Civil Law

International regulators are finalizing the first global safety standards for Automated Driving Systems (“ADS”). In January, the UN Working Party on Automated/Autonomous and Connected Vehicles (“GRVA”) approved a draft UN Regulation (“UNR”) under the 1958 Agreement and a draft Global Technical Regulation (“GTR”) under the 1998 Agreement, submitting both for adoption by the UN World Forum for Harmonization of Vehicle Regulations.

Developed in parallel to ensure harmonized technical requirements across jurisdictions, the UNR and GTR are expected to be adopted at the 199th WP.29 session in June 2026. In the meantime, work continues on finalizing the accompanying Guidance and Interpretation Document. This post provides an overview of the UN regulatory framework, the legislative status of the ADS instruments as of May 2026, an outline of the key provisions, and implications for companies across the ADS value chain.

The UN Regulatory Framework

The UNR and GTR on ADS are being developed by the UN World Forum for Harmonization of Vehicle Regulations (“WP.29”), the UN body responsible for setting international vehicle standards. The UNR and GTR are being developed under two distinct UN legal frameworks allowing for harmonized technical regulations for vehicles —the 1958 Agreement and the 1998 Agreement—which differ in scope and legal effect:

• UN Regulation (1958 Agreement): Adopted by the EU, Japan, South Korea, and other type-approval jurisdictions. UNRs are binding once applied and require national or regional implementation. Approvals are mutually recognized among participating countries.
• Global Technical Regulation (1998 Agreement): Adopted by a broader group, including the United States, China, and Canada. GTRs are non-binding templates; each country must separately decide whether and how to implement them through domestic rulemaking.

Current Legislative Status

The Informal Working Group on ADS (“IWG on ADS”), operating under the GRVA, has been developing the UNR and GTR on ADS since 2019. The group brings together regulators, industry, and technical experts to consolidate input from across jurisdictions and stakeholder groups.

In January 2026, GRVA formally adopted the draft UNR and recommended the draft GTR for adoption by the WP.29, and the texts were posted to the GRVA website. The U.S. Department of Transportation published the draft GTR in the Federal Register and launched a 30-day public comment period beginning January 23, 2026. China has also announced plans to initiate its own public consultation process. These efforts reflect a growing emphasis on stakeholder engagement and international collaboration in the development of global ADS standards.

In February 2026, there was an IWG and GRVA workshop in Shanghai focused on resolving remaining technical issues and advancing the accompanying Guidance and Interpretation Document (“GID”), which will support consistent implementation. Discussions addressed open items such as data storage (“DSSAD”), audit procedures, user interaction, and the scope of safety case documentation.

Key Provisions of the UNR and GTR on ADS

The UNR and GTR on ADS are built on a shared technical foundation and apply to vehicles equipped with ADS features capable of performing the entire Dynamic Driving Task (“DDT”) within a defined Operational Design Domain (“ODD”). The scope covers SAE Level 3 (“conditional automation”) systems—such as systems that allow hands-off, eyes-off driving in certain situations (e.g., highway driving), but require the driver to resume control in other situations—as well as higher levels of automation. Lower-level driver assistance systems (e.g., adaptive cruise control or lane keeping) remain outside of scope and are addressed under separate instruments, such as UN Regulation No. 157 on Automated Lane Keeping Systems.

Both instruments adopt an outcome-focused safety assurance approach centred on a structured “safety case.” Rather than prescribing fixed test procedures, the rules require manufacturers to demonstrate that their ADS is at least as safe as a competent and careful human driver. This must be substantiated through a Safety Management System (“SMS”) and a documented safety case comprising claims, arguments, and supporting evidence. The safety case is subject to review by the relevant authority—either a Type Approval Authority under the UNR or a designated assessor under the GTR, depending on the jurisdiction.

Notable technical requirements include performance of the DDT, safe fallback strategies, and user interaction protocols. For example, the ADS must avoid collisions with safety-relevant objects, comply with traffic laws, and manage transitions between automated and manual control. Systems must include safeguards against foreseeable misuse, such as disabling manual controls when the ADS is active, and must incorporate cybersecurity and software update capabilities. Validation is expected to include virtual simulation, track, and real-world testing, with regulators auditing the manufacturer’s scenario analysis to ensure coverage of reasonably foreseeable conditions. Post-deployment, manufacturers must monitor ADS performance in service and report significant safety events to authorities, supporting continuous compliance and regulatory oversight.

Implications for Industry Stakeholders 

For automotive manufacturers and suppliers, the adoption of the UNR and GTR on ADS will bring both regulatory clarity and new compliance expectations:

• European Union (and aligned markets): The EU is expected to incorporate the UN Regulation on ADS into its type-approval framework shortly after WP.29 adoption. Manufacturers will need to obtain approval under the new regulation to sell Level 3+ vehicles in the EU. Other 1958 Agreement countries, including Japan and South Korea, are likely to follow suit, enabling streamlined approvals across key markets.
• United States: While the U.S. does not automatically adopt UN Regulations, the National Highway Traffic Safety Administration’s publication of the draft GTR and request for public comment signals growing alignment. Although no federal ADS safety rule is currently in force, the GTR offers a ready framework should U.S. regulators chose to move forward with implementing rules. U.S. developers targeting global markets may decide to preemptively align with UNR/GTR standards.
• China and Other Markets: China, a 1998 Agreement member, has been active in WP.29 discussions and may adopt the GTR domestically. Other countries such as Australia, India, and Canada could also use the GTR to shape national ADS rules, contributing to broader regulatory convergence.

As the UNR and GTR move toward adoption, companies should prepare for a more harmonized global compliance landscape. Early alignment with these frameworks will be key to market access and long-term competitiveness in the ADS space.

We will continue to monitor these developments and provide further updates as the international and domestic regulatory framework on autonomous vehicles evolves. We are available to discuss the implications for companies across the automotive, technology, and AI sectors.

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