund/compensation measures
Material change / software update
Unauthorised ADS modification prohibited and sanctioned; post-market risk layer is explicit
Retesting / revalidation
Implementing rules still required; change/revalidation mechanics not fully specified
Commercial service pathway
Supports ordinary national road operation once enacted and implementing rules exist
Dominant deployment model
Manufacturer-centred road-use and enforcement model
Legal status
Draft / public consultation
Primary-source anchor
Road Traffic Safety Law revision draft Arts 95–103
Primary current-law rationale
Analytically important but must not be coded as current Chinese law. It adds a national road-use layer to the already emerging technical and pilot layers.
Confidence
High
Slovakia – CPT 1329 prospective modelOperator licence + specific operation approval would create a genuine second gateSupervision operator + control centre; current draft boundary with remote driving needs correctionLicensed-operator + control-centre deployment modelDraft / parliamentary print 1329High for text; prospective only

Slovakia – CPT 1329 prospective model prospective

Regulatory object
Licensed FAV operator + approved operation + control centre + supervision operator + ODD
Technical approval baseline
EU/UNECE technical approval remains baseline
Additional deployment / road-use gate
Operator licence + specific operation approval would create a genuine second gate
ODD / operating-area legalisation
ODD and defined roads/territory become part of operational documentation / approval
Competent authority / decision maker
Ministry of Transport with police/other authority inputs
Primary accountable organisational actor
Licensed FAV operator becomes organisational centre of responsibility
Remote human role
Supervision operator + control centre; current draft boundary with remote driving needs correction
DDT / fallback allocation
ADS should remain DDT performer; current wording risks transferring DDT remotely to supervisor in some clauses
Traffic-offence allocation
Still requires explicit rule for offences committed by FAV while ADS is active
Civil liability / insurance
Insurance/organisational requirements improve, but full civil/product/service allocation remains to be clarified
Data / logging
Dedicated recording system proposed
Post-market / in-use oversight
Operator/licence supervision and operational duties create stronger in-use layer
Material change / software update
Draft requires clearer material-change / software-version triggers
Retesting / revalidation
Local validation/testing is structurally present but should be proportionate and recognise existing type-approval/foreign evidence
Commercial service pathway
Potential general commercial pathway if enacted and separated from test-only logic
Dominant deployment model
Licensed-operator + control-centre deployment model
Legal status
Draft / parliamentary print 1329
Primary-source anchor
CPT 1329 §§ 49a–49f and related amendments
Primary current-law rationale
The draft is conceptually close to a mature second-gate architecture, but actor boundaries, offence allocation, material-change control and the relation between licence and operation approval should be tightened.
Confidence
High for text; prospective only

Snapshot record

Provenance

Snapshot
ROAT-SNAP-SECOND-GATE-2026-08-31 · legal snapshot date 2026-08-31 · data exported 2026-09-05
Coder · second pass
JA · No second pass recorded yet.
Caveats
  • Current law and draft/prospective regimes are kept apart; China RTSL draft and Slovak print 1329 are prospective only.
  • Great Britain is coded as 2026 transitional current law; full AV Act framework planned for 2027.
Related modules
Regulatory normalisation by functional layer
Concepts
DDT fallback and minimal risk condition (DDT / fallback allocation); Deployment gate (the second gate) (Additional deployment / road-use gate); Dynamic driving task (DDT) (DDT / fallback allocation); Operational design domain (ODD) (ODD / operating-area legalisation); Remote assistance (Remote human role); Remote driving (Remote human role); Remote intervention (Remote human role); Technical supervision (remote supervisor) (Remote human role)
All snapshots
2026-08-31 (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-2026-0155
Act No. 8/2009 Coll. on Road Traffic (Zákon č. 8/2009 Z. z. o cestnej premávke)
ROAT-2026-0156
Act No. 106/2018 Coll. on the Operation of Vehicles in Road Traffic (Zákon č. 106/2018 Z. z.)
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-2026-0205
Technical Report of the Working Group “Research Needs in Teleoperation” (BASt F 166b)
ROAT-2026-0214
Automated vehicles: statement of safety principles consultation
ROAT-2026-0262
Report · Analysed · Level 4 - Conference or institutional source — not yet in the public Source Library
ROAT-2026-0301
The Automated Vehicles (Permits for Automated Passenger Services) Regulations 2026
ROAT-2026-0302
Automated Vehicles Act implementation programme
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-2026-0304
Ordinance amending the Ordinance on special conditions for vehicles used in public road transport and own-account transport, NN 154/2024 (Pravilnik o izmjenama i dopunama Pravilnika o posebnim uvjetima za vozila kojima se obavlja javni cestovni prijevoz i prijevoz za vlastite potrebe)
ROAT-2026-0305
Act amending the Road Transport Act, NN 77/2026 (Zakon o izmjenama i dopunama Zakona o prijevozu u cestovnom prometu)
ROAT-2026-0306
Act No. 131/2026 Coll. amending the Slovak Road Traffic Act and related legislation (Zákon č. 131/2026 Z. z.)
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-2026-0326
Road Traffic Safety Law of the People's Republic of China – revision draft (中华人民共和国道路交通安全法（修订草案）)
ROAT-2026-0327
GB 44721-2026 – Safety Requirements for Autonomous Driving Systems
ROAT-2026-0328
MIIT conditional approval of the first two Level 3 automated-driving vehicle models (工业和信息化部许可两款L3级自动驾驶车型产品)
ROAT-2026-0329
German Road Traffic Act (StVG) §§ 1d–1g – Motor vehicles with autonomous driving function in defined operating areas (Straßenverkehrsgesetz §§ 1d–1g)
ROAT-2026-0330
Ordinance on the approval and operation of motor vehicles with autonomous driving function in defined operating areas, AFGBV (Verordnung zur Genehmigung und zum Betrieb von Kraftfahrzeugen mit autonomer Fahrfunktion in festgelegten Betriebsbereichen)
ROAT-2026-0336
Decree No. 2024-1063 of 25 November 2024 on automated road freight transport (Décret n° 2024-1063 relatif au transport routier automatisé de marchandises)

Cite this snapshot

ROAT Observatory, Post-type-approval deployment models [ROAT-MOD-SECOND-GATE], snapshot 2026-08-31 [ROAT-SNAP-SECOND-GATE-2026-08-31], DOI 10.5281/zenodo.22409314. Jozef Andraško. /modules/second-gate/2026-08-31/