Automated and connected vehicle regulation by continent (October 2026): who is most advanced, and a roadmap to 2030

1. The question

Which jurisdiction has the most complete legal framework for automated and connected vehicles, on each continent? And what is actually scheduled between now and 2030?

The technology, the deployment scoreboard and the safety data are a separate subject. This article goes one layer deeper, into the law itself. It asks how each jurisdiction answers the same questions: who approves the vehicle, who permits the service, who is liable, what must be recorded and reported, who gets the ticket when nobody is driving, how remote operation is governed, and what is being done about V2X.

The answer is not the same as “who has the most robotaxis”. The United States leads on operations but has no federal AV statute. Germany has had an operative Level 4 law since 2021 but almost no regular services under it. The UAE has strict operator liability and live regulator telemetry. China is the only country that combines a national approval route, a mandatory safety standard, a draft national law and a large V2X installed base.

This is a status atlas as of 21 October 2026. Section 10 scores a leader per continent on a rubric set out in full; it is my assessment, not an official ranking. Section 11 is a dated roadmap, with each milestone marked announced or expected.

2. How to read AV regulation: the building blocks

Every jurisdiction that wants driverless vehicles on public roads must answer seven questions (Figure 1).

Figure 1. Seven questions, from vehicle approval to liability, sit between a global layer of UN instruments and an infrastructure layer of V2X. Source: author’s schematic based on [2][3][15][20][28][51].

1. Vehicle approval. Is the automated driving system (ADS) approved by an authority before sale (type approval), or does the manufacturer certify compliance itself (self-certification)?
2. Operation permit. Where, when and at what scale may the vehicle run? This covers the operational design domain (ODD), the operating area, fleet caps and local testing.
3. Operator licensing and remote operation. Who runs the fleet, and what remote assistance or “technical supervision” must exist?
4. Traffic law. Who receives the ticket when a vehicle with no driver breaks a rule?
5. Data and reporting. What must the vehicle record (the Data Storage System for Automated Driving, DSSAD), and what must be reported to whom?
6. Liability and insurance. Who pays a victim, and on what basis?
7. V2X. Is spectrum assigned, is a technology chosen, and is there a deployment mandate?

The levels used throughout are those of SAE J3016 [1]. At Level 3 a human must take over on request. At Level 4 the system must reach a minimal risk condition by itself.

3. The global layer: UN instruments and road-traffic conventions

UN R185 and GTR No. 26. On 24 June 2026 the UNECE World Forum (WP.29) adopted a UN Regulation and a Global Technical Regulation on ADS [2][3]. UN R185 sits under the 1958 Agreement, which governs mutual recognition of type approvals. GTR No. 26 sits under the 1998 Agreement, which provides a technical baseline that countries such as the US must transpose into their own rules [6][5]. The requirements include:

• an audited Safety Management System across the whole lifecycle;
• a safety case showing that the ADS reaches “at least the level of safety of a competent and careful human driver” [3];
• multi-pillar validation by simulation, track and real-world testing [3][4];
• in-service monitoring, incident reporting and data recording [2][3][5].

Entry into force has not been confirmed. Shoosmiths wrote in July that “the precise timing has not yet been confirmed” [3]. Applied Intuition expected it to take effect “as early as 2027 in type-approval markets” [4]. One secondary headline gives January 2027 [70]; I could not verify that date. For US adoption, NHTSA rulemaking is still required [12].

UN R157 (ALKS). The motorway Level 3 regulation started at 60 km/h. A 2022 amendment raised the limit to 130 km/h [9].

Vienna Convention, art. 34bis. On 14 July 2022 a new article 34bis of the 1968 Vienna Convention on Road Traffic took effect [7]. It treats the requirement for a driver as satisfied while an automated driving system complies with domestic technical regulations and domestic operating legislation [8]. It does not authorize automated driving on its own. Each country must still legislate, including on liability [7]. The United States and China are not parties to the Vienna Convention [8]. Their national law is therefore the only constraint.

Standards. The R185 safety case draws on industry practice in scenario-based testing and safety of the intended functionality (ISO 34502, ISO 21448) and on the UL 4600 safety-case standard. I have not verified how directly each is referenced in the adopted texts, so treat these as context only.

4. North America

United States: federal

The US has no federal AV statute. Federal control works through vehicle standards (FMVSS), exemptions and crash reporting under the Standing General Order [10].

• Approval route. Manufacturers self-certify compliance with the Federal Motor Vehicle Safety Standards (FMVSS), so a vehicle without manual controls needs an exemption or a rewritten standard [10][13].
• Exemptions. On 30 July 2026 NHTSA granted Zoox the first commercial Part 555 exemption, capped at 2,500 vehicles a year, “the maximum under current law” [11]. The cap rises to 5,000 in the second year [76].
• Data and reporting. The amended Standing General Order (SGO) requires serious crashes to be reported within five days, and dockets on remote assistance and first-responder interaction are expected [10][12].
• Enforcement after the fact. NHTSA used a Special Order in September 2026 to test Tesla’s self-certification of the Cybercab [67].
• Congress. The SELF DRIVE Act of 2026 (H.R. 7390) has stalled since February 2026, while the House surface transportation bill would create FMCSA rules for commercial AVs [12][14].

United States: states

States control operation, licensing and traffic law. A 2024 survey counted 19 states that permit AV operation subject to conditions [17]. That count is two years old and should be rechecked.

• California. DMV regulations finalized on 28 April 2026 let police send “notices of autonomous vehicle noncompliance” to manufacturers from 1 July 2026, with a two-minute emergency-geofence rule and a 1,000,000-mile threshold for driverless heavy-duty AVs [15].
• Texas. Under SB 2807, commercial AV operators have needed TxDMV authorization since 28 May 2026 [16].
• Arizona and Florida. Both have statutes permitting operation; Florida requires a “minimal risk condition” after a system failure [17].

Canada and Mexico

Transport Canada published an updated AV safety framework in 2025. Public-road use remains “limited to temporary pilot projects” run by provinces [18]. Ontario’s pilot, running since 2016, had 15 organizations approved to test driverless vehicles as of June 2025. It expires in October 2027 and no successor has been announced [18]. No driverless ride service operates in Canada [18]. Mexico has no federal AV framework and no federal bill [19].

Building block	United States	Canada	Mexico
Legal basis for driverless ops	State statutes (CA, TX, AZ, FL…) [15][16][17]	Provincial pilots only [18]	None [19]
Approval route	Self-certification + Part 555 exemption (2,500/yr) [11]	CMVSS; pilot permits [18]	—
Traffic law	CA noncompliance notices to manufacturer [15]	Laws assume a human driver [18]	—
Data and reporting	SGO (5-day serious crashes) [10]	Pilot conditions	—
Remote operation	Federal dockets pending [12]	Remote operator allowed in Ontario pilot [18]	—

5. Europe

European Union

• Approval. Regulation (EU) 2019/2144 and Implementing Regulation (EU) 2022/1426 provide EU type approval for the ADS of fully automated vehicles. Approval is limited to 1,500 units per type per year for categories M and N. It covers vehicles in a specified area, on a fixed route between fixed points, or in automated parking [20]. Implementing Regulation (EU) 2026/481, in force since 24 March 2026, removed the registration limit for automated parking systems [21]. The Commission plans a wider type-approval reform for unlimited series, then regulatory sandboxes and automated driving corridors [22].
• Pre-deployment. More than ten Member States agreed on 8 June 2026 to sign a declaration on cross-border AV testbeds. The declaration aims at mutual recognition of approvals and coordinated permitting. The Connecting Europe Facility set aside €20 million for AV digital infrastructure [26].
• Liability. The revised Product Liability Directive (EU) 2024/2853 explicitly covers software, including over-the-air (OTA) updates and AI systems. It presumes a defect where the claimant faces “excessive difficulties, in particular, due to technical or scientific complexity”. Member States must transpose it by 9 December 2026 [24].
• AI Act. Article 109 of the AI Act amends Regulation 2019/2144. When the Commission adopts implementing acts on AI safety components, the AI Act’s high-risk requirements “shall be taken into account” [25]. The effect on vehicles is indirect and runs through type approval.
• C-ITS. The revised ITS Directive (EU) 2023/2661 had to be transposed by 21 December 2025. Binding C-ITS specifications are targeted for 2026–2027 [27].

Germany

Germany’s 2021 Level 4 law (Road Traffic Act, StVG §§1d–1l) and its implementing regulation (AFGBV) allow driverless operation in an approved, geofenced operating area [22]:

• the KBA approves the vehicle and its ODD, using EU type approval as the basis;
• a separate national authority approves the operating area [20];
• a technical supervisor in a control centre must always be available, able to deactivate the vehicle or approve alternative manoeuvres [22];
• keepers have extensive data-storage duties, covering accidents, near-accidents and evasive manoeuvres [22];
• a remote-driving ordinance (StVFernLV), in force since 1 December 2025, replaces case-by-case exemptions for teleoperation with a standard permit route [22].

Even so, “no company has transitioned a Level 4 pilot project into regular operation” [22]. At Level 3 the law exists but the products are retreating: BMW said in February 2026 it will discontinue its Level 3 system [66].

France

Decree 2021-873 of 29 June 2021, applicable from 1 September 2022, created the framework for automated road transport systems (STRA) on predefined routes or zones [23][73]. Fully automated systems must be supervised by a person in charge of remote intervention [23]. Approval rests on two safety demonstrations, one by the system designer and one by the transport organiser, each reviewed by qualified bodies approved by the STRMTG, the national guided-transport safety agency [73]. An annual external audit report and serious-accident reports go to the prefect, the police authority and the road manager [23].

Ordinance 2021-443 of 14 April 2021 sets the criminal-liability rules. While the delegated-driving system has dynamic control, the driver is not criminally liable for offences resulting from its manoeuvres. The manufacturer or its representative answers for involuntary-harm offences if fault is established and pays the fine for minor offences. For automated road transport systems the service organiser or operator bears the same liability, and the remote operator answers for their own interventions [74].

United Kingdom

The Automated Vehicles Act 2024 received Royal Assent on 20 May 2024 [71]. It creates authorization for self-driving vehicles. An authorised self-driving entity (ASDE) is responsible for the vehicle’s driving and must meet requirements on financial standing and repute. A licensed operator must supervise any journey with no user in charge [28].

• Liability. Under the Automated and Electric Vehicles Act 2018, victims claim directly against the insurer even with no driver [28].
• Passenger services. The Automated Passenger Services (APS) permit regulations came into force on 15 May 2026. As of September, “No operator has completed even the first stage of the APS approval process in London” [30].
• Safety standard. A draft statement of safety principles was published on 17 June 2026. It sets the bar at “careful and competent human drivers”. After consultation closed in September, it is to be laid before Parliament in 2027 [29].
• Full implementation of the Act is planned for the second half of 2027 [28].

Building block	EU	Germany	France	UK
Legal basis	GSR + 2022/1426 [20]	StVG L4 + AFGBV (2021) [22]	Decree 2021-873 [23]	AV Act 2024, staged to H2 2027 [28]
Approval	EU ADS type approval, 1,500/type/yr [20]	KBA + operating-area approval [20]	Safety demonstrations + AQO review [73]	Authorisation + APS permits [28][30]
Liability	PLD 2024/2853 from Dec 2026 [24]	Product liability + PLD [22]	Ordinance 2021-443: maker/operator answers while system drives [74]	Insurer-first (AEVA 2018) [28]
Data	R185 DSSAD (pending) [2]	Keeper storage duties [22]	Audit + accident reports [23]	Call for evidence 2025–26 [28]
Remote operation	—	Technical supervisor; StVFernLV [22]	Remote intervenor required [23]	Licensed operator for no-user-in-charge journeys [28]

6. Asia

China

China combines city rules, national product access and a national law in progress.

• City rules. Beijing’s Autonomous Vehicle Regulations, in force since 1 April 2025, cover “Level 3 and higher systems” [31].
• National product access. A pilot launched in November 2023 led to nine automakers being selected in June 2024 [32]. The first Level 3 product approvals came on 15 December 2025, for designated expressway sections at up to 50 and 80 km/h [33].
• Marketing and OTA. In April 2025 MIIT told carmakers to stop using terms such as “autonomous driving” for driver assistance, and to treat emergency OTA updates as recalls [34].
• Mandatory standard. GB 44721—2026, Safety Requirements for Autonomous Driving Systems of Intelligent Connected Vehicles, was approved on 30 July 2026 and becomes mandatory on 1 July 2027 [39]. It covers L3 and L4 systems in categories M and N and sets the bar at “at least as safe as a competent and attentive driver”. It requires a driver-readiness monitor for L3, and checks safety capability across design, production and post-deployment through dossiers and third-party testing [39].
• Draft national law. On 25 August 2026 the State Council submitted a Road Traffic Safety Law amendment with an autonomous-vehicle chapter to the NPC Standing Committee for first reading [35][36][37]:
  • if a violation occurs while autonomous driving is active, the manufacturer or importer is responsible;
  • according to two reports, a company claiming the system was not involved must prove it; the official summary does not set out evidentiary rules [36][38];
  • AVs fall under compulsory motor insurance;
  • vehicles must pass road-rule tests and be registered before driving autonomously [38];
  • handover cases are left to “future regulation and judicial practice” [37].
• After the Wuhan outage of March 2026, three ministries ordered “safety rectifications” [69]. Reports that new permits were suspended remain unconfirmed [68].

Japan

Japan built its framework in three steps [43]:

• the 2020 revisions of the Road Transport Vehicle Act and Road Traffic Act enabled Level 3;
• Level 4 vehicle safety standards followed in January 2023;
• the April 2023 Road Traffic Act revision created a permit system for “specified automated operation”, meaning driverless operation.

The first Level 4 approval, in Eiheiji, came in March 2023 [42]. The government target is unmanned mobility services at about 50 locations in FY2025 and “100 or more locations by fiscal 2027” [43]. In November 2025 MLIT’s draft update of the national transport plan proposed replacing this with a target of 10,000 Level 4 buses, taxis and trucks by FY2030 [72]. I found no official count of locations achieved in FY2025. Waymo plans public driverless trips in Tokyo in 2027, subject to approvals [44].

South Korea

The Act on Promotion and Support of Commercialization of Autonomous Vehicles has been in force since 1 May 2020. It created pilot zones where vehicles may run under a lighter performance check [46]. The compensation law makes the owner’s insurer pay first, with recourse against the manufacturer for defects, and requires an AV data recorder whose data owners keep for one year [46].

In July 2026, MOLIT issued Level 4 driverless operation guidelines [47]:

• at least 15,000 km of driving records, with takeovers no more frequent than once per 160 km;
• real-time remote monitoring, system redundancy and a passenger emergency stop;
• a minimal-risk strategy that alerts the remote centre.

Amendments to the Automobile Management Act are targeted within 2026 [47]. The commercialization goal is Level 4 “in defined settings by 2027” [48].

Singapore

Fixed-route autonomous shuttles in Punggol opened to the public on 1 April 2026 under LTA monitoring [50]. The release does not set out the legal framework, so Singapore is not scored.

Middle East (part of Asia)

• UAE, federal. Federal Decree-Law No. 14 of 2024 is the first federal law to provide expressly for self-driving vehicles. Its Cabinet implementing decision is still pending [51].
• Dubai. Law No. 9 of 2023 and Administrative Resolution No. 939 of 2025 define six AV categories and fourteen operator obligations, and require local testing in Dubai [51][52]:
  • the operator bears strict civil liability, with recourse against the party at fault;
  • operators must keep an electronic record of movements, faults and accidents that may not be altered or deleted without RTA approval [51].
  • The RTA launched commercial autonomous taxis on 30 March 2026 [53].
• Abu Dhabi. A permit regime run by the Integrated Transport Centre sends telemetry, incident and violation data directly to the regulator [51]. It issued the region’s first two permits for fully driverless commercial operation in November 2025 [51][54].
• Ras Al Khaimah. Law No. 1 of 2026 was added in January [51].
• Saudi Arabia. AV deployments are restricted to the Transport General Authority’s (TGA) regulatory sandbox [55]. A SASO technical regulation for AVs reportedly took effect in April 2026. In June 2026 the Interior Ministry reportedly said driver-authorization rules do not apply to vehicles operating without human intervention, with responsibility on the owner [56]. Both points come from one secondary source and are UNVERIFIED.

Building block	China	Japan	South Korea	UAE (Dubai)
Legal basis	City regs + draft national law [31][35]	Road Traffic Act L4 permit (2023) [43]	AV Act (2020) + L4 guidelines (2026) [46][47]	Law 9/2023 + Res. 939/2025 [51]
Approval	MIIT access; GB 44721 from Jul 2027 [33][39]	L4 vehicle standards + operation permit [43]	Temporary operation permit [47]	RTA licence + local testing [52]
Who gets the ticket	Manufacturer/importer (draft) [36]	Not verified	Not verified	Operator obligations, fines [51]
Liability	Compulsory insurance + maker (draft) [36]	Not verified	Insurer-first, recourse to maker [46]	Operator strict liability [51]
Data	Incident data exchange standard to follow [39]	Not verified	AV recorder, 1-year retention [46]	Electronic record, no alteration or deletion without RTA approval [51]
Remote operation	Not in draft as reported [36]	Remote monitoring under permit [43]	Real-time remote monitoring [47]	Not addressed directly [52]

7. Oceania

Australia. The planned national Automated Vehicle Safety Law (AVSL) would put safety responsibility on an Automated Driving System Entity (ADSE), a corporation rather than a human driver. States and territories would make complementary changes [57]. A limited exposure draft of an Automated Vehicle Safety Bill 2026 circulated in September 2026 [58]. The federal government aims to finalise the framework by 2027 [59]. No commencement date has been published [57].

New Zealand. The Land Transport Act 1998 does not legally require a human driver. Trials run through case-by-case exemptions, which the Ministry calls unsustainable at scale [60]. The no-fault Accident Compensation Act 2001 may apply to AV injuries [60].

Building block	Australia	New Zealand
Legal basis	AVSL in exposure draft [58]	No driver requirement in statute [60]
Approval	Planned ADSE regime [57]	s166 exemptions [60]
Liability	ADSE responsibility (planned) [57]	ACC no-fault scheme may apply [60]
Timing	Finalise by 2027 (target) [59]	No dates [60]

8. Latin America

A March 2026 regional survey by CMS found little to score [19]:

• Argentina has federal parameters for autonomous cars, through a traffic-law reform, but no liability rules. The reform is Decree 196/2025 of March 2025, which amended the national traffic-law regulation “to permit the circulation of autonomous-driving vehicles” [75].
• Brazil has Bill 1317/2023 pending; it requires a human able to take control in emergencies.
• Chile has no specific framework in progress; its AI bill would classify AVs as high-risk AI.
• Colombia regulates automated driving systems “up to SAE level 3”.
• Peru and Mexico have no federal bills. Colombia, Peru and Mexico “still lack a regulatory framework and legal certainty” [19].

I found no driverless public service in the region.

Country	Status [19]
Colombia	Regulated up to SAE Level 3; no liability rules
Argentina	Federal traffic-law parameters; no liability rules
Brazil	Bill 1317/2023 pending
Chile	Testing encouraged since 2021; AI bill
Mexico, Peru	No federal framework

9. Africa

I found no African AV statute. In South Africa, an industry source said in March 2026 that “autonomous vehicles cannot even enter the roads until these regulations are in place” [61]. One outlet reported that Baidu Apollo would start trials of 30 robotaxis in Cairo in October 2026, in partnership with Egypt’s Ministry of Transport [62]. That report is UNVERIFIED. The legal basis was not stated.

Country	Status
Egypt	Ministry-partnered robotaxi trial reported for Oct 2026 (UNVERIFIED) [62]
South Africa	No AV regulations; AVs not permitted [61]

10. Scorecard: the leader on each continent

Rubric (author’s assessment). I scored each jurisdiction from 0 to 3 on six criteria, for a maximum of 18:

• A. Legal basis for driverless operation. 0 none; 1 pilots or exemptions; 2 enacted but partial or staged; 3 operative.
• B. Approval route. Is there a defined route from vehicle to service?
• C. Liability clarity. Is it clear who pays and who answers for violations?
• D. Data and reporting. Are recording and incident reporting mandatory?
• E. Operations at scale. 0 none; 1 supervised or small; 2 driverless commercial; 3 thousands of driverless vehicles.
• F. V2X readiness. Spectrum, technology choice, deployment targets, and installed roadside base.

Where scores tie, the jurisdiction with a published bill or law in progress leads. Where a fact was unverified, I scored conservatively.

Figure 2. Leaders per continent with score and maturity. Source: author’s assessment.

Figure 3. Leaders in bold. Within Asia the UAE (13) follows China; Japan drops to 10 because its liability and data rules could not be verified. Source: author’s assessment; sources as cited in sections 4–9.

Continent	Leader	Score /18	Why	Runner-up
Asia	China	15	National access route, mandatory L3/L4 standard from July 2027, draft law making makers liable, largest V2X base [33][36][39][40]	UAE 13 (strict operator liability, regulator telemetry); South Korea 11
Europe	Germany	14	Operative L4 law with approval, supervision and data duties; scores 1 on operations [22]	France 11, UK 10 (strongest liability design, not yet in force)
North America	United States (California as most advanced state)	13	Driverless operation at scale, state permits, SGO; no federal statute and unsettled liability [10][15]	Canada 4
Oceania	Australia	5	Exposure-draft bill with ADSE model; wins the tie-break over New Zealand [58]	New Zealand 5
Latin America	Colombia / Argentina (tie)	2	Colombia regulates ADS up to Level 3; Argentina has federal traffic-law parameters; neither has liability rules [19][75]	Brazil (bill pending)
Africa	None	0	No AV statute found; the reported Cairo trial [62] is unverified and scores 0	South Africa 0

How to read it. The scores measure how complete the legal framework is, not how good it is.

• The US scores high because operations are large and state law permits them, despite its federal gaps.
• Germany scores high on law but low on use.
• The UK’s liability design is the clearest in Europe. It scores lower only because most of the Act is not yet in force.

Figures 4 and 5 show the two dimensions where the differences matter most to agencies.

Figure 4. Self-certification, type approval and permit-led models. Source: [10]–[12][15][16][20][22][23][30][33][39][51][55][56][73].

Figure 5. Responsibility shifts from driver to manufacturer or operator at Level 4 in every jurisdiction shown. Level 3 remains unsettled in the US. Source: [1][15][22][28][36][37][38][51][52][71].

11. Roadmap 2026–2030

Figure 6. Most hard dates cluster in 2027. Source: as in the table.

Date	Milestone	Status	Source
9 Dec 2026	EU Product Liability Directive transposition deadline (software = product)	Announced	[24]
End-2026	Korea Automobile Management Act amendments for L4	Announced target	[47]
Q3–Q4 2026	UK draft regulations on ASDE and no-user-in-charge operator licensing	Announced plan (may slip)	[28]
2027	UN R185 applies in type-approval markets (EU, UK, Japan)	Expected; date unconfirmed	[3][4]
2027	UK statement of safety principles laid before Parliament	Announced	[29]
1 Jul 2027	China GB 44721—2026 L3/L4 safety standard mandatory	Announced	[39]
2027	China Road Traffic Safety Law AV chapter adopted	Expected (first reading Aug 2026)	[35]
H2 2027	UK AV Act fully implemented	Announced	[28]
Oct 2027	Ontario AV pilot expires; successor not announced	Announced	[18]
FY2027	Japan: Level 4 services at 100+ locations	Official target (proposed for replacement)	[43]
2027	Waymo public driverless trips in Tokyo	Company plan	[44]
2027	Australia AVSL finalised	Official target	[59]
2026–27	EU binding C-ITS specifications	Expected	[27]
2027+	EU type-approval reform for unlimited ADS series	Expected	[22]
2028	USDOT V2X on 20% of the National Highway System and 25% of signalized intersections in the top 75 metros	Official target	[64]
2030	ADACities: 100+ AVs per participating EU city	Initiative target (not independently verified)	[22]
FY2030	Japan: 10,000 Level 4 vehicles	Draft MLIT target	[72]
2031	USDOT V2X at 50% of both	Official target	[64]

Figure 7. Only the US, China and Korea have a firm technology choice. Source: [27][40][41][45][49][63][64].

V2X in one paragraph.

• In the US, the FCC gave 5.895–5.925 GHz to C-V2X in November 2024 [63], and USDOT set the 2028 and 2031 targets [64].
• China has more than 11,000 roadside units but about 4% vehicle penetration [40].
• Korea chose C-V2X in December 2023, with 20 MHz for LTE-V2X Direct [49].
• Japan began clearing the 5.9 GHz band for V2X in 2026 [45].
• The EU still awaits binding C-ITS specifications [27].

What to watch.

1. When UN R185 actually enters into force, and whether the EU uses it to lift the 1,500-unit cap.
2. Whether China’s draft law keeps the burden of proof on manufacturers through second reading.
3. NHTSA’s remote-assistance and first-responder dockets, and any movement on the Part 555 cap.
4. The first UK APS permit and the first ASDE authorisation.
5. Whether Ontario renews its pilot before October 2027.
6. How Gulf permit regimes handle cross-emirate and cross-border operation.

12. What it means for road agencies and consultants

1. Map the approval route before the proposal. In a self-certification country, the agency’s leverage sits in the operating permit and local conditions. In a type-approval country, it sits in the operating-area approval (Germany) or the service dossier (France).
2. Write the traffic-law interface now. California’s noncompliance notices and China’s draft rule both send violations to the manufacturer [15][36]. Agencies need a process: who issues the notice, to whom, with what evidence and what response time.
3. Ask for the data the law will require anyway. DSSAD records under R185, SGO reports in the US, and Dubai’s RTA-controlled logs [2][10][51] show what will become standard. Ask for exposure-based rates matched to the ODD.
4. Specify remote-operation expectations. Germany requires a technical supervisor, France a remote intervenor, Korea real-time monitoring [22][23][47]. In answers to a Senate inquiry, Waymo reported about 70 remote assistance agents for about 3,000 vehicles in early 2026 [65]. Where the law is silent, put staffing, response times and recovery procedures into the permit.
5. Plan V2X on the national track. In the US, procure C-V2X in the 30 MHz band. In Europe, align with C-ITS specifications as they arrive.
6. Treat 2027 as the planning year. R185, the UK Act, China’s GB 44721 and the Ontario expiry all fall in 2027.
7. Budget for independent review. A transatlantic comparison of approvals is often the fastest way to test whether a proposal is complete. See technical review and US–Italy practice.

13. Limitations

• Scores are judgement. The rubric is transparent but coarse. A 0–3 scale cannot capture the quality of a law, only how complete and operative it is.
• Unverified items:
  • R185’s entry-into-force date (one headline says January 2027 [70]);
  • the Saudi SASO regulation and Interior Ministry statement [56];
  • the Cairo trial [62];
  • Japanese liability and data-recording rules, and Japanese and Korean rules on who gets the ticket (Japan is scored conservatively);
  • the detail of Germany’s remote-driving permit route;
  • how far ISO 34502, ISO 21448 and UL 4600 are referenced in R185.
• Dated counts. The 19-state US count is from 2024 [17].
• Secondary sources. Many facts come from law-firm summaries rather than the legal texts. Treat them as accurate summaries, not the law itself.
• Fast change. Several of the milestones in section 11 could slip. The UK has already moved its implementation once, to late 2027 [71].

14. Checklist for agencies and practitioners

1. Identify which approval model applies: self-certification, type approval or permit-led.
2. List every ADS permit on your network with its ODD, fleet cap and expiry date.
3. Confirm who receives traffic violations by driverless vehicles, and set up the notice process.
4. Check whether the operator, the manufacturer or the insurer pays first after a crash, and what evidence they must disclose.
5. Require DSSAD-type event records and periodic exposure-based safety reports.
6. Require remote-operation details: staffing ratio, location, response time and on-site recovery.
7. Agree emergency-geofence and first-responder protocols. California’s two-minute rule is a useful benchmark [15].
8. Align V2X procurement with national spectrum and technology decisions.
9. Track the 2027 milestones (R185, UK Act, GB 44721, Ontario) in your programme risk register.
10. Re-score your jurisdiction against the rubric every six months.

For an independent review of an AV or V2X proposal on your network, see peer review or get in touch.

Sources

1. SAE International. J3016_202104 Taxonomy and Definitions for Terms Related to Driving Automation Systems, revised 30 Apr 2021. https://saemobilus.sae.org/content/j3016_202104
2. Bennett Jones. “First global regulatory framework for autonomous vehicles: key takeaways for Canada and the auto industry”, Aug 2026. https://www.bennettjones.com/Insights/Blogs/2026/08/First-Global-Regulatory-Framework-For-Autonomous-Vehicles
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