The UK is moving quickly to shape a clear, safety focused framework for self driving vehicles. With the Automated and Electric Vehicles Act 2018 already in force and the Automated Vehicles Act 2024 laying out a framework of the UK legal landscape for the authorisation, safety oversight and operation of automated vehicles, organisations working with automated driving technology face a rapidly evolving regulatory landscape.
This article highlights the core elements of the UK regime at present and what to expect from the secondary legislation being introduced during the course of 2026 and 2027.
UK AV regulatory landscape in brief
The UK’s regulatory framework for automated vehicles currently rests on two legislative pillars:
- the Automated and Electric Vehicles Act 2018 (“AEVA”), which extends the compulsory motor insurance regime to cover automated driving; and
- the Automated Vehicles Act 2024 (“AVA”), a framework statute for authorising, operating and regulating self driving vehicles.
AEVA 2018 – the insurance backbone for automated driving
AEVA answers the question of who pays when an automated vehicle causes an accident whilst an automated vehicle is driving without any human assistance. The AEVA does this by:
- extending compulsory motor insurance so that the vehicle’s insurer is initially liable to compensate victims of accidents caused by an automated vehicle in automated mode; and
- allowing that insurer to recover its costs from whichever party was actually at fault and liable (for example, the manufacturer, software provider or other supplier).
Insurers can limit or exclude cover under certain exceptions, but it is worth noting that under the AEVA, the Secretary of State should regularly publish a list of automated vehicles to which AEVA applies, so that manufacturers, owners and insurers know when this regime is engaged. Such a list has not been published to date, largely due to the lack of AVs currently driving on UK roads and a focus on EV charging (covered under Part 2 of the AEVA).
Although it seems likely that the AEVA will remain the civil liability cornerstone for automated driving, and therefore consequential for insurers, it will inevitably have to operate alongside the AVA’s rules on authorisation, operation, enforcement and driver immunity, once the AVA is fully in force.
AVA 2024 – the framework for safe deployment of self driving vehicles
Whereas the AEVA focuses on liability for fault, the AVA sets out when and how vehicles may lawfully drive themselves, and who is responsible for ensuring they do so safely. The key provisions from the AVA are set out below.
1. Authorisation and the self-driving test
Under the AVA, no automated vehicle will be permitted to drive itself on roads in the UK unless it has been authorised under the AVA as being authorized as “self driving”. To be authorised, an automated vehicle must, at a minimum, satisfy the self driving test, which requires that:
- it is designed or adapted with the intention that a feature of the vehicle will allow it to travel autonomously; and
- it is capable of doing so, by means of that feature, safely and legally.
How this authorisation test is practically applied remains to be seen. The AVA provides for a “Statement of Safety Principles” to be published in relation to the self-driving authorisation test. Although these principles have not yet been published following the closure of a consultation on those principles in September 2025, their stated goal is to ensure that (a) AVs achieve a level of safety that is higher than that of the average human driver and (b) AVs improve the overall standards of road safety in the UK.
These safety principles will mandate, at least, deployment authorisation checks, in use monitoring, and annual assessments of the overall performance of AVs. Manufacturers, software developers and other operators involved in the supply chain for AVs will have to closely maintain adherence to these safety principles, to avoid issues with the authorization of an AV under the AEA.
2. Licences and new regulated entities
The AVA introduces new legal roles, and associated responsibilities, to reflect the reality that responsibility for self driving will sit primarily with organisations rather than individual drivers:
- An Authorised Self Driving Entity (“ASDE”): Typically the manufacturer or AV software developer, which is responsible for ensuring that its authorised vehicles continue to satisfy the self driving test over time. ASDE’s will have authorization requirements to ensure that they can become, or remain, authorized under the AVA. These are currently broadly drafted with requirements for an ASDE to be “of good repute”, “good financial standing” and capable of discharging any authorization requirements mandated by the Department for Transport, so it will be important to closely monitor how these principles are fleshed out in the law and associated guidance over time;
- The user in charge (“UiC”): The driver of the vehicle that is in a position to operate the driving controls when a UiC feature is engaged (e.g. a feature that allows a driver to take full control over an AV) – such UiCs will generally be immune from driving offences and any criminal liability committed while the vehicle is self-driving (subject to some exceptions); and
- The no user in charge (“NUiC”) operator: A licensed operator overseeing vehicles that complete journeys with no driver in the vehicle or no ability for a driver to take control of the vehicle (for example, a robotaxi). Such vehicles will need an ASDE as well as an NUiC operator, with the latter being responsible for non-driving related tasks such as maintaining roadworthiness and breakdown/incident management.
Although much of the detail of these provisions will be determined via secondary legislation, ASDEs and NuiC operators are likely to bear the heaviest compliance burden, as well as (in the case of ASDEs) potentially facing some high barriers to market access depending on how the reputational and financial standing requirements are interpreted.
3. Enforcement
In terms of the enforcement landscape, the AVA equips regulators with some significant powers to:
- vary, suspend or withdraw vehicle authorisations in certain scenarios including where authorization requirements remain unmet, traffic infractions arise or if the AV can no longer satisfy its “self-driving test”;
- issue compliance and redress notices; and
- impose monetary penalties where regulatory requirements are breached.
ASDEs and NUiC operators may also be required to collect and share safety related data and to appoint a nominated individual responsible for information provided to regulators, with such individuals carrying personal liability. It will be an offence to fail to provide requested information or to provide false or misleading information about vehicle safety, and the nominated individual can also face personal liability, subject to a due diligence defence.
4. Marketing
The AVA sets out a regime for restricting promotional communications, marketing or advertising that hold out AVs as self-driving or automated where such AVs have not been properly authorized under the AVA. Draft regulations were published in the Summer of 2025 which set out some specific wording restrictions, ranging from "automated" to “driverless” / “self-driving”. The intention of these restrictions remains unclear but it follows on from concerns voiced about “Advanced Driver-Assistance Systems” being inaccurately portrayed as fully automated systems, rather than ones that still require driver control. A consultation on the draft regulations ran in Summer 2025 (closing in September 2025) with the results yet to be published.
What’s next?
The AVA is a framework Act, and most of its key mechanisms set out above will come into force through secondary legislation over the next few years. As of early 2026:
- The AEVA is fully in force and already governs compensation for accidents involving automated driving.
- Most operational provisions of the AVA are due to be brought into force by secondary legislation in the second half of 2027, although this date could move by virtue of the AVA allowing the Secretary of State to appoint an enforcement date within the relevant secondary legislation. As an example of this, Part 5 (the automated passenger services permitting scheme) of the AVA is expected to come into effect from spring 2026 to support early commercial robotaxi / bus-like services as part of the government’s Transport AI action plan.
The outcome of now closed calls for evidence – such as the Automated passenger services (“APS”) permitting scheme, the protected “self driving” marketing terms, and the Statement of Safety Principles will shape the final impact, breadth and granularity of the AVA once it becomes law in mid-2027. Additionally, a broader consultation for developing the automated vehicles regulatory framework (which largely covers the authorization requirements for ASDEs and NUiC operator licensing) remains open, closing on 5 March 2026.
In summary, the UK now has a rapidly developing regulatory framework, underlining the UK government’s ambitions to chart the UK’s path as a leader for autonomous vehicle technology. Much remains to be detailed in terms of the granularity of the regulatory landscape during the course of 2026 and 2027, which will determine the compliance burden for the many different participants in the AV market, ranging from vehicle manufacturers to software developers, LLM operators, and insurers.
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