Author

Ed Wright

Author

Liz Machin

Published
3rd February 2026

Contents

Summarise Blog

A call for evidence on developing the regulatory framework

While the Automated Vehicles Act 2024 (AVA 2024) provides a comprehensive umbrella scheme for self-driving vehicles in Great Britain, almost all its provisions are to be brought in by secondary legislation.

To help shape the next stage, the UK government launched a call for evidence on 4 December 2025, open for the three months until 5 March 2026, seeking input on how the automated vehicles (AVs) regulatory framework should evolve. The written statement to Parliament refers to this call as ‘ambitious’.

What is the purpose of the call for evidence?

The Department for Transport (DfT) and the Centre for Connected and Autonomous Vehicles (CCAV) are inviting responses to their 125 questions. There are two main chapters within the consultation:

  • Getting AVs on the road, and
  • Once AVs are on the road.

There are also separate sections on accessibility and environmental impacts.

The purpose is expressed as:

‘This call for evidence seeks information that will help inform secondary legislation, guidance and policy development, ensuring the AV regulatory framework remains proportionate, forward-looking and responsive to emerging technologies’.

Read the call for evidence here.

Key questions in the consultation

In this blog we take a brief look at the call for evidence – dipping into the consultation of 125 questions.

For an exploration of key concepts, regulated bodies, and liability shifts within the AVA 2024, read our earlier blog on AVs here.

Chapter 1: Getting AVs on the road

This chapter covers vehicle type approval, authorisation, user-in-charge (UIC) and transition demands, operator licensing, and insurance.

Reference is made to work being carried out by the United Nations (UN) to develop automated driving systems (ADS) regulations. It is noted that, on vehicle type approval requirements for AVs, these requirements will be closely linked to the outputs of the UN work.

The questions include the following:

  • Vehicle type approvalIn your view, what do you think will be the use-cases of self-driving vehicles deployed in the next 5 years in the UK? (Question 5).
  • Authorisation:In your view, what processes should be in place to ensure that authorised vehicles continue to meet the legal safety standard over time? (Question 19)
  • UIC and transition demandsIn your view, should different scenarios require different transition demand protocols, and why? (Question 33)
  • Operator licensing:In your view, how should operators and authorities seek to prevent and respond to crimes committed within a no-user-in-charge (NUIC) passenger vehicle, e.g. taking illegal drugs or sexual assault? No personal information should be provided as part of the evidence. (Question 42)
  • InsuranceWhat, if any, learnings from other insurance models could be applied to any new types of insurance for AVs, and why? (Question 66)

Chapter 2: Once AVs are on the road 

The second chapter covers incident investigation, in-use regulation, and cyber security. For example,

  • The records to be kept on AV maintenance and repair (Question 75).
  • In relation to automated passenger services (APS), whether a permit holder’s turnover should be considered when setting a maximum monetary penalty limit (Question 90).
  • To support the cyber security duties under the AVA 2024, the management of relationships between parties e.g., vehicle manufacturers, ADS suppliers, and no-user-in-charge operators (NUICOs) (Question 116).

Accessibility and environmental impacts

The standalone section on accessibility within the call for evidence is put in the context of where else this is being thought about, and talks first about the APS permitting scheme consultation launched in July 2025, a chapter of which considers accessibility.

It is within this context that only one question in this section is asked, namely:

  • Whether there are any wider considerations regarding accessibility that should be taken into account in the deployment of AVs (Question 121).

The environmental impacts section (four questions) includes:

  • What evidence, if any, can you supply on how AV production— particularly in the UK—will affect the environment, including carbon and other emissions? (Question 123)

Who should respond?

The call for evidence states that the DfT is keen to hear from a diverse range of respondents. This includes, though is not limited to:

  • those working within the AV industry, including technology providers;
  • original equipment manufacturers;
  • parts suppliers;
  • academics;
  • road safety experts;
  • road users;
  • trade unions;
  • first responders;
  • those with accessibility needs; and
  • anyone else with an interest in this area.

Other recent developments in AV regulation 

This call for evidence on developing the AV regulatory framework follows other related consultations and publications:

Why does this matter for businesses and operators?

Responding to this consultation is an opportunity to influence how AV regulation will work in practice. Wider considerations include:

  • Compliance risks: Future penalties for failing to meet safety or cyber security duties.
  • Operating impacts: Transition demand protocols, and licensing requirements.
  • Insurance models: How liability shifts could affect cover and costs.
  • Accessibility obligations: Design that meets inclusivity standards.

If you operate in the transport, technology or insurance sectors, now is the time to review your position and consider submitting evidence. Early engagement can help shape a regulatory framework that works for your business.

How we can help

As stated in the written statement to Parliament on 4 December 2025:

‘Self-driving vehicles have the potential to increase opportunities and break down barriers for how people and goods move around the country, making transport safer, greener and more reliable. Strengthening road safety, improving accessibility and ensuring safeguarding remain central to this vision’.

Our experienced team oftechnology solicitors can support you if you would like to learn more about the evolving AV regulatory landscape.

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About the Authors

Ed primarily advises on the creation, ownership and exploitation of IP, including licensing, R&D/technology transfer and agency, distribution, reselling, and franchising arrangements. Ed also specialises in drafting and negotiating agreements governing IP licensing and the supply of goods and/or services. He works across all sectors, but has a particular specialisms in healthcare/life sciences, sport, technology, and media and communications. Ed is recognised as a 'Leading Partner' in the Legal 500 UK, 2026 guide, and as a ranked lawyer in the Chambers UK 2026 guide.
Stewart Argo

Legal Director

Stewart's work includes advising on supply of goods and services agreements, outsourcing, software licencing, SaaS and cloud agreements, software development agreements, software support and maintenance agreements and other agreements for IT services, data protection, assignment and licencing of intellectual property rights, e-commerce, distribution agreements and standard terms of business. Stewart has experience advising clients in the technology, energy, education, manufacturing, and logistics sectors on both business to business and business to consumer arrangements.
Liz Machin

Knowledge Development Lawyer

As a knowledge development lawyer, Liz works alongside the firm’s transactional and advisory lawyers practising in commercial contracts, technology, energy, data and privacy, and intellectual property. Liz’s day-to-day activities include tracking legislative changes on the horizon, following developments in contract law, encouraging the sharing and capture of new knowledge, and scoping out related training delivery ensuring that our lawyers deliver high-quality advice to our clients in line with the latest legal developments and best practices. Liz also conducts legal research on complex issues and contributes to the development of innovative approaches to meet our clients’ needs. Liz works on the…