Self-driving vehicle pilot scheme compliance
The pilot scheme is the only route to run a self-driving vehicle without a safety driver in Great Britain today. It is a deliberate bridge ahead of the Act’s full framework, and it comes with real conditions. This page explains the routes it uses, who does what, and the evidence you need — and is careful about the line between the pilot and the wider regime coming in 2027.
The routes: trialling, piloting, and the legal building blocks
The pilot scheme enables operating automated vehicles without a safety driver on GB roads; trialling with a safety driver who can take over is a separate route under its own code of practice.[2] Piloting is assembled from a few legal building blocks, and it helps to keep them distinct:
| Building block | What it does | Legal basis | Issued / granted by |
|---|---|---|---|
| Vehicle Special Order (VSO) | Allows a vehicle that doesn’t meet normal construction & use rules to operate, without a safety driver | s.44 Road Traffic Act 1988 | VCA (for the Secretary of State) |
| Vehicle listing | Places the vehicle on the official list of vehicles capable of safely driving themselves | Automated and Electric Vehicles Act 2018 | Secretary of State |
| APS permit | Needed in addition if the service carries passengers | Part 5, Automated Vehicles Act 2024 | DVSA |
A pilot runs under a Vehicle Special Order made under section 44 of the Road Traffic Act 1988, issued by the VCA on behalf of the Secretary of State.[2],[6],[4] The vehicle must also be on the official list of vehicles capable of safely driving themselves under the Automated and Electric Vehicles Act 2018.[2],[5] And if you carry passengers, you also need an automated passenger service permit under Part 5 of the Act.[2],[3] See the APS permit guide.
Who does what
Four bodies are involved, with distinct roles: DfT sets policy, the VCA issues Vehicle Special Orders, DVSA grants APS permits and carries out assessments, and CCAV supports pre-application engagement.[2],[4] Knowing which body owns which decision saves time when you apply.
The evidence the pilot expects
The pilot’s conditions almost all resolve into evidence you must hold and be able to produce. The specific figures below are the pilot scheme’s conditions — not general law:
| Requirement | What it means | The record |
|---|---|---|
| Safety case & SMS | A documented safety case and safety management system for the duration of the pilot | Safety case, SMS, review log |
| Critical incidents | Notified within 24 hours of the operator knowing | Incident log with timestamps |
| Cyber incidents | Reported within 72 hours; align to the NCSC Cyber Assessment Framework | Cyber incident log, CAF evidence |
| Maintenance records | Kept for at least 15 months, following DVSA principles | Maintenance & roadworthiness records |
| Competent people | Staff trained and competent to operate, oversee and respond | Training & competency evidence |
In detail: a documented safety case and safety management system are expected for the pilot’s duration;[2] critical safety incidents must be notified within 24 hours;[2] cyber incidents within 72 hours with NCSC CAF alignment;[2],[7] and maintenance records kept for at least 15 months.[2]
Applicant readiness checklist
| Before you apply, can you show… | Evidence |
|---|---|
| Organisational, operational and technical competence | Governance, roles, competency records |
| A documented safety case for your operational design domain | Safety case + supporting analysis |
| A working safety management system | SMS with owners and review dates |
| Incident detection, response and reporting to the timelines | Procedures + a live incident log |
| Cyber-security aligned to the NCSC CAF | CAF self-assessment, controls |
| Maintenance and roadworthiness kept and retained | Maintenance schedule + 15-month records |
| For passenger services: local consent and an APS permit | Consent evidence + permit |
What the pilot is — and is not
This is the point people most often get wrong. Taking part in the pilot is not authorisation under the Act’s full framework: it does not make you an ASDE or a licensed NUIC operator, and a Vehicle Special Order and vehicle listing are not the same as future authorisation.[2],[1] Nor does an APS permit authorise the vehicle — it covers the passenger service. Treat the pilot as a way to operate now and to build an evidence base that will carry across, not as a shortcut to the 2027 regime.
| Pilot (now) | Full framework (targeted 2027) |
|---|---|
| Operate under a VSO + listing (+ APS permit for passengers) | Authorised automated vehicle under the self-driving test |
| Operator meets pilot conditions | ASDE and licensed NUIC operator roles |
| Pilot incident/cyber/maintenance conditions | In-use regulatory scheme and enforcement |
Worked scenarios (confirm against the guidance)
| Your plan | Likely route (confirm) |
|---|---|
| Test with a safety driver ready to take over | Trialling code of practice — not the no-safety-driver pilot |
| Run a shuttle with no safety driver, no passengers yet | VSO + listing; pilot conditions apply |
| Run a bus-like passenger service, no safety driver (E/W/S) | VSO + listing + APS permit; bus franchising consent where relevant |
| Run a taxi/PHV-like service, no safety driver (England) | VSO + listing + APS permit; licensing-authority consent |
| Automated goods delivery, no passengers | VSO + listing; APS permit not engaged |
| “We’re in the pilot, so we’re AV Act authorised” | No — the pilot is not authorisation; confirm the distinction |
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
Complys does not grant a Vehicle Special Order, a vehicle listing or an APS permit, and it does not certify a deployment. It is the record-keeping system that holds the pilot’s evidence — safety case and SMS, incident and cyber logs to the 24- and 72-hour timelines, 15-month maintenance records, training and document control — organised, in date and produced on demand. See the compliance software overview.
FAQs
Can we run a self-driving vehicle without a safety driver in Great Britain today?
Yes, but only through the government's self-driving vehicle pilot scheme, and only if you meet its conditions. The pilot uses a Vehicle Special Order (and vehicle listing) to allow operation without a safety driver, plus an automated passenger service permit if you carry passengers. It is not the Act's full authorisation regime, which is targeted for 2027.
Is taking part in the pilot the same as being authorised under the Automated Vehicles Act?
No. The pilot is a bridge arrangement. It does not make you an Authorised Self-Driving Entity or a licensed no-user-in-charge operator, and a Vehicle Special Order and listing are not the same as future authorisation under the Act. Build your evidence base now so it will carry across, but don't describe pilot participation as authorisation.
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] Piloting of Self-Driving Vehicles — Vehicle Certification Agency (ENGLAND, WALES, SCOTLAND). Checked 2026-09-24.
- [5] Automated and Electric Vehicles Act 2018 — UK Parliament / The National Archives (GB). Published 2018-07-19. Checked 2026-09-24.
- [6] Road Traffic Act 1988, section 44 (authorisation of use on roads of special vehicles) — UK Parliament / The National Archives (GB). Published 1988-05-15. Checked 2026-09-24.
- [7] NCSC Cyber Assessment Framework (CAF) — National Cyber Security Centre (UK). 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.