By Peter Allchorne, Joanna Folan, Michael McCabe

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Published 24 July 2025

Overview

The Department for Transport has now published its consultation on automated passenger services (APS) pilots. This is the third consultation of an expected nineteen related to the regulations required to underpin the framework set out by the Automated Vehicles Act 2024 (the Act).

Our article on the first two consultations can be found here.

In June, the government announced that it is planning on fast-tracking commercial pilots of automated vehicles from spring 2026, what it is now calling APS.

Under Part 5 of the Act, the government has the power to permit APS, though consultation on the regulatory regime is required. This consultation is the next step in getting the APS pilot scheme up and running.

In bringing forward implementation of the APS permitting scheme, the government has three goals: providing clarity for organisations that wish to deploy a commercial service, as well as helping further inform it about the in-use challenges and benefits of automated passenger services.

It is expected that the government will use the data it collects from APS schemes to improve the regulatory framework for automated vehicles before full implementation of the Act, and we welcome this development.

Full implementation of the Act is still scheduled for the second half of 2027.

 

The consultation

The consultation seeks views on initial regulations made under the APS scheme (see below). The Department for Transport is also interested in receiving views on the practicalities of running the scheme in its initial phase and following implementation of the Act.

The consultation runs until 23:59 on 28 September 2025.

You can find the consultation here.

The draft regulations that accompany the consultation can be found here.

 

Our thoughts

This is a particularly important consultation that will help shape the regulatory framework for the very first automated vehicles on the UK's roads, including principles relating to data sharing and consequences to service providers for non-compliance.

Additionally, the pilot's performance is likely to have a strong impact on the viability of automated vehicles more widely in the next few years. Those looking to see the successful integration of automated vehicles into the UK's fleet would be advised to respond to this consultation.

DAC Beachcroft's Strategic Advisory team is well placed to work with you in drafting a response to this very important consultation. If we can assist you in any way, please get in touch.

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