Self-driving vehicle listing for a Great Britain pilot

Listing is a decision about a vehicle, not a whole service

A pilot applicant can complete months of engineering work and still face a basic legal question: has the vehicle been listed as capable of driving itself? For a current Great Britain pilot without a safety driver, the answer cannot be inferred from a demonstration, a successful closed-track test, a marketing description or a supplier's assertion. The Department for Transport's pilot applicant guidance requires an applicant to set out a case for listing under section 1 of the Automated and Electric Vehicles Act 2018. The Secretary of State makes the listing decision.

Listing identifies a motor vehicle that meets the statutory test. It does not by itself settle every other road-use question. A vehicle may also need a Vehicle Special Order for particular construction or use exemptions, a suitable approval and registration route, insurance that covers the pilot, and an automated passenger service permit if it will carry passengers under a service model requiring one. The applicant should track those decisions as separate records with separate owners. A positive assessment in one column cannot be copied into another.

The public government list said on 28 September 2026 that no self-driving vehicles were listed for use in Great Britain. This is a date-sensitive observation, not a prediction about a named applicant. Check that page again before release and before describing any deployment as listed. The list may change as pilot applications are decided. The presence or absence of a model on a public page also needs to be matched carefully to the actual vehicle and its registration record.

This guide owns the 2018 Act listing question. The pilot overview owns the full deployment sequence. The Vehicle Special Order question concerns the exemption application and conditions. This page does not offer a legal determination for a particular vehicle or promise that an applicant will be listed.

Read the two-part statutory test

Section 1 of the Automated and Electric Vehicles Act 2018 requires the Secretary of State to prepare and keep updated a list of motor vehicles that, in the Secretary of State's opinion, satisfy two conditions. They must be designed or adapted to be capable, in at least some circumstances or situations, of safely driving themselves. They must also be capable of lawful use while driving themselves, in at least some circumstances or situations, on roads or other public places in Great Britain. The government must publish the list and updates. The Act allows identification by type or another method, so a team should check precisely which variant or configuration a listing covers.

The first condition asks for more than a feature name. The applicant needs a credible claim about the vehicle, the automated function and the circumstances in which it can operate safely. It should define the road environment, speeds, weather, lighting, traffic interactions and fallback behaviour that form the proposed operating boundary. Evidence from a different software build or another vehicle variant may not show that the submitted configuration meets the test. The legal decision is the Secretary of State's opinion, informed by the application and assessment process. Internal confidence is not a substitute.

The second condition addresses lawful use. It is possible to build a system that performs well on a test route while the physical vehicle or its intended use conflicts with a road rule. The applicant must identify a route to lawful operation. An exemption through a Vehicle Special Order may be part of that route for a vehicle that cannot comply with a particular construction or use requirement. The DfT guidance says a vehicle that successfully demonstrates the requirements for a VSO will also be considered for listing. It does not say the VSO automatically creates the listing.

Section 8 of the 2018 Act explains that a vehicle is driving itself when it operates in a mode in which an individual is neither controlling it nor required to monitor it. This distinction matters where a vehicle has both driver assistance and an automated mode. A feature that needs continuous human supervision cannot be renamed a self-driving function through a sales deck. The evidence should describe when the person is expected to watch the road, what prompts an intervention and who actually controls motion in each mode.

Distinguish a no-driver pilot from a supervised trial

The DfT's pilot guidance covers operation without a safety driver. Its supervised trialling code covers trials in which a safety driver remains ready, able and willing to resume control. The pilot guidance says a deployment is unsuitable for its route if a safety driver must control the vehicle or monitor it with a view to immediate safety-critical intervention while the automated system is engaged. A team cannot solve this boundary by moving the safety driver into another seat or calling that person an observer.

Remote assistance needs closer analysis. The pilot guidance recognises that some remote assistance to the automated system may occur. It does not mean a remote person can become a continuous safety driver who watches every manoeuvre and intervenes immediately. The applicant should explain the exact commands a remote operator can give, whether they control motion, whether the vehicle can reach a safe state without an immediate response, and how frequently assistance is needed. If the real operating model depends on a human monitoring the vehicle with a view to immediate intervention, specialist reviewers should reconsider the pilot route and the listing claim.

A practical mode table is more useful than a broad assertion that the vehicle is autonomous. For each mode, record who controls steering and speed, who watches the road, when the mode can be engaged, how it exits and which hazards require a human response. Tie the table to test evidence. A fleet may include conventional driving, driver assistance, a supervised trial mode and a proposed no-driver mode. The legal label cannot be applied indiscriminately across them. The public listing guidance also warns that driver assistance features inside a self-driving vehicle are not automatically self-driving features.

Build a traceable case for the exact configuration

The pilot application should identify the vehicle make, model, design, modifications and automated driving system. A listing case must be traceable to the configuration that was assessed. Maintain a controlled baseline for vehicle identification, sensors, computing hardware, software release, maps, remote support and operating limits. If the applicant uses more than one prototype, show which evidence applies to each. A fleet-level statement can conceal differences that affect a safety claim.

Organise the safety argument around the two statutory questions. For the capability question, show the scenarios in which the vehicle is intended to drive itself, its performance evidence, its detection and response to foreseeable hazards, and the limits outside which it must not operate. For lawful use, map applicable road, vehicle and insurance requirements to the proposed use and any exemption sought. Identify unresolved points openly. The decision-maker needs to see what is established, what is assumed and what is still conditional.

Evidence might include structured track and road testing, simulations, incident and intervention records, system safety analysis, maintenance controls and the operator's response procedures. The DfT pilot guidance describes assessments of automated-driving capability, behavioural competencies, modelling, simulation and pre-deployment checks. These are assessment materials and expectations, not a fixed statutory checklist that guarantees listing. A qualified AV engineer should determine whether a test actually supports the claimed route and circumstances. A legal reviewer should determine whether the planned road use is lawful.

Avoid treating distance driven without an incident as a complete safety argument. A low-frequency hazard can remain untested. A pilot applicant should describe scenario selection, exposure, test coverage, known failures and the response when the vehicle leaves its defined conditions. If test evidence is from a different city, explain why the road design, traffic patterns, local rules and emergency arrangements remain relevant. If it is not relevant, collect new evidence rather than citing an impressive mileage figure.

The applicant should also establish responsibility for source records. A supplier may own model training and software updates while the pilot operator owns dispatch and maintenance. The listing case needs a route to evidence from both. Record the version, test date, reviewer and open limitations for each material item. This is an editorial evidence organisation method, not a claim that the Act prescribes a particular document-management platform.

The VSO and listing decisions can be connected but remain separate

A Vehicle Special Order under section 44 of the Road Traffic Act 1988 can permit use of a vehicle despite specified non-compliance with rules about construction, weight, equipment or use. The issued order may include vehicle identifiers, restrictions and conditions. The 2018 Act listing asks whether the vehicle can safely and lawfully drive itself in at least some circumstances. The two decisions can be assessed in one pilot programme, but they answer different questions.

For example, a shuttle without a conventional driver position may need a carefully specified exemption and safeguards for unattended operation. The VSO decision addresses the legal non-compliance and the conditions under which the vehicle may be used. The listing decision addresses self-driving capability and lawful self-driving use. A team should retain the issued order and evidence of listing separately. It should not label a VSO as an automated-vehicle certificate or assert that a recommendation for listing is the published listing itself.

An applicant can make the handoff clearer with a permission matrix. Put the exact vehicle or type in one column; its VSO and conditions in another; listing status in a third; approval, registration, insurance and passenger service permission in others. Note the authority, decision date, configuration and any expiry or change trigger. A coloured dashboard may help staff, but the underlying decision documents remain authoritative. If two records refer to different builds, stop the launch check and reconcile them.

The exemption case should be documented separately. The APS permit overview addresses the service permission. Neither topic should be rewritten into a second listing guide.

Registration follows listing, with its own keeper action

Vehicle registration records indicate whether a vehicle is capable of self-driving. The DfT pilot guidance says a vehicle can only be registered as capable of self-driving if it has been listed under the 2018 Act. Once listed, the registration details can be updated, and the registered keeper is responsible for notifying the Driver and Vehicle Licensing Agency of a change. Listing does not silently update every individual vehicle record. The keeper should establish which vehicle identification and registration details need changing and retain proof that the notification was made.

Vehicle approval is another question. Under ordinary circumstances registration requires vehicle-specific approval evidence. The pilot guidance points to type approval and individual vehicle approval routes, while warning that novel designs built solely for self-driving may not fit existing routes. It advises applicants to contact the Vehicle Certification Agency about the appropriate approval route. Do not promise that a listing decision is a type approval certificate or that an approval certificate alone proves listing.

The public list may identify a model or variant rather than every individual vehicle. That is why a fleet manager should match the published listing scope, the build record and the DVLA record before putting a particular vehicle into a pilot. A replacement sensor or new software release may make a vehicle different from the configuration considered during assessment. The right response is to check the listing basis and any VSO conditions with the relevant authorities, not to assume the public model name covers every future modification.

Where several organisations are involved, nominate who is the registered keeper, who holds the application evidence and who can request changes to the fleet record. A software supplier may know that a build changed but may have no power to update a DVLA record. A service operator may schedule the vehicle but not own its approval file. These handoffs should be settled before launch.

Insurance needs a precise use case

The 2018 Act also contains provisions about insurer liability when an accident is caused by an automated vehicle while driving itself. The DfT pilot guidance expects evidence of insurance that clearly specifies the pilot use case and duration and covers at least third-party liability and the liability addressed by section 2 of the 2018 Act. A conventional motor policy certificate should not simply be assumed to cover a no-driver deployment or every automated mode. The operator and insurer should agree the vehicle, operating area, service model and changes that need notification.

Listing helps identify the vehicles to which the 2018 Act framework applies. It does not answer every contractual coverage question. A qualified insurance adviser should check the policy wording, insured entities, vehicles, named uses and any exclusions. The pilot may include passenger carriage, remote support, testing outside public roads or supplier demonstrations. The policy schedule needs to reflect the real activity, not a generic statement that the vehicle is insured. A renewal or fleet substitution can create a gap even after a listing decision.

The applicant should preserve insurer correspondence, policy periods and the approved use description alongside its permissions register. If the automated function is disabled or its software materially changed, assess whether the insurer needs an update. Keep insurance review distinct from the engineering decision that a vehicle is safe. Both are necessary inputs to a launch decision, and neither substitutes for the other.

Passenger carriage adds a separate permission path

If the pilot involves a passenger service, an automated passenger service permit may be required. The DfT applicant guidance says the service applicant is expected to address this route in addition to vehicle listing and any VSO. Passenger permission can involve the type of service, area, operator standards and local consent. It does not establish that the vehicle meets the 2018 Act listing test.

A project should therefore separate three questions. Is the particular vehicle listed for self-driving use? Is it legally usable in its configuration and operating area, including any necessary order, approval, registration and insurance? Is the passenger service authorised under the applicable permit and consent route? A strong answer to the first question cannot carry a weak answer to the third. A service permit may cover an area or service pattern narrower than the vehicle's technical capability.

The organisation should make a single pre-launch reconciliation record after all decisions arrive. Include the precise vehicle or variant, current software, route, date, service type and permit holder. If one approval is still only an application, the deployment is not ready. If an authority imposes a condition, translate it into an operating control and test that the responsible organisation can carry it out. The APS permit overview owns the permit route; this page owns what the 2018 Act listing does within that wider set.

Manage changes after a positive decision

A listed vehicle may change through a new sensor, model update, braking component, map layer or remote-support workflow. The fact that a change improves average performance does not prove the original listing assessment still applies. Keep a change log that identifies the prior and proposed configuration, the safety claims affected, test evidence, any VSO notification condition, insurance implications and the authority contact or decision. An internal product-release approval is not a government decision.

Not every small update necessarily requires a new listing, but a generic article cannot decide the threshold for a particular deployment. The applicant should examine the published listing scope, its application evidence and any issued order. It should ask the relevant authority when a change may alter the basis on which the vehicle was assessed. This is especially important if the change enables new weather conditions, higher speed, another route or a different remote-assistance model. The change may affect lawful use even if the model name stays the same.

Monitor the public list and official guidance. The 2024 Automated Vehicles Act provides a broader future authorisation framework that is intended to replace the earlier listing mechanism when relevant provisions commence. As of this source audit, the pilot guidance uses 2018 Act listing for the current no-driver pilot and describes the remaining full framework as future. Do not present an application for a future authorisation as a current listing. Check commencement and transition rules before any page is released or revised.

A realistic listing review before launch

Consider a proposed no-driver shuttle on a short route with a depot at one end. The applicant has tested the automated system in dry daylight and can show safe stops at marked crossings. It now wants evening service and has changed the camera unit. The correct review begins with the exact circumstances the listing case covers. Was the vehicle assessed for dusk or darkness? Is the new camera part of the assessed configuration? Can the vehicle lawfully use the route without a person monitoring it? Does an issued VSO allow this build and time of day? Has the insurer agreed the extended use? Does the passenger permit cover evening service?

A service planner might say the published model is listed. That answer is too coarse. The vehicle engineer must compare the physical and software build with the assessment evidence. The legal lead must compare the actual order and listing scope. The keeper must confirm the registration update. The service holder must check its permit and local consent. The operator should keep the shuttle outside the changed service until the necessary reviews and authority decisions are complete. This is not a claim that the law prescribes one workflow; it is a practical way to prevent a gap between permissions and the real deployment.

A second example concerns a vehicle with a remote supervisor who watches a live feed and takes immediate control whenever a cyclist approaches. Calling the service driverless does not resolve the statutory meaning of driving itself. The applicant must explain whether an individual is controlling or needs to monitor the vehicle in its claimed automated mode. The pilot guidance may point that design back toward supervised trialling. Specialist legal and engineering assessment is needed before either description is used publicly.

Questions a buyer or partner should ask

These questions are for due diligence. They do not ask a software tool to declare the vehicle legally self-driving. A supplier should provide the authoritative decision and enough traceability to match it to the delivered vehicle. If a document is still a proposal, mark it as such. If the public list still shows no listed vehicles, verify any contrary claim directly with the authority rather than treating a slide deck as evidence.

Where Complys could support the handoff

A buyer may wish to keep vehicle identifiers, controlled decision documents, insurance dates, assigned review owners and change evidence together. Complys should be assessed against that workflow in a product demonstration. This guide does not claim that the platform decides listing eligibility, submits applications, connects to DVLA, reads vehicle telemetry or automatically detects whether a software update needs authority review. A product owner must verify any specific capability before publication.

In the demonstration, use one proposed vehicle variant and two individual vehicles. Ask whether the team can link a listing decision and an issued VSO to the correct configuration, mark one vehicle's registration notification pending, assign an insurance review and retrieve the earlier version after a software change. If the product cannot enforce a control, describe the external process instead. The AV software overview is a starting point for the broader buying conversation. The AV checker can orient a reader to possible regimes, but it cannot give a legal decision about a vehicle.

The immediate next step for an applicant is a two-part listing case tied to a defined vehicle and mode, alongside a separate register for VSO, approval, registration, insurance and passenger service permissions. Seek early engagement under current DfT guidance and have legal and technical specialists test the case. Recheck the public list and government guidance before calling a vehicle listed. A useful article can explain the questions and evidence, but only the competent authority can make the decision.