Proposal to clarify that ADS Off means the ADS is prevented from performing any activity, and ADS On means the ADS has been requested to perform activity, either an ADS feature is performing the DDT or the system is in ADS Standby, to distinguish ADS Off from ADS Standby and be consistent with off mode definition in UN R171.

Proposal to amend Figure 1 in para. 4.2.2.2.3 to add an (ADS feature) Available box within the ADS Standby box. The (ADS feature) Available state shows that no ADS feature is performing the DDT, however the ADS may be performing some other activity such as determining whether the vehicle is in the ODD. The figure depicts ADS Off, ADS Standby, ADS Feature (A) Active, ADS Feature (B) Active states with transitions for Activation, Deactivation, Switching On, and Switching Off.

The 19th Automated Driving Systems session in Shanghai (February 2026) involved approximately 90 participants from multiple countries and organizations. Key outcomes included adoption of amendments to UNR and GTR on ADS, addressing EDR/DSSAD definitions and recording intervals, and reviewing Guidance and Interpretation Document sections covering introduction, DDT performance, audit, user interaction, approval, FADS, safety case, testing, and ISMR. Outstanding items for resolution include remote assistance prioritization and future work program definition. Amendments will be submitted to WP.29 in June 2026. Future meetings scheduled for April-May in Bangkok and July in Brussels.

Proposal to amend WP.29-198-07. Paragraph 5.3.2. is amended to specify that the “Condition for requirement” field for visual images in the time-series data table during a triggering event is set to “Mandatory,” with a recording interval of -7 to +7 seconds relative to the triggering event. The EDR/DSSAD-IWG has agreed to this modification to complete the blank field in the original document.

Proposal to amend WP.29-198-09. The proposal modifies paragraph 5.3.2 to specify that visual images are mandatory data elements to be recorded during a triggering event, with a recording interval of minus 7 to plus 7 seconds relative to the triggering event. The EDR/DSSAD-IWG has agreed to set the condition for requirement field to “Mandatory” in the visual image table.

This document consolidates inputs from Officers of Principal Interest (OPI) on the Automated Driving Systems (ADS) Guidance and Interpretation Document and organizes content into regulatory text, guidance, comments, and examples to facilitate April-May 2026 Workshop discussions. The document provides interpretation of UN Global Technical Regulation and UN Regulation requirements on ADS, addressing safety performance of the Dynamic Driving Task in nominal, critical, and failure situations; interactions between ADS and users; post-deployment safety monitoring through Safety Performance Indicators; Safety Management System audit criteria; and simulation credibility frameworks for verification and validation, while emphasizing that guidance does not introduce new requirements and that the Regulations remain the sole authoritative texts under 1958 and 1998 Agreements.

Proposals for a new GTR and UNR pending before WP.29 in June are based on texts approved by GRVA in January plus text in brackets from EDR/DSSAD and ADS IWG February sessions (presented to WP.29 in WP.29-198-07 and WP.29-198-09). The IWG must send a proposal to GRVA to remove brackets. OPI materials (ADS-20-03 to ADS-20-11) have been consolidated into ADS-20-12/Rev.2 for review to inform structuring of the Guidance and Interpretation Document on ADS. Session discussions address harmonization, compliance, and preparation for July submission.

Proposal to revise the explanation for para. 8.3.3.1 to clarify the relationship between assessment of the manufacturer’s testing under 8.3.2 and confirmatory testing. The revision adds language specifying that during assessment, the assessor can determine the need for additional scenarios or variations and shall convey this information to the manufacturer requesting additional test evidence under agreed upon protocols. The revision changes “trustworthy” to “accurate” and specifies that confirmatory testing verifies the accuracy of the manufacturer’s testing, with the exception of real-world testing that cannot be precisely replicated.

Proposal to clarify components and functions of the ADS and other vehicle systems relevant to meeting the requirements of the regulation (paras. 5.3.1.4.2 (GTR)/7.3.1.4.2 (UNR)). The revised text specifies that other vehicle systems could include shared components or functions such as sensors, map data, and GNSS used for assistance systems or positioning. Information from outside the vehicle may be included if used to meet regulation requirements. The manufacturer could use different diagram types provided information is present, and additional information regarding wireless links could be included.

The change request seeks clarification that “real-time” operational and tactical functions of the DDT, particularly “sensing and perception” and “planning and decision”, could be achieved through real-time sensor inputs alone or through integration of sensor inputs with other contextual information such as map-based data, to aid technical inspectors during testing and assessment of ADS systems.

The revised text adds ISO 21448, GB/T 34590 Road vehicles-Functional safety, and GB/T 43267 Road vehicles – Safety of the intended functionality to the original reference standards ISO 26262-2/8:2028 and ISO 9001 2015. GB/T 34590 is an important reference for functional safety in China and ISO 21448 and GB/T 43267 are important references for SOTIF.

Proposal to update the explanation on reportable occurrences in Annex 1 (GTR) and 3 (UNR). The revision refines language in the requirement describing the manufacturer’s Safety Management System by removing “expected” to avoid implying obligation and clarifying the link between occurrence monitoring, reporting, analysis, system updates, improvements, and continuous improvement processes.

Proposal to clarify EDR provision in Annex on thresholds. For vehicle categories M₂, M₃, N₂, and N₃, the revised text clarifies that UN Regulation No. 169 does not include a representative delta V threshold. The manufacturer could determine their own delta-V trigger for a critical occurrence, including one based on a subset of EDR triggers, with no obligation to do so.

Proposal to clarify MRC for ADSF-2 in para. 6.1.5.4.1. The revised text corrects the assertion that ADSF-2 features can meet a lower standard for MRC because of fallback user presence in ADSF-1. It clarifies that ADSF-2 features do not include an ADS fallback response requiring a fallback user, though such features may be present in vehicles with human users. Both ADSF-1 and ADSF-2 features must aim to bring the ADS vehicle to a stop in a safe location complying with traffic rules following ODD exit.

Proposal to revise Annex 3, item 2 regarding “ADS failure to achieve a mitigated risk condition when necessary.” The revised text maintains the four bullet points describing when such occurrence is expected to be reported when an MRC is required. The rationale states the regulatory text does not require reporting when an MRC is achieved but in an unsafe stop location, which is not defined in the regulation, nor when an MRC is achieved but conflicts occur during the MRC.

Proposal to amend ADS-20-12 (consolidated guidance document). The terms faults, malfunctions, and abnormalities lack distinct meanings in requirement 6.1.4.2. The revised explanation clarifies that “faults, malfunctions, and abnormalities” do not have specific distinct meanings and cover any failure in the ADS’ capability to perform the DDT within the ODD. The three kinds of issues encompassed are warning signals from other systems, faults without warning signals a driver would perceive, and faults within the ADS itself.

This proposal for ADS Regulation version 2 addresses remote support for automated driving systems. ECE/TRANS/WP.29/2026/137 contains 19 instances of remote references across definitions, requirements, and annexes, with only remote termination defined. The proposal requests UNECE GRVA to introduce and define different types of remote support, clarify terminology distinctions between remote monitoring, remote assistance, and remote intervention, and articulate which aspects of remote support the regulation covers. The submitter offers to provide definitions developed with ISO 26361 for consideration at the July 2026 ADS IWG meeting.

This change request proposes to amend the explanatory text for para. 6.1.2.11. (UNR)/4.1.2.11. (GTR) by modifying the phrase “the ADS is always responsible for detecting them” to “the ADS is always responsible for detecting and responding to them” and by deleting two “remote intervention” examples of non-ADS strategies. The rationale states that the ADS is responsible for both detection and response to instructions from road safety agents, and that remote intervention examples should be avoided at the current stage as this topic is already under discussion in Phase Two.

Proposal to delete from the interpretation of failures to meet ADS requirements under para. 6 in Annex 3 the items “Collisions” and “Deviation from Remote Interaction/Intervention as described in the Safety case,” as these are not ADS requirements under para. 6, and collisions are otherwise reportable under the critical occurrences criterion.

Proposal to insert provisions clarifying that when assessing manufacturer’s testing activities under paras. 8.3.2.1.1, 8.3.2.1.2, 8.3.2.2.2, and 8.3.2.2.3, the approval authority or designated technical service may identify situations or scenarios not included in manufacturer’s test evidence, convey that information to the manufacturer, and request additional test evidence covering those situations or scenarios under agreed upon protocols, with the assessor able to determine the need for variations to tested scenarios or conditions to verify that the manufacturer’s evidence is representative and able to support the safety case, where variations may include adjustments to initial conditions, parameter ranges, or environmental assumptions within the bounds or at the boundaries of the declared ODD but may also consider behaviour at ODD exit or outside the ODD, with such variations expected to be reasonable and compatible with the limitations and abilities of the toolchains and allow comparison with initial results provided by the manufacturer or be assessable against the expected behaviour of the system.

The change request seeks to amend the road-safety agent Instructions explanation to indicate that examples regarding road safety agent instructions to the ADS vehicle are territory-based. The revision adds the phrase “which depending on the country of operation” to both the list of example instructions and the statement regarding communication methods, clarifying that instructions from road safety agents vary from country to country.

Proposal to amend para. 6.1.2.5 (UNR)/4.1.2.5 (GTR) to clarify that the ADS is always responsible for detecting and responding to priority vehicles, and to delete the examples of non-ADS strategies involving remote intervention.

The 20th ADS informal working group session and 17th GRVA Workshop on Automated Driving Systems will meet during 27 April-1 May 2026. The session will address proposals to amend the draft Guidance and Interpretation Document covering definitions, performance of the DDT, scope, application for approval, general requirements, interactions between the ADS and its user(s), safety management systems, post-deployment safety, test environments, and certificate of compliance. Additional agenda items include further development of the GTR and UNR and consideration of next steps and future meetings.

This document presents the status of the Guidance and Interpretation document for UN Regulation and GTR ADS, submitted by the OPI on ISMR provisions. It outlines closed topics including clarification on EDR trigger for critical occurrence, confidentiality and publication of information, and guidance on short-term, periodic templates and SPIs. Ongoing work addresses guidance on occurrences with examples of situations and metrics for ADS operation outside its ODD, and guidance for development of scenarios derived from ISMR activities.

Proposal to amend para. 8.1.5.1. (ADS UNR) of the audit of the safety policy guidance: Change “may state” to “states,” “may address” to “addresses,” and “may therefore describe” to “therefore describes.” The rationale states that using “may” in the interpretation paragraphs seems inappropriate for explaining regulatory intention, and present tense better suits these requirements.

Proposal to delete example “collision” under “Failure to meet the ADS requirements under paragraph 6 of this Regulation” in Annex 1 (GTR) and 3 (UNR) List of reportable occurrences by reporting type. The rationale states that not all collisions involving ADS vehicles constitute failure to meet ADS requirements, as some collisions are not caused by ADS or the ADS vehicle, and some collisions are not avoidable, such as suddenly appearing obstructing road users.

Proposal to correct a paragraph number error in para. 5.3.2.15 of the GTR and para. 7.3.2.15 of the UNR by renumbering them as 5.3.2.14 and 7.3.2.14 respectively. The safety concept shall describe the manufacturer’s approach to scenario selection to cover the reasonably foreseeable situations and conditions that the ADS will encounter including how the following aspects are covered, aligned with WP.29/2026/139 (GTR) and WP.29/2026/137 (UNR).

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 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.

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. 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 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. 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 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 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 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 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.

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 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.

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 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 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.

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.

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 20th ADS IWG and 17th GRVA Workshop on ADS convened in Bangkok from April 27 to May 1, 2026. OPIs consolidated draft text for the Guidance and Interpretation document (GID) on ADS, addressing DDT performance, application for approval, user interactions, SMS, ISMR, safety case, and assessment provisions. The GID would be submitted to GRVA in May and WP.29 in June as an informal document, then officially in September and November. Numerous amendment proposals were discussed, including clarifications on crash causation, priority vehicles, road safety agents, MRC requirements, remote assistance, and scenario testing. The next session in Brussels (July 14-17) aims to finalize the GID, with Phase 2 work items to be considered thereafter.

Proposal to consider an official title for the GID. The original title “ADS Regulations Guidance and Interpretation Document” was for the baseline document used during the session in Bangkok. This title is not suitable for the official document intended for adoption by WP.29. The revised title is “UN Global Technical Regulation No. 26 and UN Regulation No. 185 Guidance and Interpretation Document,” reflecting the ADS regulations adopted by WP.29 with the expected numbers GTR 26 and UN R185.

The proposal revises para. 7.2.1.4.1. to replace the original text on personnel competencies with revised text that focuses on demonstrating confidence in personnel competence to support appropriate use of simulation results rather than prescribing specific qualifications, role profiles, or individual assessment criteria. Documentation may be supported through organisational or system-level arrangements including defining responsibilities, identifying knowledge and skills needed, providing training and supervision, maintaining records of experience and qualifications, and providing evidence of accreditations and management systems.

Proposal to delete the interpretation in para. 7.2.1.9.1. The Testing sub-group decided not to provide additional guidance regarding approaches for criticality. The topic is already covered in the Guidelines and Recommendations for ADS Safety (WP.29/2024/39). Several options were proposed but none achieved consensus, and potential compromise solutions did not provide a worthwhile addition on top of existing guidance already available in WP.29/2024/39.

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.

Proposal to specify GTR number 26 and UN Regulation number 185 to the Introductory Text.

Proposal to clarify that manufacturers need to contact authorities only in territories where features of the ADS can be active and the manufacturer intends to sell or operate the ADS, and add guidance explaining that an ADS or feature with a geo-fence limiting operation to specific territories is destined for those territories, while an ADS or feature with no specified geographic ODD condition may not be destined for specific territories, and manufacturers need not notify authorities in countries where they do not intend to sell or operate the ADS, though subsequent sale or operation in a non-notified territory requires approval revision or extension.

Proposal to add a bullet citing Automated Vehicle Safety Consortium (AVSC) Best Practice for ADS Remote Assistance Use Case (Nov. 27, 2023), available at https://avsc.sae-itc.com/publication/avsc-04-2023, which provides detailed explanation of different discrete functions underneath the broader remote operations heading, divided into interactions with vehicles or a fleet of vehicles and interactions with humans, with each then divided into more specific types of functions.

Proposal to delete text from the draft Introduction section of the Guidance and Interpretation Document on ADS Regulation. The formal submission to GRVA produced in June was based on the Workshop information document that contained additional explanations on the status of work. These contents are not appropriate for the final version of the Guidance and Interpretation Document.

Proposal to clarify in the introductory text that the document does not limit requirements or introduce new requirements, update the reference to WP.29 adoption of the Regulations under the 1958 and 1998 Agreements, and add explanation that interpretation examples are not exhaustive, definitive, or compulsory and that each safety case must be tailored to the characteristics of the automated driving system, its features, their operational design domain, and assessed on its own merits.

Proposal to delete the final sentence of the Introductory Text of the GID, which states “Nonetheless, the amendments to these other regulations, including those that enable performance of the DDT, are outside the scope of the ADS regulations and of this document.” The deletion removes redundant language already conveyed in the preceding text that modifications of other regulations related to ADS are outside the scope of this document.

Proposal to replace “all entirely” with “solely” in the Introduction.

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 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 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 to modify the ADS guidance and interpretation document to replace references to “The ADS” with “An ADS feature,” replace “activates accepts activation” with “activates,” replace “violation” with “failure to meet the ODD conditions,” change “the” to “an” before “ADS feature,” and add “or” between the second and third bullet points under ADS operation outside its ODD. These changes reflect the outcome of OPI subgroup meetings where stakeholders achieved a compromise solution on open items.

Proposal to add examples to clarify reporting on failures to achieve mitigated risk condition. The document expands existing text on ADS failure to achieve a mitigated risk condition when necessary by adding that the ADS does not transit to a safe state in accordance with manufacturer-defined response documented in the safety case, the chosen stop location is unsafe, or the chosen stop location could be reasonably considered by the manufacturer to have contributed to a collision involving the ADS vehicle before it has moved from that location.

Proposal to add examples to the guidance on reporting noncompliance with DDT performance requirements under para. 6, specifying that failures include systematic or repeated deviations from DDT performance requirements defined under para. 6, non-compliance with respect to DDT performance requirements and requirements on interactions between the ADS and its user or other requirements under para. 6, and deviation from Remote Interaction/Intervention as described in the Safety case, with a note that some examples can reveal unreasonable risk to safety requiring only a single report noting this aspect.

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.

Proposal to modify the explanation on performance issues constituting an unreasonable risk to safety by specifying that this occurrence should be understood as deviations, degradations, or performance limitations shown by an ADS feature that affect its ability to perform the DDT within the declared ODD, triggered by events that present an unreasonable risk to safety and/or are beyond expected variability or acceptable degradation, replace “may” with “might” in references to discrete failures and risk existence, replace “Violation of” with “Non-compliance with respect to the”, delete references to identified reduction in safety margins and exceeding overall hazard exposure thresholds, replace “the rate of hazardous event occurrences” with “hazardous event exposure:”, and replace “suggests” with “could suggest”.

Proposal to clarify guidance on reporting uncompleted system-initiated deactivations by deleting “i.e.” and “the user has not properly taken over control of the”, inserting “is left to the user,” after “vehicle control”, inserting “An” before “ADS”, inserting “feature” after “ADS”, inserting “, or” after the clause on driving responsibility, and inserting “The user is not properly re-engaged as defined paragraph 4.2/6.2 of the regulation.” as an additional reporting criterion.

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 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 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 for guidance on reporting average feature engagement time in para. 4. The average engagement time is a statistical measure of how long an ADS feature stays engaged per activation (e.g., cumulative time / number of activations). The average is expected to be computed in an aggregated manner, i.e., over the whole fleet of vehicles having the same ADS 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. This change was accepted as amended following OPI-group discussions aimed at finalizing the GID by reaching a compromise solution on remaining open items.

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 to clarify reporting of vehicle approval numbers by inserting “(if applicable)” after “national or supra-national regulatory frameworks” in the vehicle approval number section of GTR Annex 2/UNR Annex 4. The insertion indicates that the vehicle approval number does not apply in all jurisdictions.

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 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 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.

Proposal to delete “The requirement highlights that safety assurance is expected to extend beyond the organization to include” from para. 8.1.7.1.(b), insert “Safety assurance covers the organization and also” in its place, and delete “, reflecting a system-of-systems perspective” from the same para. Document ADS-21-42.

Proposal to delete "This provision ensures that " and insert “This element focuses on” before “changes”, delete “systematically”, and insert "that " after “changes” in para. 8.1.7.1.© to improve and streamline the text so that the description reads “This element focuses on changes that are assessed and managed, recognizing that modifications can introduce new risks.”

Proposal to delete “The intention is to ensure that”, delete “organizations have”, insert “This element focuses on”, insert “the”, and insert “organization’s” in para. 8.1.7.1.(d) to improve and streamline the text, changing “The intention is to ensure that organizations have processes to identify, implement, and track corrective actions to maintain safety at an acceptable level” to “This element focuses on the organization’s processes to identify, implement, and track corrective actions to maintain safety at an acceptable level.”

Proposal to delete “This clarifies that corrective” and replace with “Corrective”, and delete “/systemic” in para. 8.1.7.1.(e). The revised text states: Corrective actions may address both technical aspects (ADS) and organizational aspects (SMS).

Proposal to revise para. 8.1.7.1.(g) to delete “Monitoring is expected to cover both the ADS and the SMS, ensuring a comprehensive view of safety performance.” and insert “Monitoring practices include the monitoring of the ADS product (i.e., using SPIs) and evaluation of the Safety Management System so that it remains effective (i.e., using KPIs).”

Proposal to amend para. 8.1.7.1.(f) to replace “ensures” with “focuses on” in the element text describing performance monitoring practices to track safety outcomes over time.

Agenda includes status of work on GTR and UNR proposals and the Guidance and Interpretation Document (GID), and proposals to resolve open items concerning:

• The baseline document integration of GTR provisions,
• Introduction to the GID,
• Terms and definitions,
• ADS operational states,
• DDT requirements,
• Other ADS requirements,
• Safety of interactions between the ADS and its user(s),
• Safety cases and their assessment,
• SMS requirements and their assessment,
• Test environment requirements and their assessment,
• In-service monitoring and reporting requirements and related annexes,
• Approvals and related annexes,

Proposal to modify para. 8.1.7.1.(h) to replace “aims to ensure that” with “focuses on”, replace “Assessment of how organizations coordinate” with “Assessment that organizations coordinate”, delete “and product reviews” from the list of change management triggers, and delete “the approach and output from various” before “monitoring procedures” and delete “including operational data, safety reports and performance indicator” from the examples of monitoring procedures.

Proposal to modify the safety risk management definition by replacing “the core” with “an”, changing “that supports” to “described in”, deleting “and the intended results of the Organization, as well as the effectiveness of other organizational processes”, capitalizing “Organization” to “organization”, and removing the comma after “Organization”. The term safety risk management restricts itself to the management of safety risks without consideration of factors such as financial, legal, economic, or reputational risks.

Proposal to amend the interpretation of para. 8.1.5.1.(d) to replace “a key” with “an”, delete “effective”, and insert “processes” before “of the SMS”. The proposal streamlines guidance text on SMS safety policy to improve clarity in describing how safety policy demonstrates management commitment to safety through approval by the accountable executive and supports promotion of safety and continuous improvement of the SMS.

DSSAD data, whether stored on or off the vehicle, shall be readily available and retrievable through an electronic communication interface that complies with a publicly available standard, with internationally recognized standards recommended to promote interoperability. Data elements concerning activation and deactivation of the feature shall be available via the vehicle’s information display or user interface where controls related to manual performance of the DDT are provided, with access to timestamps subject to restrictions ensuring compliance with data protection requirements.

The Informal Working Group on Automated Driving Systems identified topics for future consideration, categorised into four lists: items not addressed within original versions of the GTR/UNR; existing items requiring amendment or improvement; items relating to operational implementation; and other items. List 1 includes consistent Operational Design Domain description, external Human-Machine Interface provisions, and connectivity considerations. List 2 includes remote assistance, ADS to ADAS transitions, Data Storage Systems for Automated Driving, deactivation processes, and In-Service Monitoring and Reporting. List 3 addresses improvements from drafting interpretation documents, road safety agents, mutual recognition provisions, system updates, and Separate Technical Unit approval. List 4 addresses text streamlining. A Guidance and Interpretation Document is expected. Appendix 1 provides a work schedule beyond June 2026.

Proposal to replace text explaining that the ADS IWG did not reach consensus on definitions with clarification that remote intervention and remote interaction were not intended to convey different meanings in the regulation, both covering cases where the ADS requires support for tactical functions while continuing to perform the entire dynamic driving task, note that this aspect of ADS is a developing area, and include references to SAE J3016-2021, EU 2022/1426, the Automated Vehicle Safety Consortium Best Practice for ADS Remote Assistance Use Case (Nov. 27, 2023), and the upcoming ISO/PAS 26361 standard.

Proposal to improve guidance on para. 8.1.8.1. which focuses on aspects that support safety and safety culture such as people, competencies, and communication.

Proposal to improve the interpretation of para. 8.1.6.1.(d) on continued evaluation contributing to continuous learning so that SMS remains effective through modification and adaptation.

Proposal to add resources providing guidance on Safety Performance Indicators. The added resources include J3237, Dynamic Driving Task Assessment (DA) Metrics for Automated Driving Systems; AVSC00006202103, Automated Vehicle Safety Consortium (2021) Best Practice for Metrics and Methods for Assessing Safety Performance of Automated Driving Systems (ADS); AVSC00008202111, Automated Vehicle Safety Consortium (2021) AVSC Best Practice for Evaluation of Behavioural Competencies for ADS-Dedicated Vehicles (ADS-DVs); SAE J2944, Operational Definitions of Driving Performance Measures and Statistics; and SAE J3197, Automated Driving System Data Logger.

Based on ADS-21-68/Rev.1, amend para. 3.2.3.(b) to clarify that the regulation requires the safety level of ADS to be at least to the level of a competent and careful human driver as a general concept and technology-neutral comparator, that manufacturers should explain how they determine and apply this concept accounting for national specificities including those that might arise in relevant cases, that different approaches or combinations of approaches may be used varying depending on the safety concept, claims and argument structure, and approach to safety assessment, that no single approach is presumed better, that manufacturers may use more than one approach, that driver population reference data sets should be subject to appropriate selection, processing and interpretation, and to provide non-exhaustive examples of reference driver based approaches and behaviour-based approaches.

Proposal to revise the guidance text in para. 8.1.8.1.© by deleting “This element ensures the existence of effective communication channels, both internally and externally, to support awareness and information sharing.” and inserting “This point focuses on the existence of communication channels, both internal and external, to support awareness and information sharing.” The proposal follows comments received in the 18th ADS Workshop where discussion of the SMS section in a dedicated small drafting group was requested, and the current text aims at streamlining the text.

Proposal to delete text stating “The requirement highlights that competence is expected to be actively developed and maintained through structured training.” and insert text stating “This point focuses on the existence and maintenance of SMS training plans to support competence for the SMS management” as guidance on interpreting the requirement in para. 8.1.8.1.(b).

Proposal to improve the guidance to read “This point focuses on management of qualification and experience for roles responsible for making decisions that affect safety so there is appropriate level of competence to perform their duties.”

Proposal to remove brackets around GB/T 34590 Road vehicles – Functional safety and GB/T 43267 Road vehicles – Safety of the intended functionality in para. 8.1.5.1. References for Implementation. The approval authority or its designated technical service shall verify that the safety policy covers definition of principles and objectives, general recognition of inherent risks of ADS-related activities throughout their life cycle, organisational structure and safety governance elements, evidence of commitment to safety, and description of means/approaches to engage people within the organisation in the culture of safety.

Proposal to improve the interpretation of para. 8.1.5.1.(e) the description of the means/approaches to engage people within the organisation in the culture of safety.

Proposal to improve the interpretation of para. 8.1.5.1.© concerning the organizational structure and the safety governance elements and their appropriateness for the needs of the organisation.

Proposal to improve the interpretation of para. 8.1.5.1.(b) concerning the general recognition of the inherent risks of ADS-related activities throughout their life cycle, including the risks of the parties involved.

Proposal to improve the interpretation of para. 8.1.5.1.(a) concerning the definition of the principles and objectives upon which the SMS is built, operated, and maintained.

Proposal to improve the interpretation of para. 8.1.5.1. concerning the scope and contents of the manufacturer’s SMS safety policy.

Proposal to improve the interpretation of para. 8.1.6.1.(b) concerning verification that the risk-management activity is not limited to the ADS itself but includes risk arising from organisation/people which can affect the SMS effectiveness or the safety of the ADS.