The Automated Vehicles (Permits for Automated Passenger Services) Regulations 2026 and the impact on UK health and safety law
What has changed
These Regulations detail certain procedural and administrative matters to enable the permitting regime for automated passenger services in Part 5 of the Automated Vehicles Act 2024 (c. 10) to function. An automated passenger service is a service that consists of the carrying of passengers in a road vehicle that is designed or adapted to travel autonomously or is being used for a trial with the aim of developing vehicles that are so designed or adapted. These Regulations apply in relation to bus-like services in England, Wales and Scotland and taxi- and private hire vehicle-like services in England.
Who is affected
The Regulations apply to providers of automated passenger services across the described sectors, including operators of bus-like services in Great Britain and taxi or private hire vehicle services in England. Operators will need to navigate the new permitting regime to operate such services lawfully under UK health and safety law.
Key duties for employers and operators
- Secure and maintain an appropriate permit for the specific service type and operating area.
- Establish governance and competent oversight for autonomous vehicle operations.
- Ensure safety in design, development and operation of automated passenger services remains aligned with UK health and safety law.
- Review risk assessments and implement controls to mitigate hazards associated with autonomous vehicle operation and passenger transport.
- Engage with staff and workers to understand safety implications and reporting requirements.
- Ensure supplier and contractor arrangements reflect the new regime, including safety requirements for vehicles, software and data handling.
Why this matters
The new permitting regime creates formal oversight for automated passenger services, aiming to strengthen safety and accountability across the sector. For duty holders, this affects governance, risk management, compliance costs and the pace of deployment. By aligning with the new requirements, organisations can demonstrate regulatory compliance under UK health and safety law and support safe innovation.
Steps to achieve compliance
- Review governance structures and ensure there is a designated competent person for autonomous vehicle safety.
- Map existing policies to the new permit requirements and update risk assessments for autonomous passenger operations.
- Update operating procedures, safety management system, and training to cover permit requirements and reporting obligations.
- Engage with the regulator early to understand permit conditions, data reporting and inspection regimes.
- Assess contractor and supplier arrangements to ensure they meet the new safety standards and regulatory expectations.
- Consider implementing or aligning with ISO 45001 for systematic control of workplace risk and legal compliance.
For practical support, organisations may work with Synergos Consultancy on health and safety risk assessments and management system alignment:
ISO 45001 occupational health and safety management,
health and safety risk assessments,
Competent Person support.
Timely compliance with the new regime will help organisations manage risk and realise the benefits of safe innovation in automated passenger services.
