Driverless Vehicles on British Roads: Operating Under the Self-Driving Pilot Scheme
In Short
The Situation: The United Kingdom has opened the road to driverless commercial pilots. On 31 March 2026, the Centre for Connected and Autonomous Vehicles ("CCAV") and the Department for Transport ("DfT") published guidance on the Self-Driving Vehicle Pilot Scheme, setting out the application process and the safety, operational and reporting requirements for deploying self-driving vehicles without a safety driver on roads in Great Britain (England, Wales and Scotland).
The Result: A multi-layered approvals pathway applies. Businesses seeking to participate must secure vehicle approval and registration, a Vehicle Special Order ("VSO") and listing under the Automated and Electric Vehicles Act 2018 ("AEVA 2018"), and, where passenger services are envisaged, an Automated Passenger Service ("APS") permit under part 5 of the Automated Vehicles Act 2024 ("AVA 2024").
Looking Ahead: Industry momentum is accelerating. With the UK government forecasting up to 38,000 new jobs and an industry worth £42 billion by 2035, and with a growing number of technology developers and transport operators positioning for early deployment, the Self-Driving Vehicle Pilot Scheme represents a significant milestone in the commercial rollout of automated driving systems in Great Britain.
Legislative Background and Industry Context
The self‑driving vehicle sector in Great Britain centres on vehicles equipped with an automated driving system ("ADS"), which refers to the vehicle hardware and software that are collectively capable of performing the entire dynamic driving task. The sector is underpinned by two principal statutes: The AEVA 2018 established the framework for listing vehicles as self-driving and for ensuring that appropriate motor insurance arrangements are in place. Building on the AEVA 2018, the AVA 2024 introduced a comprehensive legal framework with safety at its centre, covering vehicle authorisation, in-use regulation, incident investigation and the new APS permitting regime.
Following the UK government's decision in June 2025 to accelerate the rollout of commercial self-driving vehicle pilots by one year, the AVA 2024 is now expected to come fully into force beginning in late 2027. However, to support the Self‑Driving Vehicle Pilot Scheme, part 5 of the AVA 2024, which governs APS permits, is intended to be commenced ahead of the wider regime, alongside the Automated Vehicles (Permits for Automated Passenger Services) Regulations 2026 ("APS Regulations 2026"), both with effect from 15 May 2026. While the current guidance does not specify a fixed opening date for applications, it is anticipated that further updates may clarify the application timetable and related details. (Northern Ireland is excluded from the Self-Driving Vehicle Pilot Scheme, as it maintains its own distinct highway code and road-safety legislation.)
The Pilot Scheme: What It Is and What Businesses Need
Unlike the existing Code of Practice for Automated Vehicle Trialling, which requires a safety driver to be present at all times, the Self-Driving Vehicle Pilot Scheme provides the first lawful route for fully driverless commercial operation on roads in Great Britain, with corresponding rigorous regulatory requirements. In particular, the guidance anticipates substantial pre-application engagement with the Vehicle Certification Agency ("VCA"), the Driver and Vehicle Standards Agency ("DVSA"), and the CCAV.
All deployments are built around two core approval pathways. First, the vehicle must obtain regulatory approval, either through type approval or individual approval, and be registered for use on roads in Great Britain. Second, where a vehicle does not fully comply with applicable construction and use requirements, deployment under the Self-Driving Vehicle Pilot Scheme is expected to require a VSO under section 44 of the Road Traffic Act 1988, issued by the VCA. A vehicle granted a VSO may be considered for listing as self-driving under section 1 of the AEVA 2018.
Applications are assessed by the VCA and DVSA through a process that includes a pre-assessment of organisational and system capability; a review of the safety case; confirmatory testing of the ADS in real-world, track and simulated environments; and an on-site evaluation of operational management systems.
Reporting Obligations for Piloting
Operators must submit ongoing reports as required by the VSO, covering two main areas. The first concerns safety-relevant ADS occurrences such as collisions and traffic infractions, informed by annex 3 of the draft United Nations ADS regulation which is currently being developed. The second encompasses cybersecurity incidents both at vehicle level under UN Regulation 155 and at operator level.
ADS safety occurrences require notification within 24 hours, a short-term report within 30 days, and periodic reporting at intervals arranged on a case-by-case basis. Cybersecurity incidents follow a similar structure but with a 72-hour notification window. The DfT may accept alternative materially equivalent reporting where applicants make a reasoned case.
In addition, ADS data collection and reporting, including closed-circuit television footage, location data and other onboard information, may involve the processing of personal data and are therefore subject to the UK General Data Protection Regulation and the Data Protection Act 2018. Operators must comply with these requirements, including carrying out a data-protection impact assessment, as the Information Commissioner's Office considers the processing involved in the use of automated vehicles to be high risk. Where required by the DfT, operators may also need to enter into and comply with a data-sharing agreement governing the use and disclosure of non-personal data, with any non-compliance potentially leading to revocation of the VSO.
APS Permits
Where a pilot includes passenger-carrying services similar to taxi, private-hire vehicle operations or bus operations, the operator must also obtain an APS permit under part 5 of the AVA 2024. This disapplies existing passenger transport legislation that cannot be met by driverless vehicles. APS permits are granted by the DVSA, subject to the consent of the relevant local licensing authority or bus-franchising body, together with any necessary consultation of affected traffic authorities and emergency services. Applicants must demonstrate good repute, financial standing, operational competence and safety assurance, supported by detailed operational plans.
Under the current guidance, APS permits are expected to be granted for a maximum period of between 12 and 18 months during the initial pilot phase, ahead of the full implementation of the AVA 2024 (anticipated in late 2027). Once the AVA 2024 is fully implemented, APS permits are expected to be granted with a validity of up to five years under the APS Regulations 2026. Renewal applications must be submitted between six and two months prior to expiry.
Three Key Takeaways
- Engage early with regulators and local authorities. The guidance expressly expects significant pre-application engagement with the VCA, DVSA and CCAV before any formal application is submitted. For passenger-carrying services, the APS permit requires the consent of the relevant local licensing authority, meaning that businesses should assess at an early stage whether their proposed deployment is likely to require local consent, and that they should proactively engage with relevant authorities to demonstrate alignment with local transport-policy, accessibility and safeguarding requirements.
- Prepare for a substantial evidentiary and compliance burden. Compliance with a range of automated-vehicle regulatory frameworks sits at the core of the application process. Applicants must demonstrate alignment with applicable domestic and international standards and vehicle-approval regimes through a robust safety case, a safety management system and evidence of effective transport management, insurance, cybersecurity and incident response. Ongoing obligations also require operators to meet reporting and data-sharing requirements.
- Monitor a fast-moving regulatory landscape. The guidance is non-statutory and expressly subject to change. The APS Regulations 2026 came into force on 15 May 2026, with the remaining AVA 2024 provisions due beginning in late 2027. Regulators retain the power to suspend, amend or withdraw both VSOs and APS permits where safety concerns arise, and non-compliance may affect an applicant's repute in future applications.
