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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Photo of Sam Jungyun Choi Sam Jungyun Choi

Recognized by Law.com International as a Rising Star (2023), Sam Jungyun Choi is an associate in the technology regulatory group in Brussels. She advises leading multinationals on European and UK data protection law and new regulations and policy relating to innovative technologies, such…

Recognized by Law.com International as a Rising Star (2023), Sam Jungyun Choi is an associate in the technology regulatory group in Brussels. She advises leading multinationals on European and UK data protection law and new regulations and policy relating to innovative technologies, such as AI, digital health, and autonomous vehicles.

Sam is an expert on the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act, having advised on these laws since they started to apply. In recent years, her work has evolved to include advising companies on new data and digital laws in the EU, including the AI Act, Data Act and the Digital Services Act.

Sam’s practice includes advising on regulatory, compliance and policy issues that affect leading companies in the technology, life sciences and gaming companies on laws relating to privacy and data protection, digital services and AI. She advises clients on designing of new products and services, preparing privacy documentation, and developing data and AI governance programs. She also advises clients on matters relating to children’s privacy and policy initiatives relating to online safety.

Photo of Alan Kenny Alan Kenny

Focusing on high value, multi-party and multi-jurisdictional matters, Alan Kenny advises companies, banks, institutions, and high-net-worth individuals on all stages of dispute avoidance and resolution.

Alan has notable experience of high profile and complex commercial litigation, competition litigation, and class actions. He acts…

Focusing on high value, multi-party and multi-jurisdictional matters, Alan Kenny advises companies, banks, institutions, and high-net-worth individuals on all stages of dispute avoidance and resolution.

Alan has notable experience of high profile and complex commercial litigation, competition litigation, and class actions. He acts for clients in a broad range of industries with particular experience in financial services, technology, fast moving consumer goods, commodities, and media.

Alan has represented clients in:

Pre-action negotiations;
Mediation;
Commercial litigation before the English High Court and Court of Appeal (and internationally with local counsel);
Competition litigation, including class action proceedings before the UK’s Competition Appeal Tribunal;
International arbitration and trade association arbitration under a variety of rules, including LCIA, HKIAC, SCAI, LMAA, GAFTA and FOSFA;
Responding to enquiries from – and defending enforcement proceedings brought by – regulators in the UK and internationally;
Bringing competition-related complaints to the European Commission, leading to investigations and dawn raids;
Proceedings to obtain emergency and interim relief, including: security, vessel and container arrest, freezing orders, disclosure orders, Norwich Pharmacal and Bankers Trust orders, delivery up of passport orders, search orders, committal orders, and anti-suit injunctions;
Settlement negotiations;
Proceedings to enforce judgments; and
Proceedings to compel UK-based third parties to produce evidence under the Hague Convention for use in foreign proceedings.

Alan is a contributing editor of the International Comparative Legal Guide to Litigation and Dispute Resolution.

Alan’s recent pro bono work includes:

Advising an international development charity working to combat poverty and climate change, to settle disputes with distributors relating to its projects to provide access to solar power in Malawi and Zambia.
Representing a charity that provides young people with opportunities to explore orchestral music, obtaining a judgment and third party debt orders to successfully recover payments made to a catering company for services that were not provided.
Representing a vulnerable, single-parent immigrant family facing deportation to obtain rights of residence and access to public funds and pursue UK citizenship.
Representing a charity that works with vulnerable women and children to remove defamatory statements relating to the charity and its staff from third party websites, search engine result pages, and other media.

Photo of Moritz Hüsch Moritz Hüsch

Moritz Hüsch is partner in Covington’s Frankfurt office and co-chair of Covington’s Technology Industry Group as well as the IoT & AI Practice Groups. His practice focuses on complex technology- and data-driven licensing deals and cooperations, outsourcing, commercial contracts, e-commerce, m-commerce, as well…

Moritz Hüsch is partner in Covington’s Frankfurt office and co-chair of Covington’s Technology Industry Group as well as the IoT & AI Practice Groups. His practice focuses on complex technology- and data-driven licensing deals and cooperations, outsourcing, commercial contracts, e-commerce, m-commerce, as well as privacy and cybersecurity.

Moritz is regularly advising on issues and contracts with respect to IoT, AV, big data, digital health, and cloud-related subject matters. In addition, he regularly advises on all IP/IT-related questions in connection with M&A transactions. A particular focus of Moritz’s practice is on advising companies in the pharmaceutical, life sciences and healthcare sectors, where he regularly advises on complex licensing, data protection and IT law issues.

Moritz is regularly listed as one of the best lawyers in the areas of IP, IT, and data protection, among others, by Chambers, Legal 500, Best Lawyers in cooperation with Handelsblatt, and Wirtschaftswoche.