{ "module": "ROAT-MOD-SECOND-GATE", "snapshot_date": "2026-09-07", "exported_from_hub": "2026-09-06T13:49:54.688Z", "source_sheet": "Post-Type-Approval Deployment Models", "rows": [ { "regime_id": "ROAT-JUR-DE", "regime_label": "Germany – current law", "records": [ "ROAT-2026-0329", "ROAT-2026-0330", "ROAT-2026-0170", "ROAT-2026-0205" ], "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", "panel": "current", "regulatory_object": "Autonomous vehicle + approved defined operating area + keeper + technical supervision", "technical_baseline": "EU/UNECE technical baseline plus German autonomous-vehicle operating permit under StVG/AFGBV", "deployment_gate": "Vehicle operating permit + authority approval of defined operating area + registration before autonomous road use", "odd_legalisation": "ODD is translated into a geographically defined and authority-approved 'festgelegter Betriebsbereich'", "authority": "KBA / competent road authority depending on decision layer", "accountable_actor": "Halter (vehicle keeper), with manufacturer duties and Technische Aufsicht functions separately allocated", "remote_role": "Technische Aufsicht – may deactivate and release specified manoeuvres; not ordinary continuous remote driving", "ddt_allocation": "ADS performs DDT; system must comply with road rules and achieve minimum-risk condition where necessary", "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": "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", "in_use_oversight": "KBA/authority market surveillance and permit supervision", "material_change": "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.", "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for vehicle changes; suspension/withdrawal pending clarification under § 6; operating-area approval can be suspended/withdrawn under § 10 when safety assumptions or infrastructure conditions cease to hold.", "service_pathway": "Possible within approved operating area and applicable transport/service law", "dominant_model": "Operating-area + technical-supervision model", "legal_status": "In force", "primary_source_anchor": "StVG §§ 1d–1g; AFGBV §§ 4, 7–11, 13–14" }, { "regime_id": "ROAT-JUR-FR", "regime_label": "France – current law", "records": [ "ROAT-2026-0307", "ROAT-2026-0308", "ROAT-2026-0336" ], "rationale": "France regulates the socio-technical transport system, not merely the vehicle. Technical approval is necessary but not sufficient for service deployment.", "confidence": "High", "panel": "current", "regulatory_object": "Automated road transport system: vehicle + technical system + route/zone + service organisation", "technical_baseline": "EU type approval / relevant vehicle technical approval", "deployment_gate": "Prior system safety demonstration + qualified independent opinions + formal mise-en-service decision", "odd_legalisation": "Safety case is tied to intended route or zone and service configuration", "authority": "Service organiser / competent transport and road authorities within statutory framework", "accountable_actor": "Automated transport-system/service operator architecture rather than vehicle owner alone", "remote_role": "Qualified remote intervention personnel integrated into system operation", "ddt_allocation": "ADS performs DDT; remote intervention supports defined situations without collapsing into ordinary remote driving", "offence_allocation": "Dedicated criminal-responsibility adaptations exist; detailed allocation depends on operating mode and legal actor", "civil_liability": "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", "in_use_oversight": "In-use system safety management and authority oversight tied to service operation", "material_change": "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.", "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.", "service_pathway": "Yes. Passenger automated-road-transport-system pathway extended to automated road freight by Décret 2024-1063, effective 28 Nov 2024.", "dominant_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" }, { "regime_id": "ROAT-JUR-HR", "regime_label": "Croatia – current law", "records": [ "ROAT-2026-0262", "ROAT-2026-0303", "ROAT-2026-0304", "ROAT-2026-0305" ], "rationale": "Croatia is especially useful for the bridge from EU type approval to local service validation in real operating conditions.", "confidence": "High", "panel": "current", "regulatory_object": "Fully automated vehicle + owner + operating area + transport service + remote intervention arrangements", "technical_baseline": "EU ADS type approval", "deployment_gate": "Dedicated road-traffic rules plus mandatory real-world service validation before passenger-service deployment", "odd_legalisation": "Operating area / territory forms part of deployment validation and service conditions", "authority": "Transport/road authorities; licensing authority under national transport framework", "accountable_actor": "Vehicle owner is a central road-traffic accountability actor; service operator duties exist at transport layer", "remote_role": "Remote intervention role recognised; boundaries and concurrency remain implementation questions", "ddt_allocation": "ADS performs driverless operation; remote intervention supports defined operational/safety functions", "offence_allocation": "Owner bears dedicated responsibility for traffic offences of fully automated vehicle in driverless operation", "civil_liability": "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", "in_use_oversight": "Service/deployment oversight, incident management and licence conditions", "material_change": "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.", "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.", "service_pathway": "Yes, through transport licensing after service-level real-world validation", "dominant_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" }, { "regime_id": "ROAT-JUR-UK", "regime_label": "Great Britain – 2026 transitional current law", "records": [ "ROAT-2026-0171", "ROAT-2026-0214", "ROAT-2026-0301", "ROAT-2026-0302" ], "rationale": "UK is a control case showing that actor/institution design can legally precede full ordinary deployment.", "confidence": "High", "panel": "current", "regulatory_object": "APS permit holder and pilot-operator architecture as the 2026 transitional route; authorised self-driving vehicle / responsible-entity architecture enacted but not yet commenced", "technical_baseline": "UK vehicle approval/self-driving authorisation architecture under AV Act implementation programme", "deployment_gate": "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", "odd_legalisation": "Deployment area fixed through APS permit and pilot conditions; authorised domain under Part 1 of the AV Act not yet in force", "authority": "Secretary of State / DVSA and relevant local transport authority for APS consent", "accountable_actor": "APS permit holder / pilot operator; ASDE and NUiC-operator architecture in Part 1 of the AV Act not yet in force", "remote_role": "No German-style technical supervisor as universal core role; remote functions depend on operating model", "ddt_allocation": "Authorised ADS performs self-driving task; user-in-charge duties are separated where relevant", "offence_allocation": "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", "civil_liability": "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", "data_logging": "Reporting under APS permit conditions and pilot conditions (collisions, infractions); information duties of Part 1 of the AV Act not yet in force", "in_use_oversight": "Oversight through APS permit monitoring and pilot conditions; in-use regulation under Part 1 planned for full implementation", "material_change": "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", "revalidation": "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", "service_pathway": "APS permit enables staged commercial passenger deployment in 2026", "dominant_model": "Staged-permit model (APS permits and pilots ahead of Part 1 authorisation)", "legal_status": "Partly in force: Part 5 (APS permits) from 15 May 2026; Part 1 authorisation and Part 4 marketing restrictions commence in 2027", "primary_source_anchor": "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" }, { "regime_id": "ROAT-JUR-CN", "regime_label": "China – current transitional regime", "records": [ "ROAT-2026-0327", "ROAT-2026-0328" ], "rationale": "China already demonstrates the second-gate logic in practice even before the new national Road Traffic Safety Law is enacted.", "confidence": "High", "panel": "current", "regulatory_object": "Conditionally admitted L3 vehicle + designated user entity + specified roads/speeds + road-access pilot", "technical_baseline": "Conditional product admission; GB 44721-2026 adopted but effective from 1 July 2027", "deployment_gate": "Product admission is followed by geographically/functionally limited road-access pilot rather than unrestricted deployment", "odd_legalisation": "Specified road segments, speed limits and operating conditions function as legally bounded ODD/geofence", "authority": "MIIT and participating local authorities under pilot framework", "accountable_actor": "Designated user entity + manufacturer within monitored pilot architecture", "remote_role": "No mature national standalone technical-supervisor/remote-operator role architecture yet", "ddt_allocation": "L3 ADS performs DDT within approved conditions; human fallback remains relevant to L3 design", "offence_allocation": "Current pilot arrangements do not yet equal the proposed national manufacturer-centric offence rule", "civil_liability": "Existing compulsory insurance/general rules apply; national AV-specific insurance provisions are proposed, not yet enacted", "data_logging": "Pilot monitoring and safety evidence required", "in_use_oversight": "Government monitoring and conditional product/road-access controls", "material_change": "Pilot/product approval is version- and condition-sensitive; exact general change-control rule is still evolving", "revalidation": "Road-access pilots and reassessment provide staged evidence before expansion", "service_pathway": "Limited pilot deployment; not unrestricted nationwide commercial L3 operation", "dominant_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" }, { "regime_id": "ROAT-JUR-CN:RTSL-DRAFT", "regime_label": "China – 2026 Road Traffic Safety Law draft", "records": [ "ROAT-2026-0326", "ROAT-2026-0327", "ROAT-2026-0328" ], "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", "panel": "prospective", "regulatory_object": "Autonomous vehicle/ADS + manufacturer/importer + road-use accountability layer", "technical_baseline": "Road-traffic-rule conformity test + technical/product admission; GB 44721-2026 technical pillar", "deployment_gate": "Registered AV may activate ADS only within design operating conditions; national road-use rules sit above technical conformity", "odd_legalisation": "Manufacturer/importer must ensure ADS cannot activate outside design operating conditions", "authority": "Public-security / product / transport authorities under State Council allocation", "accountable_actor": "Manufacturer/importer becomes direct central accountability actor for ADS-active traffic violations", "remote_role": "Remote human role remains underdeveloped in the draft", "ddt_allocation": "ADS continuously performs full DDT within design operating conditions; L2 assistance is expressly distinguished", "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": "Compulsory motor-vehicle liability insurance required; commercial insurance encouraged; detailed regime delegated", "data_logging": "Strong accident evidence/data duties and manufacturer data-provision obligations", "in_use_oversight": "National road-safety risk assessment can support suspension/prohibition, recall, repair, replacement/refund/compensation measures", "material_change": "Unauthorised ADS modification prohibited and sanctioned; post-market risk layer is explicit", "revalidation": "Implementing rules still required; change/revalidation mechanics not fully specified", "service_pathway": "Supports ordinary national road operation once enacted and implementing rules exist", "dominant_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" }, { "regime_id": "ROAT-JUR-SK", "regime_label": "Slovakia – current law (31 Aug 2026)", "records": [ "ROAT-2026-0155", "ROAT-2026-0156", "ROAT-2026-0306", "ROAT-2026-0159" ], "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", "panel": "current", "regulatory_object": "EU-approved vehicle + national test-operation / narrower operational exceptions", "technical_baseline": "EU/UNECE type-approval framework can provide high technical maturity", "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", "odd_legalisation": "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", "authority": "Ministry of Transport / road and police authorities depending on permit", "accountable_actor": "Permit holder / owner / driver-type roles; operator holding an operational permit for automated delivery vehicles (§ 52); no general licensed FAV operator architecture in force", "remote_role": "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))", "ddt_allocation": "Current framework remains structurally driver/test oriented; dedicated driverless DDT allocation is incomplete", "offence_allocation": "No complete general rule for traffic offences committed by driverless FAV", "civil_liability": "General motor insurance/civil liability; no mature FAV-specific allocation", "data_logging": "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", "in_use_oversight": "Primarily permit/test supervision rather than mature in-use driverless market oversight", "material_change": "Handled through technical approval/test permit changes; no general deployment change-control regime", "revalidation": "Retesting tied mainly to test-operation context", "service_pathway": "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)", "dominant_model": "Testing-permit / technical-leading model", "legal_status": "In force", "primary_source_anchor": "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" }, { "regime_id": "ROAT-JUR-SK:1329", "regime_label": "Slovakia – CPT 1329 prospective model", "records": [ "ROAT-2026-0159", "ROAT-2026-0040", "ROAT-2026-0311", "ROAT-2026-0326", "ROAT-2026-0329", "ROAT-2026-0330" ], "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", "panel": "prospective", "regulatory_object": "Licensed FAV operator + approved operation + control centre + supervision operator + ODD", "technical_baseline": "EU/UNECE technical approval remains baseline", "deployment_gate": "Operator licence + specific operation approval would create a genuine second gate", "odd_legalisation": "ODD and defined roads/territory become part of operational documentation / approval", "authority": "Ministry of Transport with police/other authority inputs", "accountable_actor": "Licensed FAV operator becomes organisational centre of responsibility", "remote_role": "Operátor dohľadu + riadiace centrum; current draft boundary with remote driving needs correction", "ddt_allocation": "ADS should remain DDT performer; current wording risks transferring DDT remotely to supervisor in some clauses", "offence_allocation": "Still requires explicit rule for offences committed by FAV while ADS is active", "civil_liability": "Insurance/organisational requirements improve, but full civil/product/service allocation remains to be clarified", "data_logging": "Dedicated recording system proposed", "in_use_oversight": "Operator/licence supervision and operational duties create stronger in-use layer", "material_change": "Draft requires clearer material-change / software-version triggers", "revalidation": "Local validation/testing is structurally present but should be proportionate and recognise existing type-approval/foreign evidence", "service_pathway": "Potential general commercial pathway if enacted and separated from test-only logic", "dominant_model": "Licensed-operator + control-centre deployment model", "legal_status": "Draft / parliamentary print 1329", "primary_source_anchor": "CPT 1329 §§ 49a–49f and related amendments" } ], "purpose": [ "ROAT", "Post-Type-Approval Deployment Models – Automated Vehicles", "Scope", "Comparative model of the legal gate between technical vehicle/ADS approval and lawful real-world deployment. Current law and draft/prospective regimes are separated. Snapshot: 31 August 2026." ] }