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.

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.

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 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.

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. 6.1.2.1. of the ADS UN Regulation. The revision clarifies that where collisions involving the ADS occur during the approval process, including manufacturer’s on-road testing or confirmatory testing, a root cause analysis must be done 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 as implemented within national law.

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.

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.

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 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.