Following the Automated Vehicles Act (AV Act) receiving royal assent in May 2024, stakeholders have been keenly awaiting the publication of government consultation papers which represent the first part of the wider programme to implement the 2024 Act.
On 10 June 2025 the Government published two consultation papers:
- A Statement of Safety Principles.
- Protecting marketing terms for automated vehicles.
Interest in these consultation papers is even more topical given the Government’s recent announcement of pilot self-driving taxi and bus services in the Spring of 2026.
Statement of Safety Principles
The AV Act stipulates that the minimum safety standard for a self-driving vehicle should be equivalent to, or higher, than that of a careful and competent human driver. The underlying principle is that road safety should be better as a result of autonomous vehicles (AVs) than would have otherwise been the case.
The concept of the careful and competent driver is already established in international regulations (e.g. UN Reg 157 in respect of the approval of automated lane keeping systems).
The Statement of Safety Principles is intended to cover the pre-deployment stage and will set out the expected safety standard for motor manufacturers to meet in presenting their safety case for authorisation/approval by the Vehicle Certificate Authority (VCA).
It will also cover post-deployment to consider the ongoing safety performance of self-driving vehicles, to facilitate continuous learning and improvement.
Protecting marketing terms
The aim of this consultation paper is to potentially eliminate/reduce the risk of consumer confusion regarding the language that might be used by businesses to promote and sell their vehicles.
The AV Act gives the Secretary of State for Transport the power to protect certain terms so they can only be used to market vehicles authorised as being automated as distinct from driver assistance systems.
The intention is ultimately to create a list of protected terms, which it is suggested, will include: -
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Self-driving
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Driving itself
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Driverless
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Automated vehicle
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Automated driving
Such is the concern over misleading marketing surrounding AVs, the Act contains a statutory offence (Section 79) applying to commercial communications likely to confuse the end user into thinking that unauthorised vehicles can travel autonomously.
Timetabling
The response to both consultation papers are due by 1 September 2025.
We are currently supporting the ABI with regard to compiling responses to both consultation papers.
The Government has set itself a target for full implementation of the regulatory framework in the second half of 2027.