ROAT Observatory / Topics and terms
ROAT Observatory / Thematic overview
UN R185 and GTR26 – requirements for automated driving
Two UN instruments for automated driving systems: their legal effects, requirements, evidence and relationship to traffic rules.
Why two instruments?
UN R185 and GTR26 provide a shared technical foundation for automated driving systems (ADS). They connect vehicle-behaviour requirements with a manufacturer’s obligation to explain and substantiate system safety. Their legal effects arise from different international agreements. [2] [3] [8]
| Question | UN R185 | GTR26 |
|---|---|---|
| Legal framework | 1958 Agreement. | 1998 Agreement. |
| Purpose | Vehicle type approval with regard to ADS and recognition among parties applying the relevant regulation. | Harmonised technical requirements implemented in national or regional law. |
| What determines application? | Entry into force, applicable version, application by a contracting party and the scope of approval. | The national or regional measure implementing the requirements and specifying the assessment procedure. |
| Recognition of approvals | Part of the 1958 Agreement’s mechanism. | A GTR does not itself establish mutual recognition of approvals. |
Comparable technical content therefore does not make the legal bases interchangeable. A project assessment must identify the legal regime through which each requirement applies. [8]
What is required of ADS?
While a feature is active, ADS performs the entire dynamic driving task (DDT): perceiving the environment, planning and deciding manoeuvres, and controlling motion. The feature has defined operating conditions, its operational design domain (ODD). UN R185 covers categories M, N, L6 and L7; paragraph 1 defines its scope and the exception for features approved under UN R157. [2]
The requirements address nominal driving, critical situations and failures. They cover appropriate speed and distances, responses to objects and events, safe interaction with other road users, and responses when continued driving under the specified conditions is no longer possible. The framework also addresses user interactions, records, updates and safety monitoring during use. [2] [3]
The connection to local law: UN R185, paragraph 6.1.2.6, and GTR26, paragraph 4.1.2.6, require compliance with traffic rules in accordance with the application of relevant law within the area of operation. This general requirement must be made concrete for the place and situation in which the vehicle drives. [2] [3]
How is compliance demonstrated?
The manufacturer prepares a safety case: structured claims about the system, supporting arguments and evidence. It must be clear which requirement a claim addresses, which assumptions it depends on, and why the evidence is sufficient. UN R185 develops this in paragraph 7.3.3, GTR26 in paragraph 5.3.3. [2] [3]
UN R185, paragraph 7.3.2.16, and GTR26, paragraph 5.3.2.16, also require justification of acceptance criteria and verification results. Scenario selection, ODD coverage and the credibility of simulation or physical testing matter. A statement that a test passed must therefore be read together with its success criterion and scope. [2] [3]
A procedural difference: GTR26, paragraph 6.3.3.1, leaves the requirement for confirmatory testing to the contracting party’s option. The procedures in UN R185 and GTR26 cannot simply be substituted for one another. [3] [5]
Where do EU and national law fit?
Implementing Regulation (EU) 2022/1426 governs ADS type approval within Article 1’s scope. Annex II, point 1.3, requires compliance with the traffic rules of the country of operation. A project needs an identified approval regime and relevant local rules. [1]
Interpretation for practice: a rule on speed, priority or responding to a police instruction can affect required ADS behaviour and testing. Human legal roles, permission to operate and authorities’ powers require separate assessment. A technical requirement does not itself settle those issues.
Adoption, application and GID
Report ECE/TRANS/WP.29/1192 confirms that AC.1 adopted the UN R185 text on 24 June 2026, with 39 votes in favour, none against and no abstentions. On the same day, AC.3 established the GTR in the Global Registry on the basis of WP.29/2026/139 together with WP.29-199-08 and related documents. [4] [5]
For UN R185, this overview uses the June version of WP.29/2026/137. WP.29-199-07 explains that changes to the April advance copy had already been incorporated into that version. [6]
Adoption is distinct from entry into force and application by an individual contracting party. This overview confirms June adoption; it does not confirm an entry-into-force date for UN R185 or a list of parties applying it. For the GTR, implementation in the relevant legal order also matters. [4] [8]
The Guidance and Interpretation Document (GID) assists interpretation. The GRVA-26-09 proposal version cited here explains in section F7 the link to local law and its application, including case law. Publication of guidance proposals or workshop outcomes does not adopt a new regulatory requirement. Further updates require checking the exact version and the competent body’s subsequent decision. [7]
Legal analysis and a practical example
Sources and versions
UN paragraph numbers refer to the listed source documents underlying the adopted texts. Adoption is established by the WP.29 report; the original proposal documents alone do not explain that status. English explanations of Slovak law are the author’s paraphrases.
- Regulation (EU) 2022/1426Consolidation of 24 March 2026. Article 1; Annex II, points 1.1.2(a) and 1.3, p. 12; Annex III, Part 2, points 3.5.5.2(c), 3.5.5.3(v) and 4.1.1, pp. 36–37.
- UN R185: ECE/TRANS/WP.29/2026/137Basis of the adopted text, June version. Introduction and paragraph 1, p. 3; paragraphs 2.3 and 2.12, pp. 4–5; paragraph 6.1.2.6, p. 13; paragraphs 7.3.2.16 and 7.3.3, pp. 33–35; assessment under section 8.
- GTR26: ECE/TRANS/WP.29/2026/139Read with amendments in WP.29-199-08. Paragraphs 3 and 4.1, pp. 22–23; paragraphs 5.3.2.16 and 5.3.3, pp. 43–44; paragraph 6.3.3.1, pp. 53–54.
- WP.29 report: ECE/TRANS/WP.29/1192Paragraphs 101 and 103, including the table on p. 30: AC.1 vote on UN R185 on 24 June 2026. Paragraph 113, p. 32: establishment of the GTR in the Global Registry on the same day.
- WP.29-199-08: amendments to the GTR26 proposalTwo-page document included in the decision recorded in paragraph 113 of WP.29/1192. Includes simulation-tool documentation and confirmatory-testing changes.
- WP.29-199-07: information on UN R185 changesRecords that changes to the April advance copy had already been integrated into the June version of WP.29/2026/137.
- GRVA-26-09: proposed Guidance and Interpretation DocumentThe version used has 69 pages; section F7, pp. 13–14. Related amendments are listed on the session page. Guidance content and publication are distinct from adoption of a normative requirement.
- UNECE: the 1958 and 1998 AgreementsOfficial explanation of mutual recognition under the 1958 Agreement and global technical regulations under the 1998 Agreement.