Modules › Second Gate › 2026-09-07
Module 02 · ROAT-MOD-SECOND-GATE
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?
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
Select a row for every coded dimension, the rationale and the ROAT records behind it.
| Regime | Deployment gate | Remote human role | Dominant deployment model | Legal status | Confidence |
|---|---|---|---|---|---|
| Current law · snapshot 2026-09-07 | |||||
| Germany – current law | Vehicle operating permit + authority approval of defined operating area + registration before autonomous road use | Technische Aufsicht – may deactivate and release specified manoeuvres; not ordinary continuous remote driving | Operating-area + technical-supervision model | In force | High |
Germany – current law | |||||
| France – current law | Prior system safety demonstration + qualified independent opinions + formal mise-en-service decision | Qualified remote intervention personnel integrated into system operation | System/service safety-assurance model | In force | High |
France – current law | |||||
| Croatia – current law | Dedicated road-traffic rules plus mandatory real-world service validation before passenger-service deployment | Remote intervention role recognised; boundaries and concurrency remain implementation questions | Owner-centred deployment-validation model | In force | High |
Croatia – current law | |||||
| Great Britain – 2026 transitional current law | Automated Passenger Service permit under Part 5 of the AV Act 2024 (in force 15 May 2026) for eligible passenger services; other deployments run as pilots under vehicle special orders; Part 1 authorisation not yet commenced at snapshot | No German-style technical supervisor as universal core role; remote functions depend on operating model | Staged-permit model (APS permits and pilots ahead of Part 1 authorisation) | Partly in force: Part 5 (APS permits) from 15 May 2026; Part 1 authorisation and Part 4 marketing restrictions commence in 2027 | High |
Great Britain – 2026 transitional current law | |||||
| China – current transitional regime | Product admission is followed by geographically/functionally limited road-access pilot rather than unrestricted deployment | No mature national standalone technical-supervisor/remote-operator role architecture yet | Manufacturer/user-entity conditional deployment model | In force as pilot / conditional admission architecture | High |
China – current transitional regime | |||||
| Slovakia – current law (31 Aug 2026) | Predominantly § 49 test-operation permit; the only non-test deployment gate is the operational permit for automated delivery vehicles under § 52 of Act 106/2018; no general dedicated commercial FAV deployment gate | No general commercial FAV technical-supervision/control-centre role in force; supervising driver (dohliadajúci vodič) with remote takeover for automated delivery vehicles (Act 8/2009 § 2(2)(w), § 5(6)) | Testing-permit / technical-leading model | In force | Medium–High |
Slovakia – current law (31 Aug 2026) | |||||
| Sensitivity · prospective law (not current-law scores) | |||||
| China – 2026 Road Traffic Safety Law draft | Registered AV may activate ADS only within design operating conditions; national road-use rules sit above technical conformity | Remote human role remains underdeveloped in the draft | Manufacturer-centred road-use and enforcement model | Draft / public consultation | High |
China – 2026 Road Traffic Safety Law draft prospective | |||||
| Slovakia – CPT 1329 prospective model | Operator licence + specific operation approval would create a genuine second gate | Supervision operator + control centre; current draft boundary with remote driving needs correction | Licensed-operator + control-centre deployment model | Draft / parliamentary print 1329 | High for text; prospective only |
Slovakia – CPT 1329 prospective model prospective | |||||
What changed
20 cells in 2 rows differ from the superseded snapshot. Every difference is a deliberate recoding; the reason is recorded in the second-pass statement and the caveats below.
| Row | Dimension | Before (2026-08-31) | After (2026-09-07) |
|---|---|---|---|
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Regulatory object | Authorised self-driving vehicle / responsible entity architecture; APS service permits as transitional deployment route | APS permit holder and pilot-operator architecture as the 2026 transitional route; authorised self-driving vehicle / responsible-entity architecture enacted but not yet commenced |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Additional deployment / road-use gate | Automated Passenger Service permit for eligible passenger services before full 2027 implementation; wider general authorisation framework still being completed | Automated Passenger Service permit under Part 5 of the AV Act 2024 (in force 15 May 2026) for eligible passenger services; other deployments run as pilots under vehicle special orders; Part 1 authorisation not yet commenced at snapshot |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | ODD / operating-area legalisation | Authorised domain / territory forms part of self-driving authorisation and safety principles | Deployment area fixed through APS permit and pilot conditions; authorised domain under Part 1 of the AV Act not yet in force |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Primary accountable organisational actor | ASDE / licensed service operator / NUiC-type actor architecture depending on service and vehicle use | APS permit holder / pilot operator; ASDE and NUiC-operator architecture in Part 1 of the AV Act not yet in force |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Traffic-offence allocation | AV Act reallocates legal responsibility away from user where vehicle is driving itself, subject to statutory architecture | No general rule in force at snapshot: Part 1 reallocation of legal responsibility away from the user not yet commenced; pilot and permit conditions require reporting of infractions |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Civil liability / insurance | Dedicated insurance/liability reforms are part of UK AV framework | Dedicated: Automated and Electric Vehicles Act 2018 s. 2 makes the insurer liable for accidents caused by a listed automated vehicle driving itself; AV Act 2024 insurance and liability provisions pending |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Data / logging | Information, incident and in-use regulatory duties form part of full Act architecture | Reporting under APS permit conditions and pilot conditions (collisions, infractions); information duties of Part 1 of the AV Act not yet in force |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Post-market / in-use oversight | In-use regulation and safety-principles monitoring planned as core of full implementation | Oversight through APS permit monitoring and pilot conditions; in-use regulation under Part 1 planned for full implementation |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | 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. | APS Regulations 2026 treat a material change in circumstances as a ground for permit variation, suspension or withdrawal; AV Act ss 5, 8 and 9 authorisation powers not yet commenced |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | 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. | Permit-level: variation, suspension or withdrawal of an APS permit or pilot on breach or incident; general authorisation lifecycle under Part 1 remains implementation-stage through 2027 |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Dominant deployment model | Authorised-entity / staged-permit model | Staged-permit model (APS permits and pilots ahead of Part 1 authorisation) |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Legal status | Partly in force; full AV Act framework planned for 2027 | Partly in force: Part 5 (APS permits) from 15 May 2026; Part 1 authorisation and Part 4 marketing restrictions commence in 2027 |
| Great Britain – 2026 transitional current law ROAT-JUR-UK | Primary-source anchor | Automated Vehicles Act 2024; SI 2026/439; DfT implementation programme | Automated Vehicles Act 2024 and Commencement No. 1–3 Regulations (SI 2025/1339, 2026/437, 2026/731); SI 2026/439; AEVA 2018 s. 2; DfT implementation programme |
| Slovakia – current law (31 Aug 2026) ROAT-JUR-SK | Additional deployment / road-use gate | Predominantly § 49 test-operation permit; no general dedicated commercial FAV deployment gate | Predominantly § 49 test-operation permit; the only non-test deployment gate is the operational permit for automated delivery vehicles under § 52 of Act 106/2018; no general dedicated commercial FAV deployment gate |
| Slovakia – current law (31 Aug 2026) ROAT-JUR-SK | ODD / operating-area legalisation | ODD can be reflected in permit/test conditions but is not yet a general autonomous-operation authorisation object | ODD reflected in permit/test conditions; for automated delivery vehicles the operational permit fixes territory, route and time (§ 52(6)); not yet a general autonomous-operation authorisation object |
| Slovakia – current law (31 Aug 2026) ROAT-JUR-SK | Primary accountable organisational actor | Permit holder / owner / driver-type roles; no general licensed FAV operator architecture in force | Permit holder / owner / driver-type roles; operator holding an operational permit for automated delivery vehicles (§ 52); no general licensed FAV operator architecture in force |
| Slovakia – current law (31 Aug 2026) ROAT-JUR-SK | Remote human role | No general commercial FAV technical-supervision/control-centre role in force | No general commercial FAV technical-supervision/control-centre role in force; supervising driver (dohliadajúci vodič) with remote takeover for automated delivery vehicles (Act 8/2009 § 2(2)(w), § 5(6)) |
| Slovakia – current law (31 Aug 2026) ROAT-JUR-SK | Data / logging | Test-operation documentation and technical rules, but no general FAV logging architecture equivalent to CPT 1329 | Test-operation documentation and technical rules; supervision log and permit-conditioned operational data for automated delivery vehicles (Act 8/2009 § 6(7); Act 106/2018 § 52(6)–(7)); no general FAV logging architecture equivalent to CPT 1329 |
| Slovakia – current law (31 Aug 2026) ROAT-JUR-SK | Commercial service pathway | No clear general pathway from EU type approval to ordinary commercial driverless operation | No general pathway from EU type approval to ordinary commercial driverless operation; goods delivery by automated delivery vehicles is the only permitted service use (Act 8/2009 § 55b; Act 106/2018 § 52) |
| Slovakia – current law (31 Aug 2026) ROAT-JUR-SK | Primary-source anchor | Act 106/2018 § 49; Decree 131/2018; Act 131/2026 effective 1 Sep 2026 only prospectively at snapshot | Act 106/2018 §§ 49, 52; Act 8/2009 §§ 2, 5, 6, 55b; Decree 131/2018; Act 131/2026 effective 1 Sep 2026 only prospectively at snapshot |
Snapshot record
ROAT-SNAP-SECOND-GATE-2026-09-07 · legal snapshot date 2026-09-07 · data exported 2026-09-06ROAT-SNAP-SECOND-GATE-2026-08-31 · 20 cells recodedSources cited in this snapshot
Cite this snapshot
ROAT Observatory, Post-type-approval deployment models [ROAT-MOD-SECOND-GATE], snapshot 2026-09-07 [ROAT-SNAP-SECOND-GATE-2026-09-07], DOI 10.5281/zenodo.22546848. Jozef Andraško. /modules/second-gate/2026-09-07/