Autonomous vehicle operator requirements
“Operator” isn’t one thing in the UK self-driving framework — there are several distinct roles, and which one you hold decides what you must do. This page is a router: it disambiguates the roles and points you to the right deep-dive, rather than repeating each. It is guidance, not a legal determination — confirm your role against the primary sources.
The roles at a glance
The framework creates two core operator-side roles — the ASDE (responsible for the vehicle’s self-driving behaviour) and the licensed NUIC operator (responsible for overseeing driverless operation) — and one deployment can involve both.[1],[4],[6] Where a service carries passengers, an APS permit is also needed — that is about the passenger service, separate from vehicle authorisation and operator licensing.[3],[1]
| Role | Responsible for | Status | Go to |
|---|---|---|---|
| ASDE | The vehicle’s self-driving behaviour (usually the manufacturer/ADS developer) | Full framework (2027) | ASDE guide |
| NUIC operator | Overseeing driverless vehicles in service (licensed) | Full framework (2027) | NUIC guide |
| APS permit holder | The passenger service (taxi/PHV- or bus-like) | In force now | APS permit |
| Manufacturer / provider | The vehicle/ADS — usually the ASDE, or supplies one | Full framework (2027) | See ASDE guide |
| Local authority / transport body | Consent & consultation on APS permits (not an operator) | In force now | See APS permit |
| User-in-charge | An individual able to take control (a person, not an org role) | Full framework (2027) | See below |
What applies now vs later
Operating today is done through the pilot scheme, not the Act’s operator licensing, which comes into force with the 2027 framework.[2] So even where a role below is “future”, the way to run now is the pilot — see pilot scheme compliance.
Which role are you?
| If you… | You are likely (confirm) |
|---|---|
| Develop or put forward the vehicle / automated driving system | ASDE |
| Oversee driverless vehicles running in service | NUIC operator |
| Carry passengers | APS permit holder (in addition to the above) |
| Only supply the vehicle/technology to another operator | Manufacturer/provider — likely the ASDE, not the operator |
| Are a council or transport body in the service area | Consent/consultation role, not an operator |
| Are the person in the vehicle able to take control | User-in-charge (a legal status, not an operator) |
A manufacturer or technology developer is usually the ASDE, or supplies the vehicle and ADS to one — not automatically the operator or permit holder.[1],[6] A user-in-charge is an individual able to take control while a self-driving feature is engaged — not an organisational role; they gain immunity from dynamic-driving offences while the feature is correctly engaged but keep duties such as insurance and reporting.[1],[4],[6] Local authorities and transport bodies are not operators but have a consent and consultation role in APS permitting.[5]
Not sure what applies to your operation?
Our free autonomous-vehicle compliance checker walks you through the questions that decide which regime, authorities and records apply, and points you to the primary sources to confirm against. It is guidance, not a legal determination.
Open the compliance checker →Where Complys fits
Whichever role you hold, the duties resolve into evidence someone may ask to see. Complys does not authorise or license anyone — it keeps each role’s records organised, in date and produced on demand. See the compliance software overview.
FAQs
We just want to run a self-driving service — which role are we?
It depends on what you do. If you develop or put forward the vehicle/automated driving system, you're likely the ASDE. If you oversee driverless vehicles in service, you're likely the NUIC operator. If you carry passengers, you also need an APS permit. Many operators sit across more than one role, and today all of it runs through the pilot scheme rather than the Act's licensing.
Is the person sitting in the vehicle an 'operator'?
No. A user-in-charge is an individual able to take control while a self-driving feature is engaged — a legal status for a person, not an organisational operator role. They gain immunity from dynamic-driving offences while the feature is correctly engaged but keep duties such as insurance and reporting.
Explore the framework
Primary sources
Each numbered source is the primary reference for the claims marked with it above. This is a developing area — always check the latest guidance.
- [1] Automated Vehicles Act 2024 — UK Parliament / The National Archives (UK, GB). Published 2024-05-20. Checked 2026-09-20.
- [2] Self-driving vehicle pilot scheme: information for applicants — Department for Transport (ENGLAND, WALES, SCOTLAND). Updated 2026-09-17. Checked 2026-09-20.
- [3] The Automated Vehicles (Permits for Automated Passenger Services) Regulations 2026 — UK Parliament / The National Archives (ENGLAND, WALES, SCOTLAND). Published 2026-04-23. Checked 2026-09-20.
- [4] Automated Vehicles Act 2024 — Explanatory Notes — UK Parliament / The National Archives (UK, GB). Published 2024-05-20. Checked 2026-09-24.
- [6] Automated Vehicles: joint report (Law Com No 404 / Scot Law Com No 258) — Law Commission of England and Wales & Scottish Law Commission (GB). Published 2022-01-25. Checked 2026-09-24.
This guidance is maintained by the Complys team and reviewed against the primary legislation and GOV.UK / DVSA / VCA sources listed above (last reviewed September 2026). It is general information, not legal advice, and this is a developing area — always confirm against the official sources, which show their own dates above.