Document identifies technical and drafting issues in UN R157 and its Global Technical Regulation equivalent requiring clarification or correction. Issues include:

• Definition of ‘Critical Occurrence’ using logically inconsistent language,
• Undefined terms like ‘area of operation’,
• Absence of provisions for reactivation after fault clearance,
• Incorrect cross-references between paragraphs,
• Non-standard citations such as ‘ISO 9001 Automotive’,
• Terminology inconsistencies between ‘alternative format’ and ‘alternative data’,
• Unclear assessment pathways for user information requirements,
• Inappropriate use of ‘demonstrate’ by approval authorities,
• Limited confidentiality scope,
• Misaligned section headings,
• Omission of 7.3.3 from safety case references,
• Interaction issues between reportable occurrence thresholds and systemic categories,
• Conflicting damage-area taxonomies between templates,
• Missing template rows,
• Undefined units and computations,
• Delta-V criterion applicability to L-category vehicles,
• Definition inconsistencies regarding vulnerable road user secondary safety systems,
• Out-of-scope self-certification references,
• Unspecified regulatory references for data retrievability,
• Missing remote termination recording,
• Inconsistent British versus American English spelling variants.

Review of the initial set of ADS Phase 2 work items and their integration into an ADS2 IWG plan for 2026-2028.

Calendar of planned meetings and activities for 2027.

NHTSA announced activity to update voluntary guidance on automated driving systems. A Federal Register Notice published July 31, 2026 opened a docket to solicit comment on proposed topics for guidance development. NHTSA intends to release draft guidance documents on individual topics as chapters and consolidate them into a final updated guidance document. The public comment period is scheduled to close July 31, 2027 and may be extended. Potential chapters address Emergency Responder Interactions, Safety Management System, Remote Assistance and Operational Oversight, Safety Case, Adherence to Multi-Jurisdictional Laws, Work Zone Operations, ADS System Capabilities and Behavioral Competencies, Verification and Validation with Advanced Testing Methodologies, Considerations for Driverless Deployment, Crashworthiness, Post-Crash Behavior, Human Machine Interface, Accessible Design, Data Monitoring Capture Reporting and Governance, and Maintenance Fleet Operations Continuous Safety Monitoring and Post-Deployment Enhancement.

Agenda for the 22nd ADS informal working group session and the 20th GRVA Workshop on ADS, held 6-9 October 2026 in Sydney, Australia. Day 1 covers welcome, agenda adoption, status of work, GRVA highlights, Guidance and Interpretation Document, ADS Phase 2 context, and review of Phase 2 programme proposals. Day 2 addresses refinement of Phase 2 tasks, Australia’s proposed framework, allocation of work items, and integration into 2026-2029 strategy. Day 3 includes ADS2 schedule, coordination with other groups, and GTR, UNR, and GID change requests. Day 4 covers next steps and first ADS2 IWG session logistics for December in The Hague.

Safety Performance Indicators (SPIs) are measurable metrics monitoring and evaluating ADS safety in operation, including lagging indicators recording outcomes like crashes and injuries, and leading indicators capturing precursors like near misses and risky behaviours. Research tested time-based and distance-based SPIs on the SHRP2 dataset containing 1402 crashes and 5262 near-crashes, achieving Area Under the Curve values of 0.883 for Distance Headway and 0.832 for Time-to-Collision in distinguishing crashes from normal driving. SPIs support safety cases, in-service monitoring and reporting requirements, and continuous ADS deployment monitoring, with future work extending analysis to additional datasets and field data collection.

Document identifies open questions regarding MRC definition, risk assessment, feature deactivation, and post-MRC obligations. Discusses reasons for MRC including collisions, faults, remote termination, ODD exits, and fallback user transition failures. Addresses post-MRC reporting and data recording under DSSAD and ISMR. Examines feature deactivation following MRC and ODD exit scenarios, with three possible solutions for ADSF-2 post-ODD exit recording.

Proposal to clarify that the ADS must respond to user requests to deactivate, require multimodal signals at the start of and during deactivation procedures that continue until completion or termination, require escalation of warnings for system-initiated deactivations if the user is not re-engaging as expected, require gradual reduction of ADS control action during deactivation while maintaining safe vehicle control, allow the ADS to retake full control if the vehicle is not being controlled safely, terminate the deactivation procedure if the user is not suitably engaged and the time available to transition has expired, replace the requirement for contact with the steering wheel with being in a physical position to operate the driving controls, suspend non-driving related activities at the start of the deactivation procedure, and modify the DDT section to require fallback to an MRC instead of a deactivation procedure if there is insufficient time for transition.

Proposal to modify para. 4.2.2.3.8.1 to add a requirement that a user be in a physical position to operate the driving controls, to allow gaze to be directed to multiple driving task-relevant areas rather than a single area, and to add a requirement that the user have demonstrated an appropriate response to transition of control.

Analysis of terminology related to remote support for automated driving systems, grouping terms into four categories: remote termination, remote fleet management, remote assistance, and remote driving. Remote termination disables ADS features until rescinded. Remote fleet management involves observation without performing the dynamic driving task. Remote assistance provides information while ADS continues the dynamic driving task. Remote driving involves a remote user performing the dynamic driving task. Document proposes agreeing on categories, determining definitions, developing a supplement without new requirements, and potentially developing proposals for new requirements covering ADS performance when expected remote support is not provided and further consideration of remote assistance.

Document presents initial considerations for approving Automated Driving Systems as Separate Technical Units under UN R185. It explains how component and STU approvals divide responsibility between suppliers and vehicle manufacturers, provides examples from other regulations such as lighting, tyres, glazing, and fuel systems, and discusses potential benefits and challenges specific to UN R185 application. Benefits include independent audits and avoiding repeated assessments for different vehicle types. Challenges include difficulty splitting requirements, potential information withholding, and unclear legal responsibility. Proposes flexible approaches with shared Safety Management System requirements and validation in vehicles.

Japan presents a proposed approach to address regulatory provisions for end-to-end (E2E) automated driving systems. E2E technology uses a single AI model to perform the entire driving task from perception to decision-making. While E2E systems offer benefits including flexible responses to traffic situations and reduced deployment costs through lower dependence on high-definition maps, concerns exist regarding their black-box nature, including limited visibility into decision-making processes, challenges with reproducibility, and difficulties with root cause analysis in accident investigations. The proposed approach involves three steps: identifying key issues related to E2E automated driving, discussing and organizing identified issues including possible E2E-specific requirements, and considering concrete amendment of provisions based on conclusions reached.

Document presents candidate amendments for ADS Regulation Phase 2 addressing Safety Management System and in-service monitoring and reporting. Proposes:

• An emergency recovery plan for fleet-level failures,
• Harmonization of SMS audit provisions and certificate mutual recognition,
• Split of operational and design responsibilities between operators and manufacturers,
• Refinement of occurrence classes with objective measurable criteria,
• Delta-V thresholds for all vehicle categories in scope,
• Extended reporting templates,
• Leading safety performance indicators,
• Confidentiality rules for ISMR data sharing,
• Explicit feedback loops from findings to corrective action and approval review.

Overview of activities under the testing sub-group for ADS regulations, covering approval, manufacturer requirements, and compliance assessment. Documents Level 1 and Level 2 requirements across virtual testing, track testing, and real-world testing environments. Identifies items not addressed in original versions, existing items requiring further consideration including safety case suitability testing and evidence generation, improvements identified during drafting GID discussions, and other items not included in previous lists.

Proposal to insert a requirement that at the start of the deactivation procedure, any non-driving related activities provided or enabled by the ADS vehicle that were permitted because an ADS feature is active shall be automatically suspended. The requirement applies only to activities provided or enabled by the ADS vehicle and only to NDRA permitted because an ADS feature is active, not to activities such as listening to music or navigation permitted while an ADS feature is not active.

The document identifies inconsistencies between requirements in sections 6 and 7 and assessment provisions in section 8 of UN R185, including requirements without specific assessment provisions, assessment provisions without corresponding requirements, and cases with no direct mapping between requirements and assessment. The document presents examples of problematic wording differences and asks whether section 8 should be retained as-is, aligned, simplified, removed, or consolidated into other sections.

Change request to establish a method to transfer vehicle control between the ADS and the user during the deactivation procedure. The ADS shall maintain safe control of the vehicle until the deactivation procedure is completed, gradually reduce its vehicle control action in response to the user assuming vehicle control, and may increase its control action if the reduction is leading to an unsafe vehicle response.

Change request to add new paragraph clarifying that an advance notification that the fallback user should prepare for a system-initiated deactivation shall not be considered as the start of the deactivation procedure. The existing text does not clearly define when a system-initiated deactivation procedure begins. Advance notification is a necessary tool to prepare the fallback user for re-engagement without prematurely starting the deactivation procedure.

Change request to clarify ADS response to user-initiated deactivations. Proposes to amend para. 4.2.2.3.3 to specify that for ADSF-2 systems, deactivation procedures shall only be initiated if the ADS can assess the user to be available to assume the role of the driver according to fallback user provisions in para. 4/6.2.2.1.6 a), and to renumber para. 4.2.2.3.4 as para. 4.2.2.3.3.1. The original text could be misinterpreted as requiring the ADS to initiate deactivation whenever requested by the user.

Proposal to insert provisions requiring the ADS to terminate the deactivation procedure and execute a fallback to an MRC if the user is not suitably engaged after the time available for transition has expired, to permit the ADS to terminate the deactivation procedure and resume its previous operating state in the case of user-initiated deactivation instead of a fallback to an MRC, and to require the user be promptly informed that the deactivation process has been terminated and the reason for termination.