Proposal to add a new example and update text based on discussions by the OPI group aimed at finalizing the GID. The revised text adds that the ADS does not transit to a safe state in accordance with the manufacturers defined response as documented in the safety case, and removes provisions regarding the chosen stop location. The group agreed to further work in the next phase on situations where the chosen stop location could have contributed to a collision involving the ADS vehicle before it has moved from that location.

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. 8.1.5.1.(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.(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.(c) 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.(e) the description of the means/approaches to engage people within the organisation in the culture of safety.

Proposal to delete the requirement that competence is expected to be actively developed and maintained through structured training and insert that this point focuses on the existence and maintenance of SMS training plans to support competence for the SMS management in para. 8.1.6.1.(b).

Proposal to revise the guidance text in para. 8.1.8.1.(c) 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.

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 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.

Proposal to revise guidance text in para. 8.1.6.1.(d) to delete the statement that the intention is to ensure safety promotion contributes to ongoing learning and improvement, reinforcing the adaptive nature of the SMS, and insert revised text stating that this point focuses on continued evaluation contributing to ongoing learning so that the SMS remains effective, allowing an adaptive nature through modification and adaptation supported by safety recordkeeping.

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 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.

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 improve the interpretation of para. 8.1.6.1.(a) concerning verification that reactive and proactive practices for risk management are in place.

Proposal to improve the interpretation of para. 8.1.6.1.© concerning verification that the risk management activity includes risks from third parties.

Proposal to improve the interpretation of para. 8.1.6.1.(d) concerning verification that the risk management activity covers and is performed over the entire lifecycle.

Proposal to improve the list of examples of risk-management practices to support para. 8.1.6.1.

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.

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 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 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 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 amend para. 8.1.8.1.(a) to delete the provision that staff have the necessary knowledge and skills to perform their safety-related responsibilities and insert text stating that 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 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.

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 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 provision ensures that " and insert “This element focuses on” before “changes”, delete “systematically”, and insert "that " after “changes” in para. 8.1.7.1.(c) 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 revise the explanation of para; 8.1.7.1.(b) to explain that safety assurance includes the organization and also other involved parties.

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 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 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.

The 22nd ADS IWG session will be held in central Sydney, Australia, from 6-9 October. The meeting facility will be confirmed soon.

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 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.

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.

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 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 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 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 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 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 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 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 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.

These provisions require manufacturers to contact authorities in territories where features of the ADS can be active in advance of formally applying for approval. The intention is to make receiving authorities aware that an automated vehicle is destined for their territory. An ADS or feature whose ODD includes a geo-fence limiting operation to specific territories is clearly destined for just those territories. A manufacturer is not required to notify authorities in countries where the manufacturer does not intend to sell or operate the ADS or vehicles equipped with the ADS.

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 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 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. Proposal was not accepted by the ADS IWG session.

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.