techUK responds to autonomous vehicle consultations

techUK has responded to the first two of a series of consultations from the government on the future regulatory framework for the rollout of self-driving vehicles in the UK. These were on protecting marketing terms to ensure that advertising and public information is accurate and on the upcoming Statement of Safety Principles, which is designed to build public trust in this technology. Now we will turn to the third consultation – on Automated Passenger Services.

We are very grateful to all members of our Self-Driving Vehicles Working Group who contributed to our responses. If you are interested in getting involved in our self-driving vehicle work and joining our Self Driving Vehicles Working Group, or if you have any questions on these two consultation responses, please contact [email protected]. Details of our responses can be found below.

Statement of Safety Principles

In our response to the Safety Principles, we broadly support the proposals, but we emphasise the need to ensure that they align with international standards and regulations and not impose new, separate obligations which would create duplication and increase regulatory burden. We think that the Safety Principles should serve as a high-level, publicly-understandable framework to build trust and communicate safety, rather than act as a technical compliance tool.

On the subject of ongoing monitoring, we believe that monitoring should rely on objective outcomes like collisions and injuries, contextualised within each AV’s Operational Design Domain (ODD). We particularly highlighted that reporting statistics must be presented with great care and in the proper context to ensure a fair representation of AVs.

Protecting Marketing terms

In our response to the marketing terms consultation, we outlined our support for the principle of protecting specific marketing terms such as “self-driving,” “driverless,” “automated driving,” and “autonomous driving.” However, we stressed that protections must be carefully scoped to avoid unintended consequences for legitimate commercial activities, particularly those not aimed at end-users—such as B2B marketing, public education, and strategic partnerships.