On 4 May 2026, the Ministry of Transport (“MOT“) launched a public consultation on a legislative framework for autonomous vehicles (“AVs“) to govern AVs deployed on Singapore roads more holistically.
At present, the current road traffic framework is designed with human drivers in mind rather than AVs. The proposed AV legislation will clarify the safety regulations as well as the liability, insurance and enforcement regimes for the operation of AVs.
By way of background, the consultation utilises a technical classification for different levels of autonomy for a vehicle, ranging from level 0 to level 5, as defined by SAE International (formerly known as the Society of Automotive Engineers). As a starting point, the consultation focuses on the legal framework for AVs that do not require human control or immediate interventions for safe operations, i.e. SAE Level 4 (high automation) and SAE Level 5 (full automation).
The consultation highlights four critical areas of the proposed framework:
- Responsibility and accountability of key players involved in AV deployments
The proposed framework centres on a clear delineation of roles across key AV actors as the basis for attributing responsibility and liability. Four primary actors are identified: (i) the entity in charge of AV technology, (ii) fleet operators, (iii) onboard Safety Operators (“SOs“), and (iv) Remote Operators (“ROs“), each with conceptually distinct functions spanning development, operations, and intervention.
As AVs move towards full driverless operations, there should be a corresponding shift away from individual responsibility (e.g. drivers, SOs and ROs) towards corporate responsibility (e.g. entities developing or operating the AVs). This reflects the reduced level of human control over autonomous driving systems (“ADS“), and the corresponding increase in reliance on technology providers and operators to ensure safety and performance.
MOT proposes a two-tier regulatory structure distinguishing between:
- Research and development (R&D) or testing phase operations. During this phase, an SO will often be deployed onboard to serve as a safeguard. If the system prompts the SO to take over but the SO’s action or inaction causes an accident, the SO would be subject to prevailing road traffic offences.
- Full commercial deployment. The different actors will have stipulated responsibilities, and non-compliance may result in suspension or revocation of their licences.
- Compensation and insurance
In designing the role of AV insurance, MOT emphasised key objectives such as timely compensation for victims, keeping premiums affordable, and covering new risks like cyber attacks on vehicles.
Currently, AVs operating under the regulatory sandbox are subject to Singapore’s fault-based motor insurance regime. In the event of accidents, insurance will pay out according to the State Courts’ Motor Accident Guide or the Barometer of Liability Agreement (BOLA). However, the introduction of AVs raises complexities, particularly where fault attribution may be delayed or contested.
MOT seeks comments on three possible options to achieve timely compensation, namely:
| Option A (fault-based) | Option B (fault-based) | Option C (no-fault) | |||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Payout mechanism | Similar to status quo, but requires AV insurance to pay out within a prescribed time if undisputed | AV insurance pays out in full if AV caused accident, and subsequently recovers from other at-fault parties | AV insurance always pays out and does not recover downstream | ||||||||||
| Limitation/downside | Risk of drawn-out court proceedings for disputed cases | Subsequent recovery or subrogation may be difficult, potentially leading to higher premiums | High risk of moral hazards and perverse incentives, leading to exorbitant premiums or AVs becoming uninsurable | ||||||||||
MOT is also considering alternative AV insurance structures, especially for fleet-based deployment. Examples include comprehensive corporate insurance, or “self-insurance” for larger players.
- Data and cybersecurity management
Clear data and cybersecurity management frameworks are key to ensuring safety and natural justice outcomes, which are crucial to fostering public trust and acceptance in AVs. At the same time, personal data protection, commercial interests and national security considerations must be taken into account.
- Data management: MOT proposes regulations on the use and sharing of data generated and collected by AVs and AV operators, to safeguard personal privacy and national security. It also looks to obtain specified datasets from AV fleet operators and/or AV developers to ensure safety and legal compliance, facilitate incident management and investigations, and inform transport planning.
- Cybersecurity: Cybersecurity requirements under consideration include not only software update management systems, but also testing requirements on sensors and the ADS. Possible standards include UN R155 (Cybersecurity), UN R156 (Software Updates), ISO 21448 (Safety of the Intended Functionality) and ISO 26262 (Functional Safety).
- Advanced Driver Assistance Systems and Conditional Automation
This chapter of the consultation addresses SAE Level 3 vehicles with conditional automation. Such vehicles can handle driving tasks autonomously under specific conditions, but the human drivers must take over when requested. When active, the human driver is legally allowed to disengage from the actual driving task.
This shift necessitates a way to address liability that arises during the transition of control. The takeover transition period (i.e. the window between a clear “Request to Intervene” from the system and the human taking over control) is key.
MOT seeks views on where the liability should lie if accidents take place during this period.
Click on the following links for more information (available on the MOT website at www.mot.gov.sg):
- MOT Press Release titled “Launch of Public Consultation on Singapore’s Legislative Framework for Autonomous Vehicles”
- Consultation Paper on the Regulatory and Legal Framework for Autonomous Vehicles (AV) in Singapore
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