Shaping the Future of Automated Vehicles: Department for Transport’s New Call for Evidence

On 4 December 2025, the Department for Transport (DfT) published a call for evidence to shape the next stage of the UK’s automated vehicle regulatory framework, covering proposed secondary legislation, policy development, and operational standards. This initiative is part of the Automated Vehicles Act (AVA) Implementation Programme, launched in 2024 to advance the policy, legislative and operational steps needed to fully implement the Automated Vehicles Act 2024 (AVA 2024) by 2027.  

The AVA 2024 sets out core principles for automated vehicle safety and industry accountability, while granting powers for authorities to develop detailed rules regarding automated vehicles through secondary legislation. Although some sections of the AVA 2024 took effect upon enactment, many will only come into effect through future regulation.

Since 2024, the Government has also issued calls for evidence in respect of automated vehicles regarding restrictions to misleading claims about automation and consumer protection, as well as safety standards and performance measuring. For further context, see our previous blog on the AVA 2024 and related pieces from 2020, 2022, and 2023.

The current call for evidence 

The DfT’s latest consultation is divided into two chapters. Chapter 1 considers the standards that should govern the approval of automated vehicles before entering the market. The consultation also poses questions regarding user responsibility for offences involving user-in-charge vehicles – i.e. vehicles embedded with self-driving features that the human user may choose to engage or disengage. The consultation further considers the minimum safety protocols required when a vehicle issues an alert calling on the human user to assume control of the vehicle, automatically disengaging the self-driving feature (a process called “transition demand”). The DfT mentions proposals such as setting a minimum interval between the transition demand and the user taking over, to ensure sufficient time for the user to prepare. Additionally, the DfT is considering how insurance arrangements should function in this new environment. 

Chapter 2 focuses on the DfT’s considerations on the proposed in-use regulatory regime, inviting contributors to provide insights on how the Government should monitor authorised self-driving vehicles throughout their lifecycle and enforce compliance through civil and regulatory sanctions.

Although the call for evidence does not create any binding rules, it does shed some light on how the DfT is shaping the next phase of automated vehicle regulation. Key insights include:

• Data Storage and Insurance Claims. The consultation anticipates that automated vehicles will generate extensive timestamped and event data, which the DfT suggests that will be regulated with guidance from the United Nations Economic Commission for Europe (UNECE) on Data Storage Systems for Automated Driving (DSSAD), covering ADS activation, emergency manoeuvres and collisions. According to the DfT’s serious incidents might require additional time-series data, such as sensor inputs. Following recommendations from the Law Commission’s joint report on Automated Vehicles, the Government is considering mandating retention of key data for up to 39 months to support claims, with the caveat that timestamps can be stored as a simple text-string to minimise data storage burdens.
   
• Insurance Framework and New Products. The consultation confirms that Authorised Self-Driving Entities (ASDEs) and No-User-in-Charge Operators (NUICOs) will need to take on business insurance products in addition to motor insurance. Coverage for Automated Vehicles (AVs) featuring No-User-in-Charge (NUIC) capability will typically be provided under multi-vehicle fleet policies, which may also include remote human intervention. The Government is considering broader insurer access to vehicle data for incident analysis, risk modelling, and pricing, while addressing manufacturers’ concerns over proportionate data sharing. Additionally, the Motor Insurers’ Bureau (MIB) will act as insurer of last resort for incidents caused by uninsured drivers guaranteeing victims’ access to compensation.
   
• In-Use Regulatory Scheme (IURS). The AVA 2024 provides for a new lifetime compliance regime. The call for evidence envisages that the in-use regulation will involve multiple parties: the Driver and Vehicle Standards Agency (DVSA) and VCA are likely to take on many of the key responsibilities for the IURS, acting on behalf of the Secretary of State; however, the development of the IURS will require close collaboration with industry, international regulators, and first responders such as police, ambulance, and fire services.
   
• Cyber Security and Software Updates. The DfT also plans to embed the UNECE Regulations 155 and 156 into UK law, requiring manufacturers to maintain robust cyber security and controlled software update processes throughout a vehicle’s lifecycle. These process-based standards represent a shift from traditional type approval and will demand ongoing governance and risk management.
   
• Accessibility and Equality. The consultation reinforces that AV safety must not disadvantage vulnerable road users. An Automated Passenger Services Accessibility Advisory Panel is planned to guide reporting and ensure effective inclusivity.
   
• Environmental Impact. The DfT acknowledges the need for further research into AVs’ net environmental effects, balancing potential benefits such as efficiency and shared mobility against risks like increased mileage and energy demands.

Next steps

The DfT is moving from principle to practice, developing detailed rules in respect to automated vehicles which comprise data governance, insurance, lifetime compliance and cyber security, while embedding accessibility and sustainability into the regulatory framework. 

Further consultations are expected in 2026 on key issues like data retention, disclosure obligations, and how in-use regulation and enforcement will work, paving the way for new draft regulations. For organisations considering integrating autonomous vehicles into their operations, now is the time to get involved. Early engagement offers an opportunity to influence policy and prepare for compliance requirements that could impact product liability, data governance, and risk strategies.