Proposal to simplify text on AV screening in the GID Introduction section. The revised text condenses the explanation that AV screening amendments to WP.29 Regulations are outside the scope of the GID. The original lengthy paragraph explained WP.29’s screening process, task forces, and technical requirements for systems such as braking, steering, and lighting. The revised text concisely states that WP.29 has updated its regulations concerning aspects of the DDT to enable their application to ADS vehicles, and these AV-related amendments are outside the scope of this document.

Proposal to add an interpretation of the term “other road user” in para. 2.21. of Definitions. The proposal defines “other road user” (ORU) as any entity making use of publicly accessible road infrastructure, covering users making intentional use of roadways with knowledge of traffic rules and other sentient entities that might be found in vehicle paths but cannot be expected to respond predictably based on vehicle signals or traffic rules, such as children and animals. The safety case would address both classes of ORU with appropriate adaptation to account for lower predictability of child and animal behaviours where relevant to the ODD of an ADS feature. The proposal was withdrawn for reconsideration during the further development of GTR 26 and UN Regulation 185.

Proposal to clarify para. 6.1.3.3.2. to specify that the requirement provides an exception for instances where there is a need to move the ADS vehicle before the operational state of its ADS can be verified, remove reference to fallback user since the requirement explicitly refers to ADSF-2, replace “Hand-over to fallback user” with “Allow an appropriate ADS user to take over control”, and clarify that the road safety agent may be permitted to drive the ADS vehicle manually.

Proposal to clarify guidance on reporting of system failures that compromise DDT performance by amending the description of reportable system failures, including modifying language regarding loss of redundancy or reduction in capabilities of ADS features to perform the entire DDT, replacing “failure in an actuator used by the ADS” with “hardware failure that compromises the capability of an ADS feature to perform the entire DDT,” and retaining the existing provision regarding degradation in computational capability.

Proposal to remove brackets from the ODD paragraph in section 7.3.1.3. The proposal removes square brackets that were included as a result of the ADS-20-46/Rev.3 discussion. The bracketed text addresses scenarios where a new area falls within existing ODD bounds, where deployment in that area might not require ODD modification, and where modifications to the area of operation would not require ODD modification provided conditions and environment in new areas of operation have been considered, but where operation in an area with different traffic laws or behaviour than those for which the ADS’s ability to comply has been demonstrated would require an amendment to the safety case.

Proposal to add animals and other road users as examples of entities an ADS may encounter in driving situations and test scenarios. The revised text adds “animals, or other road users” to the illustrative example in para. 2.33 and para. 2.34, and replaces “pedestrians” with “these entities” in the corresponding sentence about scenario design. This ensures scenario design used to demonstrate ADS competency explicitly accounts for animal encounters alongside pedestrians and other road users.

Proposal to add animals and children to examples of safety-relevant objects in para. 6.1.2.8. The revision inserts “Animals and children (in or adjacent to the roadway, under the vehicle carriage, etc)” into the illustrative and non-exhaustive list of safety-relevant objects. The proposal removes ambiguity for manufacturers developing safety cases and ensures consistent treatment across ADS requirements, making explicit that animals and children are safety-relevant objects even though they cannot be expected to respond predictably based on vehicle signals, traffic rules, or common conventions.

Proposal to amend the guidance on reporting safety-relevant communication issues by deleting “Such an occurrence could be reported in case of” and replacing it with “Examples of communication issues could include”, deleting “The remote interaction is unavailable” and replacing it with “Interruption of remote interaction,”, replacing “Information” with “Communication”, adding “the” before “safety threshold”, and adding “(if indicated in the safety case)” after “safety threshold”, and replacing the period after “unavailable” with “, or”.

Proposal to introduce guidance on reporting the average feature engagement time. The average engagement time is a statistical measure of how long an ADS feature stays engaged per activation, computed as cumulative time divided by number of activations. The average is expected to be computed in an aggregated manner over the whole fleet of vehicles having the same ADS feature, representing the average duration between activations and deactivations of a feature.

This document proposes guidance on reporting cyber security issues affecting autonomous driving systems safety. The proposal modifies the description of reportable cyber security incidents to replace “Safety-relevant ECU compromised” with “Any cybersecurity threat identified to safety relevant ECU, or” and deletes “ADS control channel manipulated.” The text also clarifies that reporting must align with UN R155 where this Regulation is applied, replacing the reference to “CSMS procedure where R155 is applied.”

Proposal to clarify guidance on reporting maintenance and repair issues by deleting “Such an occurrence is expected to be reported in case of” and inserting “Examples of maintenance or repair issues could include”, adding “safety-critical” before “software”, adding “potential” before “safety”, deleting “implications” and inserting “consequences, or”, deleting “Fitted hardware not compliant to safety performance specifications” and inserting “Not following the repair instructions given by the manufacturer.”

Proposal to clarify guidance on reporting unauthorized modifications to the ADS by deleting “Such an occurrence is expected to be reported in case of” and replacing it with “Examples of unauthorised modifications to the ADS could include”, deleting “Sensor tampering; obstruction;” and inserting language to specify that ADS-relevant software or hardware tampering, or third-party hardware interfering with ADS, could constitute unauthorized modifications affecting intended functionality.

Proposal to add a note that no guidance is provided on reporting when a feature required remote interaction to navigate a situation. The revised text adds that an active ADS feature required remote interaction to navigate a driving situation and marks guidance as N/A. Proposal was not accepted by the ADS IWG session.

Proposal to clarify that an appropriate ADSF-1 response to road-safety agent instructions could be a transfer of control to the fallback user while appropriately managing the response during system-initiated deactivation, add that deactivation of the ADS to enable non-ADS strategies to comply with road safety agent instructions is an appropriate response, label examples of non-ADS strategies and road safety agent instructions, and amend punctuation and references to jurisdiction in the final sentence.

Proposal to remove square brackets around “(also known as target operational domain)” in para. 7.3.2.6. The main objective of the paragraph is to compare the ODD with the expected operating conditions, which might not be identical. The proposal removes the square brackets used to clarify another term for expected operating conditions, as expected operating conditions and target operational domain refer to the same thing in different standards currently being updated.

These provisions require manufacturers to contact authorities in territories where features of the ADS can be active in advance of formally applying for approval. The intention is to make receiving authorities aware that an automated vehicle is destined for their territory. An ADS or feature whose ODD includes a geo-fence limiting operation to specific territories is clearly destined for just those territories. A manufacturer is not required to notify authorities in countries where the manufacturer does not intend to sell or operate the ADS or vehicles equipped with the ADS.

Proposal to remove the placeholder for guidance on expectations concerning mitigation risk condition end states in para. 7.3.1.14. and replace it with text from ADS-20-09 with one paragraph removed based on ADS-20-50. The revised text specifies that while ADS Performance of DDT requirements set out when an MRC is required, they do not specify the process to achieve the MRC or its end state. MRC end states are expected to be fully stopped with parking brake applied and could include activation of hazard lights. The process to reach an MRC is expected to vary depending on the situation and system capabilities, and possible end state examples include stopping in lane, on shoulder, exiting highway, or navigating to nearest parking spot.

Proposal to delete “the examples given below is not the only possible approach,” add clarification that examples are non-comprehensive and represent one possible approach for documenting claims, arguments and evidence, modify example descriptions to point to regulation requirements 5/7.3.3.2 (a) and (b), and incorporate examples from ADS-20-09 by removing the placeholder “Examples to be provided.”

Proposal to delete reference to no response within required time in section 14 on fallback user unavailability, and add reference to para. 4.2.2.1.6 (c) as the requirement for reporting MRC required due to non-response.

Proposal to remove guidance on prevention of unsafe takeovers. The document proposes deletion of the statement “Such an occurrence is expected to be reported when situation is unsuitable or unsafe for the subsequent mode of vehicle operation” from para. 15 of GTR Annex 1/UNR Annex 3, with no replacement text provided. The rationale indicates this removal reflects OPI group discussions aimed at finalizing the GID by resolving remaining open items.

Proposal for explanation that where confirmatory testing reveals apparent non-conformities, the assessor provides results to the manufacturer for review as foreseen by 6/8.3.3.1.2, the manufacturer conducts the same tests, and where results are consistent with the assessor’s, the manufacturer develops remedies and provides evidence to the assessor, or where manufacturer test results differ, the two parties discuss discrepancies and agree on next steps.

Proposal to clarify that non-ADS-related warnings refers to warnings from other vehicle systems generally managed by the ADS according to paragraph 6.3.6, that this requirement does not negate the need to give a certain warning to users where giving such a warning while an ADS feature is active is specifically required by other regulations, that this paragraph does not require such warnings to be suppressed, and that consideration should be given to how a warning is presented in the case that DDT-related warnings are not suppressed while an ADS feature is active.

Proposal for guidance on operational states, including remote termination and a diagram illustrating ADS and feature operational states, update guidance on terms “on”, “off”, “available,” “active,” “unavailable,” and “disabled” as canonical operational state terms for ADS descriptions and clarify that “active” applies only to features.

Proposal to delete and amend the draft guidance on para. 8.1.7.1. to replace “The intention of this requirement is to ensure that organizations have robust mechanisms to verify, monitor, and continuously improve safety performance. The regulatory text emphasizes” with “The Regulation implies,” delete “evidence-based” from the description of safety assurance as a continuous process, replace “aimed at ensuring that” with “to monitor the effectiveness of,” delete “remain effective” after “safety measures,” replace “whether” with “insofar that” and delete “risk control measures remain effective and whether” in the definition of safety assurance, delete “systematic” before “processes,” replace “that” with “on” after “confidence,” delete “and” before “products,” replace “established” with deletion, replace “employee reporting” with “internal feedback,” add “to maintain the demonstrated performance” after “safety improvements,” add “of KPI for the organization” in the evaluation clause, and replace “improvement of” with deletion and restructure the final clause to read “of the products.”

Proposal to modify the interpretation text for para. 8.1.7.1.(a) to replace “ensures” with “focuses on” in the statement describing the element for periodic independent internal audits and external audits.