As the automotive industry has moved along the path to the development of fully automated vehicles over the past decade, the United Nations Economic Commission for Europe (UN ECE), via its World Forum for Harmonisation of Vehicle Regulations (WP.29), has been working in parallel to develop the necessary harmonised Regulatory requirements to ensure the safety of such vehicles and allow for their large scale deployment.
In 2018, WP.29 set up a specific Working Party, the Working Party on Automated/Autonomous and Connected Vehicles (GRVA), which was tasked with the development of the necessary Regulations and frameworks to cover Automated Driving Systems (ADS). Since that time, a number of significant milestones have been achieved, such as:
- The development and publication of UN ECE Regulation No. 157 on Automated Lane Keeping Systems (ALKS) in 2021.
- The development and publication of a Framework Document for Automated / Autonomous Vehicles in 2022.
- The development and publication of guidelines and recommendations for automated driving system safety requirements, assessments and test methods to inform regulatory development in 2025.
However, possibly the most significant milestone to date was reached when WP.29 adopted a draft new UN ECE Regulation on the Approval of Motor Vehicles with regard to their Automated Driving Systems at their 199th session in June 2026. This draft Regulation, which has provisionally been allocated Regulation No. 185, has been developed over many years with inputs from the worldwide automotive industry, from specialists in the field of Automated Driving Systems and from Government representatives from around the world, including from the USA, China, Japan, the European Union and the UK.
Although this new Regulation covers the full ‘driverless’ vehicles that most members of the public associate with this technology, i.e. vehicles with no manual controls (no steering wheel or pedals), it also covers vehicles whose automated driving systems are only designed to operate in more specific Operational Design Domains or ODDs. For example the Operational Design Domain (ODD) of an automated driving system may be restricted by:
- Road type - For example, where the automated driving system is only designed to operate on roads where pedestrians or cyclists are not permitted, e.g. motorways or highways.
- Geographical area - For example, where the automated driving system is only designed to operate with the confines of one particular city or region.
- Weather conditions - Where the automated driving system is not designed to operate in extreme weather conditions, such as heavy snow or fog.
Due to the complexities of automated driving systems and the limited amount of experience/evidence related to their deployment to date, it was determined at a fairly early stage of the Regulatory development process that it would not be feasible to follow the same approach that is applied in virtually all other UN ECE Regulations, i.e. setting prescriptive requirements and specific test procedures. Instead, a Safety Management System (SMS) and safety case approach, as more commonly used in the aerospace industry and the nuclear industry, was adopted. Under this approach, in addition to the key design and performance requirements applicable to the automated driving system, the Regulation also specifies requirements that are applicable to the manufacturers themselves and to the processes to be followed by the manufacturer throughout the design, development, production and in service performance of the automated driving systems. These ‘manufacturer’ requirements are to ensure that compliance with the specified safety provisions are achieved and demonstrated by the application of robust assessment and validation methodologies which are audited by the Approval Authority or its designated Technical Service as part of the type approval process.
The ‘manufacturer’ requirements specified in the draft Regulation essentially fall under four headings:
Safety Management System - Requiring that the vehicle manufacturer must establish and implement a Safety Management System (SMS) covering the full ‘life cycle’ of the automated driving system from initial system development through to monitoring the in service performance of vehicles fitted with the system. This SMS must include a safety policy and a risk management process, and regular audits must be undertaken to ensure that the SMS is being implemented correctly and consistently.
Credible Testing Requirements - Specifying requirements on the credibility of the test tools, test procedures and test scenarios used for virtual testing, test track testing and real world testing to ensure their suitability for assessing and validating the performance of the automated driving system.
Safety Case - Requiring the vehicle manufacturer to compile a ‘safety case’ for the automated driving system to demonstrate that all of the potential scenarios, situations and risks which the system may encounter in real world use have been identified, assessed and that controls have been implemented to ensure that the system poses no unreasonable risk, with evidence being provided to support each of these assessments and conclusions.
In Service Performance Monitoring and Reporting - Requiring the vehicle manufacturer to monitor the safety performance of their automated driving systems when they are in service and to regularly provide reports to the Approval Authority on the in service safety performance of their systems.
The Regulation is available on InterRegs.NET for our ECE subscribers and is also available at SelectRegs.