Our agenda

Six changes for Brussels and The Hague.

Each ask names the problem it answers and the rules it touches. We cite only rules we have read in the Official Journal of the EU or in UN documents, checked on 3 October 2026.

01

EU-wide approval for proven systems

The problem
A new automated system can get a provisional EU type approval that is valid only in the member state that granted it. Other member states may accept it one by one, and EU-wide validity needs a Commission decision. The RDW approval of Tesla FSD (Supervised) from April 2026 is currently valid only in the Netherlands17. Approval of fully automated vehicles in unlimited numbers exists only for automated valet parking.
What we ask
Approve systems once they show better safety outcomes. Mutual recognition then lets a car approved in one member state drive in all of them.
Rules it touches
02

Updates at software speed

The problem
Under UN Regulation No. 156, a software change that affects type approval can mean an extended or a new approval. Manufacturers must also show that updates over the air will not affect safety while driving.
What we ask
A risk-based route for over-the-air updates, building on UN Regulation No. 156, so a safer version does not wait months for paperwork.
Rules it touches
  • UN Regulation No. 156 on software updates

    Para. 7.1.4.1 Manufacturers must show that updates over the air will not affect safety if installed while driving.

    Para. 7.2.1.2.1 A software change that leads to an extended or new approval must carry a new software identification number (RXSWIN).

    Para. 9.1.3 The approval authority checks the update process at intervals, including updates the manufacturer chose not to notify.

  • Draft UN Regulation on Automated Driving Systems, ECE/TRANS/WP.29/2026/137

    Para. 6.3.3 Automated driving systems must support safe and secure software updates, following UN Regulation No. 156.

    Draft. It takes effect unless a fifth of the parties object within six months of 30 July 2026.

03

Open safety data

The problem
Manufacturers of automated vehicles already report safety-critical occurrences and send yearly reports. Those reports go to type-approval authorities and the Commission. Driver-assistance reports under UN Regulation No. 171 are shared between authorities in confidence. We found no EU or UN rule that requires publication.
What we ask
Standard, public reporting of real-world safety for every driver-assistance and automated system, from every manufacturer.
Rules it touches
04

A European human benchmark

The problem
The draft UN regulation on automated driving systems sets the bar at a competent and careful human driver20. Neither the draft nor EU law defines that driver with crash data. Published comparisons, such as Waymo's, use human crash rates from US cities7.
What we ask
Comparable crash rates for human drivers per country and road type, so every system is measured against real human driving.
Rules it touches
05

Testbeds in every member state

The problem
The Commission's 2025 action plan promises at least three large-scale cross-border testbeds from 202616. In June 2026, eighteen member states signed a declaration backing them18. The declaration is not binding and sets no deadline.
What we ask
Large-scale public testing in all 27 member states by 2028, extending the June 2026 declaration of eighteen states.
Rules it touches
06

Proportionate driver monitoring

The problem
UN Regulation No. 171 requires driver-assistance systems to detect when a driver looks away, at least by tracking eye gaze. A driver judged not engaged enough loses the system for at least half an hour. EU law already limits what drowsiness and distraction warnings may record, and bars sharing with third parties.
What we ask
Rules that keep drivers engaged where supervision is needed, without punishing safe use, and that protect drivers' privacy.
Rules it touches