Comments on the draft consolidated reference document for AI use in regulated automotive safety systems. The comments propose editorial changes to the introduction; minor editorial modifications; and substantive contributions to AI use cases in driving functions (section 3.2) and non-driving functions (section 3.3). Canada’s contributions include additions to risk descriptions such as lack of resilience, regression or catastrophic forgetting, bias as systematic performance disparities, and degradation of AI safety processes over time; expanded guidance on risk management practices with specific automotive examples; and clarification of verification, validation, data management, and operational monitoring requirements aligned with existing standards including ISO 26262, ISO 21448, ISO 23894, and UN Regulations 155 and 156.
Proposals for revisions to Section I including highlighted deletions, addition of two paragraphs (2.3, 2.4) in Section II with a request to add safety benefits to para. 2.6, editorial requests for text placement in Section III introducing use case content, small editorial proposals in Section IV’s introduction, merging of whole lifecycle and organizational risks, removal of para. 4.6 (systematic performance disparities) in favour of para. 4.5, revision of para. 6.2 (concept drift), removal or moving of para. 6.5 to whole lifecycle risks, and substantive suggestions in Section V for deletion, merging and restructuring of Table 2 with standard and title references only. Annex 1 critiques the need for extended descriptions.
The IWG on AI will hold its 9th session on June 3–4, 2026 in London. The agenda includes adoption of the agenda and brief report of the 8th session (AI-09-01), consideration of AI use cases, literature review and terms & definitions proposals, guiding questions for WP.29 submission, and discussion of the consolidated draft reference document. The IWG will receive presentations from stakeholders on AI use in the automotive sector and discuss future meetings and work direction beyond the initial mandate.
Proposal to merge the requirements of Regulations Nos. 36, 52 and 107, together with European Community Directive 2001/85/EC.
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