Since 2022, the European Union requirements on Whole Vehicle Type Approval (EU WVTA) have included provisions which allow for the small series type approval of fully automated (driverless) vehicles within specific use cases. However, because these provisions are restricted to the small series type approval scheme, the maximum number of vehicles of an approved vehicle type which can be registered within the European Union in a calendar year is limited to 1,500.
Following significant technological advances and regulatory developments since 2022, the European Commission believe that we have now reached a point where it should be permissible for vehicles equipped with one particular type of automated driving system (ADS) to obtain full European Whole Vehicle Type Approval (EUWVTA), without the being subject to the vehicle registration limits imposed by the small series type approval scheme. The automated driving system (ADS) in question is referred to as Automated Valet Parking (AVP), and is a system which allows a vehicle to be driven “autonomously” within a suitable parking facility. When the driver of an AVP equipped vehicle arrives at a suitable parking facility and activates the AVP system, the vehicle will “autonomously” drive itself to an available parking space and park. When the driver returns to the parking facility and ‘calls’ the vehicle, it will ‘autonomously’ drive itself from its parking space to a defined ‘pick up’ point within the parking facility to be reunited with its driver.
When the EU Whole Vehicle Type Approval requirements specified in (EU) 2018/858 on the approval and market surveillance of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles was updated in 2022 to allow for the small series type approval of fully automated vehicles, a separate EU Regulation, (EU) 2022/1426, was published laying down uniform procedures and technical specifications for the type approval of the Automated Driving Systems (ADS) of fully automated vehicles. However, before the EU WVTA requirements can be amended to allow the full European Whole Vehicle Type Approval of vehicles equipped with AVP systems, the European Commission have determined that it will be necessary to update (EU) 2022/1426 to introduce specific technical requirements, safety performance and validation criteria for such systems.
On November 28, 2025, a draft EU Regulation was published for public comment by the European Commission, which proposes amendments to (EU) 2022/1426 on uniform procedures and technical specifications for the type approval of the automated driving system of fully automated vehicles to introduce specific provisions to cover Automated Valet Parking (AVP) systems. The draft Regulation proposes the introduction of a completely new Annex to cover AVP systems, consisting of three separate Parts:
- Part 1 contains definitions for the specific terms that are used within the AVP Annex.
- Part 2 contains the performance requirements for AVP systems, such as how the AVP should undertake the dynamic driving task (DDT) under specific scenarios.
- Part 3 contains compliance assessment procedures, specifying the test procedures to be followed when assessing the compliance of the AVP system with performance requirements defined in Part 2 of the Annex.
Once finally agreed and adopted, it is proposed that these amended requirements would enter into force 20 days after publication of the final EU Regulation in the Official Journal of the European Union.