ROAT Regulatory Brief · Issue 000 ·
The legal conditions for AV deployment
Read this issue on SubstackWelcome to the first ROAT Regulatory Brief. I created ROAT Observatory to connect my research and teaching on the legal regulation of automated transport. This newsletter brings together selected developments in international, EU and national law, with primary sources and a short explanation of their significance. The question guiding this first issue is what a legal framework needs to address when automated vehicles move from testing into operation.
Main story · Slovakia
Parliament adopts the automated vehicles bill
On 16 September 2026, the Slovak Parliament adopted a bill extending the legal framework for testing and operating automated vehicles, including their use in transport services. The proposed commencement date is 1 December 2026. Parliamentary adoption and entry into force remain separate stages.
The adopted provisions establish operator licensing and approval of fully automated vehicle operation. The approval is tied to the relevant vehicle type or group, automated driving system, operational design domain and specified roads or areas. The text also distinguishes the driver from the oversight operator and addresses technical supervision, operator duties and records of driving modes, interventions and safety incidents.
My reading is that the practical significance lies in how these obligations fit together. Deployment requires a legally defined operating arrangement, including who supervises the vehicle, what they may do and what evidence must be retained. The implementing rules on the operation of fully automated vehicles will therefore be an important part of the next stage. ROAT’s analysis examines the adopted provisions and the questions they leave for implementation.
Operating example · Germany
A bounded route into freight operations
On 15 September, Lidl announced a project with Einride using a driverless electric truck for deliveries between a distribution centre and a nearby store in Edermünde. Lidl reports approval by Germany’s Federal Motor Transport Authority, KBA, for operation on public roads. The announced project is limited to four months, with a further phase envisaged after validation.
This is a useful case for examining the relationship between vehicle approval and permission for a particular operation. The announcement describes a specific deployment. It does not establish the full scope or conditions of the underlying administrative decisions.
Document watch · UNECE
A revised ADS proposal at GRVA
UNECE’s official register lists GRVA-26-09/Rev.1, published on 17 September, as an ADS workshop proposal to supersede ECE/TRANS/WP.29/GRVA/2026/24. The entry is classified as an informal document. I am flagging the revision for follow-up. Its publication alone does not establish the outcome of GRVA’s consideration or any subsequent WP.29 decision. A substantive comparison will require the revised text and the relevant meeting outcome.
Legal context · European Union
Which part of the driving task does the human perform?
An earlier development remains relevant to that question. Commission Implementing Regulation (EU) 2026/481, adopted in March, amended the EU framework for approving automated driving systems. Among its changes are revised definitions of operational and tactical functions and requirements for automated valet parking. These provisions offer a useful starting point for analysing what a person actually does when interacting with an ADS. This is background to the current discussion, rather than a new September measure.
Worth reading · Spain
How a testing framework structures the evidence
Spain’s ES-AV instruction, VEH2025/07 of 22 May 2025, is a useful comparative reference. It structures testing through controlled, extensive and pre-deployment phases and provides different routes into the authorisation process, including recognition of testing authorisations from the European Economic Area. For researchers and operators, it offers a concrete framework for examining how permissions, test conditions and supporting evidence develop across successive stages. It is included here as background reading.
On ROAT
Explore the questions through practical examples
ROAT now includes short scenarios on testing in rain, the human role when a vehicle encounters an obstacle, and choosing an appropriate speed. They connect legal sources with concrete decisions and support my Automated Transport Regulation Clinic at the Faculty of Law, Comenius University Bratislava. I am adding materials gradually and welcome suggestions for further cases.
What I’m watching next
Implementation and the documentary record
My next priorities are the completion of Slovakia’s legislative process, the implementing decree on fully automated vehicle operation, and the documentary outcome of the September GRVA session. Each will help clarify how the emerging framework is to be applied.
Thank you for reading. I would be grateful for feedback, corrections and suggestions for future issues.