Autonomous vehicles law and regulation in the United Kingdom

Yes, the primary legislation governing the operation of AVs in the UK is the Automated Vehicles Act 2024 (“AVA”). The AVA is intended to provide a legal framework for the safe deployment and use of AVs on public roads in Great Britain. It does this by introducing new concepts and principles to address novel issues for AVs that previous road traffic legislation in the UK did not cover and by amending existing legislation to remove legal obstacles and uncertainty around their application to AVs.

The AVA does not explicitly mention the different SAE levels. Instead, it applies to vehicles that are capable of “self-driving” i.e., they are designed or adapted with the intention that a feature of the vehicle will allow it to travel autonomously without human input for some or all of a journey.

Key provisions of the AVA include:

• New legal actors: The AVA establishes new legal actors who are responsible for meeting certain regulatory requirements under the AVA and are liable for driving offences and accidents when certain circumstances apply.  These are the authorised self-driving entity (ASDE), the user-in-charge (UiC), and the no-user-in-charge (NUiC) operator. The ASDE has general responsibility for ensuring that an authorised AV continues to satisfy the ‘self-driving test’ by virtue of its authorised AV features (see further on the self-driving test below). The UiC is the individual in the AV and in a position to operate the driving controls. The NUiC operator is responsible for overseeing AVs that operate without the need for a UiC.
• AV authorisation and the self-driving test: An AV must be authorised before it can be deployed on public roads in Great Britain. The authorisation regime applies whether the vehicle is fully autonomous or has discrete automated vehicle features (e.g., a self-parking mode). To achieve authorisation, the AV must: (a) satisfy the ‘self-driving test’, (b) achieve type approval, and (c) meet any other authorisation requirements that the Secretary of State may introduce as secondary regulations under the AVA. According to the AVA, a vehicle will satisfy the self-driving test if: “(a) it is designed or adapted with the intention that a feature of the vehicle will allow it to travel autonomously, and (b) it is capable of doing so, by means of that feature, safely and legally”. The AVA contains further provisions on how this test is to be understood and applied and anticipates that the Secretary of State will publish a “Statement of Safety Principles” containing further technical detail regarding the safety expectations for AVs. The AVA mandates that such principles must be framed with a view to securing that AVs will be as safe as, or safer than, that of “careful and competent human drivers” and that road safety will be better as a result of the use of AVs than it would otherwise be.
• Licensing and permitting scheme for NUiC operators and automated passenger services: The AVA creates a licensing and permitting scheme for NUiC operators that intend to use AVs to offer transportation services for passengers and/or goods without there being a human driver involved (e.g., robo-taxis). NUiC operators need to meet certain minimum requirements to be permitted to operate and are subject to ongoing obligations to share data with regulatory authorities in relation to safety and other matters.
• Marketing restrictions: The AVA introduces new offences which prohibit the use of misleading marketing that could confuse consumers about the autonomous capability of a vehicle.
• Enforcement and remedial powers: The Secretary of State is granted a range of powers to enforce compliance with the AVA, including the ability to issue compliance notices and redress notices to ASDEs and NUiC operators. The Secretary of State may also vary, suspend or withdraw an AV’s authorisation where an authorisation requirement is not met or has not been met, an AV has committed a traffic offence, or the AV no longer satisfies the self-driving test in respect of all authorised locations and circumstances. Monetary penalties can be imposed if a regulatory requirement is not met.

See our Law-Now article here for more details of the key implications of the AVA for the automotive sector.

The AVA is principally a framework piece of legislation that requires further regulations to be made on various technical and operational matters, such as vehicle approval, operator licensing, and incident investigation. As of August 2025, the government is in the process of consulting on these secondary regulations. The AVA is expected to be fully implemented by 2027

In the interim, the UK government is facilitating advanced AV trials pursuant to its Code of Practice for Automated Vehicle Trialling. This code sets out the government’s expectations for those wishing to conduct public trials of AV technologies and services in the UK.

Yes, the AVA provides a framework for how liability will be allocated if an AV commits a driving offence or is involved in an accident. It builds on the Automated and Electric Vehicles Act 2018 (“AEVA”), which established the general principle that insurers would be primarily responsible for compensating victims of accidents involving AVs.

In particular, the AVA provides for the following: 

• Immunity for AV users: The AVA protects users of AVs from criminal or civil liability for the actions of the AV when automated vehicle features are engaged, meaning that ultimate liability will likely sit with either the manufacturer or the operator of the vehicle. This immunity principle is subject to certain exceptions, for example, if an AV issues a “transition demand” requiring the user to regain control of the vehicle because it can no longer drive itself and the user fails to do so within the relevant transition period. Another example is where an automated vehicle feature is engaged in an unauthorised location or circumstances as a result of deliberate interference with the equipment of the vehicle.
• Insurers’ liability: Insurers of AVs are directly liable to those who suffer losses because of an accident caused by an AV when driving itself on a road or other public place. Insurers can reduce their outlay for contributory negligence of the claimant and/or recoup their outlay from those that are responsible for the accident.
• Data sharing and in-use regulation: Organisations are required to disclose safety data to support the allocation of liability to the responsible party or parties. There are sanctions which can be imposed for failing to disclose or falsifying data.

As the principles in the AVA are high-level, more detailed regulations are expected to be introduced in the near future to clarify how liability will be allocated between different actors in the AV ecosystem if an AV commits a driving offence or is involved in an accident, and the particular data sets that will be subject to the data sharing obligations.

There is no legislation in the UK that specifically regulates privacy and cybersecurity for AVs, although the AVA does contain certain requirements in relation to data collection and data sharing more generally. 

With regard to cybersecurity and privacy, general (sector-agnostic) legislation, such as the UK GDPR, will apply to the collection and use of personal data that is generated by or in connection with an AV. Other legislation, such as the Network and Information Systems Regulations 2018 (NIS Regulations) and the Product Security and Telecommunications Infrastructure Act 2022, may also apply depending on the circumstances.

As noted in response to Question 2 above, the AVA imposes certain data collection and data sharing obligations on businesses who are involved in the AV ecosystem with sanctions imposed on those who fail to comply. These obligations are intended to serve a number of purposes, including to enable the Secretary of State to monitor and assess the general performance of AVs in the UK and so that when an AV commits a driving offence or is involved in an accident, the necessary information is available to ascertain who is responsible. As of August 2025, it has not yet been determined what data sets businesses will be required to collect and share. This will be the subject of an upcoming public consultation. Interested stakeholders will be encouraged to respond to this with their views on what is appropriate. A fine balance will need to be achieved between the desire for transparency and the ability for businesses to protect their intellectual property and commercially sensitive information.

The UK government has an ambition to make the UK a world-leader in AV technology. It is therefore currently intensifying its efforts to implement the secondary regulations under the AVA so that AVs can be deployed on public roads as soon as possible.

As of August 2025, it has three public consultations in progress – covering: (a) the introduction of automated passenger services, (b) what will be classed as misleading marketing for the purposes of the AVA, and (c) the “Statement of Safety Principles”, which are mandated by the AVA.

These consultations are intended to build consumer trust and set clear safety standards, as well as give businesses confidence to invest in this rapidly growing sector in the UK. Further public consultations on other aspects of the AVA are expected to take place shortly. We therefore expect the legal landscape to continue to evolve over the coming months as the government introduces the necessary secondary regulations to give effect to the framework principles laid out in the AVA.