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Consultation on the Wider Regulatory Framework for autonomous vehicles

The UK's automated vehicles (AV) regime is moving into its next phase

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Latest update 24 September 2026.

The UK's automated vehicles (AV) regime is moving into its next phase. Following the enactment of the Automated Vehicles Act 2024 (the Act) and the Department for Transport's (DfT) earlier call for evidence on implementing the framework, the DfT has indicated that a further consultation will take place during 2026 on the wider regulatory framework to ensure it meets the needs of all road users.

This consultation represents an important opportunity for insurers to influence how the UK's self-driving vehicle ecosystem develops in practice. While the Act establishes the legal foundations for deployment, many of the operational, insurance and liability issues that will determine how claims are handled and risks priced will be addressed through secondary legislation, guidance, and regulatory detail.

Why is the Consultation required?

The Government's implementation programme is intended to create a comprehensive framework governing how automated vehicles are authorised, monitored, and regulated throughout their lifecycle.

The forthcoming consultation is expected to test whether the emerging framework balances innovation with the interests of motorists, passengers, pedestrians, cyclists, disabled road users, and insurers. As wider deployment moves closer, ensuring public confidence in safety, accountability and compensation arrangements will be critical.

Key Issues

  • Data access to vehicle generated data and claims handling remains one of the most significant issues. Determining whether an automated driving system or a human user was controlling the vehicle at the time of an incident will be fundamental to liability investigations and claims resolution. Previous Government discussions have recognised the importance of providing insurers with access to relevant data to support fair and efficient claims handling.

  • Shifting liability models - automated vehicles challenge traditional motor insurance assumptions. As driving functions transfer from humans to software systems, liability may increasingly involve manufacturers, software developers, authorised self-driving entities and fleet operators.

  • Cyber and operational risks - as vehicles become increasingly connected and software-driven, cyber security and operational resilience will become core insurance considerations. The wider regulatory framework is expected to address how such risks are managed, monitored, and enforced throughout a vehicle's operational life.

Looking ahead

According to DfT implementation timelines referenced across the industry, further consultations and draft regulations are expected throughout 2026, with broader deployment of approved self-driving vehicles anticipated from 2027 onwards.

For insurers, the forthcoming consultation is more than a regulatory exercise. It is an opportunity to help shape the future claims, liability and data-sharing framework that will underpin the UK's automated vehicle market. Organisations that engage early will be better placed to understand emerging exposures, adapt underwriting and claims processes, and respond to the changing risk landscape as self-driving technology moves from pilot projects to everyday reality.

Given that October is just around the corner, we are expecting the next consultation to be published imminently.

The below update was written 20 June 2026.

Automated Vehicles – Launch of the first consultation papers

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: -

  • Self-driving

  • Driving itself

  • Driverless

  • Automated vehicle

  •  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.

A version of this article was first published on 20 Jun 2025

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Written by:

Jacqui Bickerton

Jacqui Bickerton

Principal Associate

Jacqui has over 30 years' legal experience of dealing with catastrophic injury claims, fraud and civil litigation and is based in our knowledge management team in the Liverpool office.

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