This document is a draft Guidance and Interpretation Document (GID) for UN Global Technical Regulation and UN Regulation on Automated Driving Systems, based on GRVA/2026/3 as amended by GRVA-24-29 and WP.29-198-09. The GID provides explanatory text, guidance, and examples to support implementation of ADS requirements without introducing new obligations. It covers scope, definitions, application for approval, approval procedures, ADS performance requirements in nominal, critical, and failure situations, interactions between ADS and users, safety management systems, test environments including simulation credibility frameworks, safety case requirements, post-deployment safety monitoring with reportable occurrences, and compliance assessment procedures. The document clarifies terminology including operational states of ADS features, critical occurrences, driving situations, and mitigated risk conditions, and provides detailed guidance on ODD definition, safety case structure, confirmatory testing approaches, and in-service reporting templates with threshold definitions for critical occurrences.

The Informal Working Group on Automated Driving Systems identified topics for future consideration organized into four lists: items not addressed in original versions of the GTR/UNR; existing items requiring amendment or improvement; items relating to operational implementation; and other items. List 1 includes remote assistance, ODD description taxonomy, external human-machine interface provisions, and connectivity considerations. List 2 includes ADS to ADAS transitions, Data Storage Systems for Automated Driving, ADS deactivation, in-service monitoring and reporting, and safety case requirements. List 3 addresses interpretation document improvements, mutual recognition provisions review, system updates and thresholds, and practical implementation of in-service monitoring. List 4 includes text streamlining to remove duplication and improve clarity.

Since January 2026, the group accepted proposals ADS-20-15, ADS-20-16, and ADS-20-48/Rev.1 for minor amendments. Working documents WP.29/2026/139 and WP.29/2026/137 were submitted for WP.29’s 199th session. Two informal documents (ADS-20-59 and ADS-20-60) will amend these working documents. GRVA seeks a three-year mandate extension for the informal group to address identified future work items beyond June 2026.

Proposal to amend ECE/TRANS/WP.29/2026/137: replace “[ADS]”, “[XXX]”, and “[number of this Regulation]” with the UN Regulation number upon adoption throughout Contents, Appendices, and Annexes; amend para. 1.2. cross-reference to read “7.2.3.17.”; amend para. 6.2.2.3.8.1.(b) to specify gaze directed to “the” driving task relevant area; remove brackets around “7.4.” in para. 11.2.; add period after number in Annex 1 para. 5.1.; amend Annex 1 Appendix 1 paras. 1.4.5., 1.4.7., and renumber 1.4.12., 1.4.12.1., 1.4.12.2. as 1.4.11.5., 1.4.11.5.1., 1.4.11.5.2.; amend Annex 7 table 5 rows 1–2 column 7 to replace “minimal risk manoeuvre” with “fallback to a mitigated risk condition”; remove brackets in Annex 8 para. 5.3.1. and amend para. 5.3.2. table to insert “Mandatory” in row 1.

Proposal to amend WP.29/2026/139 to amend para. 4.2.2.3.8.1. subparagraph (b) to replace “a the driving task relevant area” with “the driving task relevant area”, amend para. 6.3.2.2.3. to replace “approval authority” with “assessment”, amend Annex 5 table 5 rows 1 and 2 column 7 to replace “minimal risk manoeuvre” with “fallback to a mitigated risk condition” and remove brackets around deceleration threshold from ⁴ m/s², remove brackets in Annex 6 para. 5.3.1., and amend Annex 6 para. 5.3.2. table to insert “Mandatory” in row 1 column 2 and remove brackets after the table.

Proposal to revise the guidance on para. 6.1.2.3 of the draft UN Regulation on ADS regarding unreasonable disruption to traffic. The revision changes “prevent normal interaction” to “allow normal interaction” and “require other road users” to “may technically require other road users” to clarify that the requirement permits normal interaction with traffic, such as using on ramps, slowing for traffic lights, and waiting at unprotected turns, where other road users must adapt their speed, without violating the requirement.

Proposal to amend ADS-20-12 (consolidated guidance document). The ADS shall have strategies to detect and respond to instructions from road safety agents. For ADSF-1, this allows transfer of control to the fallback user. Manufacturers may use non-ADS strategies including remote intervention or permitting the road safety agent to drive. Examples of instructions include pull over, give way, stop after collision, move out of way, avoid specific road, and not overtake. Instructions may be issued via lights, sirens, audio messages, written signs, or light bar messages.

Proposal to amend explanation of para. 6.2.2.1.4. to clarify that ‘while’ refers to continuous presentation of information sufficient to enable a user to take over performance of the DDT such as through ambient lighting, tell-tales, or dashboard colour changes. The explanation notes that information on adapted performance is only presented if applicable.

The ADS regulations (GTR and UNR) include definitions for reporting thresholds based on EDR triggering. Time-series data recording for heavy vehicles under UN R169 requires triggers and trigger thresholds to record data in specified time periods, which may not immediately precede, follow, or coincide with crashes. Last Stop, Safety Systems, and Sudden Deceleration triggers are unreliable crash indications. Sudden Deceleration is too sensitive for storing time-series data over several months. Optional SRS or a new independent trigger alongside Detected Collision offers the only viable possibility for effective time-series data recording.

Proposal to revise explanation of Annex 3 in the draft guidance document. The change proposes language clarifying that performance issues constitute an unreasonable risk to safety only when deviations, degradations, or limitations in ADS capabilities, based on analysis of their frequency and severity, present an unreasonable risk within the declared ODD. The revision specifies that listed factors are examples for consideration in determining whether an unreasonable risk exists but do not necessarily constitute such a risk themselves.

Proposal to amend para. 6.2.2.3.8.1 (b) to change “a driving task relevant area” to “the driving task relevant area” and to expand the accompanying GID text to define the driving task relevant area as consisting of different zones including inside mirror, left outside mirror, right outside mirror, left window, right window, windscreen, and instrument cluster or instrument display, and to clarify that depending on the type of ADS feature and driving situation the user could be suitable to have looked at just one zone or more than one zone.

Proposal to remove explanation for para. 7.3.1.14. The document suggests differences in how ADSF-1 and ADSF-2 vehicles would handle fallbacks to a mitigated risk conditions that have not been fully explored by the ADS informal group. Rather than speculate, the preparatory discussions among IWG experts resulted in a recommendation to omit this explanation pending the next phase of work on the regulations.

Proposal to explain para. 8.3.3.1. of the draft UN Regulation. The proposal addresses residual comments concerning wording used to derive scenarios for confirmatory testing by removing terminology not used in the regulation to avoid mis-interpretations. Confirmatory testing scenarios depend on the ADS feature, its ODD, and safety case scenarios. When selecting scenarios, the assessor may consider the ADS system description and its safety concept, and the safety claims presented in the safety case. Confirmatory testing may be undertaken using virtual testing, expected to be within the scope and capability of the toolchain being used, and can be within, at the boundary of or outside the ODD.

Proposal to explain paragraph 8.3.2.1.2. The revision clarifies that coverage can be evaluated based on the following items and their interdependencies: Operational Environment, Behavioural competency, Scenario-type/category, and Rules of road compliance. A footnote acknowledges that no single item alone can robustly document coverage.

Proposal to explain para. 8.3.3.1.1. The revised text clarifies that relevant standards supporting the assessment of laboratories could include ISO/IEC 17025 Testing and calibration laboratories, which sets requirements for competence, impartiality, and consistent operation. Applied to ADS testing, it ensures measurements are traceable, validated, and reproducible so results are technically reliable and defensible for approval/certification purposes. However, there is no obligation for the manufacturer or third-party organization involved in the testing to be accredited according to ISO/IEC 17025.

Proposal to explain para. 8.3.2.4.1.4. The revised text divides guidance between ADS users and other road users. For ADS users, representativeness means including a range whose behaviours, skills, and characteristics reflect those reasonably expected to use the ADS, with testing not limited to engineers. For other road users, representativeness means capturing a sufficiently broad range of real-world behaviours and characteristics relevant to the ODD. The revised proposal also addresses statistical significance, encouraging manufacturers to provide calculations explaining their choice of participant numbers and underlying assumptions.

Proposal to explain para. 7.3.2.14. The revised text simplifies the definition of ‘sufficient’ to refer to the scope of tests performed on the fall-back response. With respect to scenarios, the manufacturer is encouraged to describe reasoning behind scenario choice and justification for the overall number chosen, acknowledging that scenario diversity depends on intended use case and operational design domain. References to user numbers and statistical methods for sample size assessment have been removed.

Proposal to clarify section 6.1.2.1 regarding crash causation. During approval process, when collisions involve the ADS during the manufacturer’s real-world or confirmatory testing, a root cause analysis is required and an explanation provided. Where the ADS is determined to have played a role in causation, the manufacturer will provide evidence of how related causal factors have been addressed in the final ADS prior to approval. Post-deployment collisions are covered by the ISMR process taking into account the applicable law of the country in which the collision occurred.

Proposal to amend Paragraph 5.3.1.3 (GTR) / 7.3.1.3 (UNR) in Safety Case. The revision replaces “no new behaviours or traffic flows” with “no new behaviours or traffic flows density or dynamic element types” and adds “or traffic behaviour” to the text regarding traffic laws because ODD does not include a definition of traffic behaviour, making the original sentence factually incorrect.

Proposal to amend paragraph 5.3.1.3 (GTR) / 7.3.1.3 (UNR) in Safety Case. The revised text adds “attributes and their respective values” to replace “parameters” in the sentence about links/dependencies between ODD parameters, to ensure consistent terminology and reflect that dependencies exist not only between attributes but also between their values.