Insurance sector urges detail on liability in self-driving vehicle rollout

The Department for Transport launched a consultation on 21 July 2025, seeking views on the proposed Automated Passenger Services (APS) permitting scheme – a statutory instrument under the Automated Vehicles (AV) Act 2024 – that will provide a foundation for the commercial deployment of self-driving passenger transport in the UK.

The consultation, which closes at 11:59pm on 28 September 2025, is set to inform how autonomous taxi, private hire and bus-style services will be approved, monitored and managed by local authorities. It will also seek feedback on access requirements for people with disabilities and older adults, as well as the mechanisms by which operator permits can be varied, suspended or withdrawn.

The APS permitting scheme is being introduced as part of a push to bring forward self-driving vehicle pilots to spring 2026 – a move intended to fast-track UK deployment of the technology ahead of the AV Act’s full implementation from the second half of 2027. These early trials will, for the first time, allow commercial passenger services to operate without a human safety driver.

Future of Roads minister Lilian Greenwood said self-driving vehicles presented “one of the most exciting opportunities to improve transport”, particularly for those unable to drive or living in rural areas. She added that the government was committed to “working with passengers and industry” to ensure the technology is “safe and accessible”.

Greenwood continued: “It will help stimulate innovation, create thousands of jobs, and drive investment to put more money in people’s pockets – all part of delivering our Plan for Change.”

The government estimates that self-driving vehicles could create 38,000 jobs and support an industry worth £42bn by 2035.

Insurance implications

With autonomous vehicles expected to reshape the transport risk landscape, insurers have welcomed the consultation – but cautioned that further detail on liability is urgently needed to unlock product development and enable fair pricing.

Marco Distefano, managing director at AXA Retail, said: “We believe the adoption of self-driving technology is the most exciting innovation for transport in decades. However, the introduction of automated vehicles must be accompanied by robust legislation, which is why we have consistently petitioned the government to put a framework in place.”

He explained that while the AV Act was “a significant step in the right direction”, it was the secondary legislation – including the APS permitting scheme – that would determine how risk is assessed, liability is defined and insurance is structured.

Distefano continued: “Liability will also change depending on the type of self-driving vehicle – whether it is user in charge or no user in charge. Either the driver or the vehicle manufacturer/software provider will be liable, depending on who is in control of the vehicle at the time an incident occurs. Data from the vehicle will be crucial to determine this.”

He added that current risk rating factors – such as age and postcode – may become less relevant as technology becomes the dominant factor in underwriting.

An ABI spokesperson told Insurance Times: “The insurance industry has long supported the development of automated vehicles, as they have the potential to significantly improve road safety and revolutionise our transport systems.

“Motor insurers continue to play a crucial role in the development of AV policy. Ensuring the safety of passengers and other road users must be the priority and we believe data-sharing between relevant stakeholders is vital to successful adoption.”

The APS permitting scheme consultation marks the third regulatory engagement from the government this year about self-driving vehicles, following earlier consultations on safety principles and the marketing of autonomous technology.

Distefano concluded: “We welcome meticulous attention to detail to ensure self-driving technology is safely implemented. However, until detailed legislation is in place, it is not possible for us to fully consider how insurance for self-driving vehicles will work in practice or how it will change how we assess and price risk.”