At the same time, the Department for Transport's wider call for evidence open from December 2025 to March 2026 covered safety, licensing, insurance, sanctions, cyber security and accessibility. DWF responded in detail; this briefing highlights the key points and practical implications.
Type approval: beyond technical compliance
Type approval is intended to ensure AVs are safe before deployment, with UK standards expected to align as far as possible with international and European regimes. Eighteen safety technologies are under consideration, including cyclist emergency braking and event data recorders.
DWF’s position is that technical compliance alone is insufficient. Type approval must also address cyber resilience and the realities of mixed traffic, otherwise vehicles may meet standards yet remain vulnerable in practice.
Transition demands: clarity, consistency and safety
A key issue is handover from automated driving to a “user in charge” (UIC). Current Automated Lane Keeping Systems (ALKS) standards allow ten seconds for transition, but the Automated Vehicles Act 2024 leaves the detail to secondary legislation and technical standards.
DWF supports a single, standardised transition period across AVs, set longer than the ALKS benchmark so users can safely disengage from non-driving tasks. AVs should also be able to manage emergencies without forcing transition where the user cannot respond safely.
There should also be interface standardisation, with consistent safety-critical audio and visual alerts across manufacturers to improve user recognition and reduce disputes about warnings and responsibility.
No user in charge operators: robust licensing expectations
Where there is no user in charge, responsibility will sit with No User in Charge Operators (NUICOs), which may supervise journeys and provide limited remote assistance.
Consideration should be given to NUICOs licensing requirements, including good repute, financial standing, organisational capability and operational competence.
Further safeguards are essential, including safety and accessibility compliance, crime prevention, incident response, transparent data handling and effective customer support. For passenger services, it highlights on-vehicle recording, prompt police notification and secure sharing of route and location data.
Insurance: data certainty and new risk models
The need is for clear, time-stamped vehicle data showing whether the vehicle was in autonomous mode at the time of an incident. Without that, liability will be challenging. Where the ADS caused the accident, insurers must be able to recover under the Automated and Electric Vehicles Act 2018, including product liability claims against manufacturers or others in the chain.
AV deployment will create new insurance challenges, especially for fleet-based NUICO operations. Motor cover is likely to sit alongside separate cyber insurance, reflecting risks such as cyber-attacks and system interference.
Sanctions: proportionate and effective enforcement
Licence suspension for serious or repeat breaches and financial penalties should be linked to turnover rather than fixed sums. Penalties should continue for as long as a breach persists, without an arbitrary cap on daily sanctions.
Incident investigation: specialist expertise required
We consider investigations should be led by people with an engineering background and specialist AV knowledge. Investigators must understand AV data, identify editing and secure access to data. They will require formal manufacturer training and refreshers as the technology develops.
Cyber security: resilience, monitoring and response
Cyber assurance must go beyond design standards and include ongoing monitoring, protection of control rooms and screening of staff. Communications between vehicles and operators should be continuous, backed by clear escalation procedures and rapid transfer of data after any detected breach.
Accessibility and the environment: ongoing oversight
DWF strongly supports AVs’ potential to improve accessibility for disabled and older users. On environmental impact, DWF recognises possible efficiency gains and reduced vehicle numbers, but stresses the need to monitor supply chains, battery disposal and the energy demands of supporting the digital infrastructure particularly data storage.
