The amendments introduce specific provisions for autonomous vehicles, including competent authority approval before deregistration, the disapplication of ordinary driver authorisation requirements for fully autonomous vehicles, and the allocation of traffic law obligations where there is no human driver. They build on Saudi Arabia’s wider AV framework, including SASO’s Technical Regulations for Autonomous Vehicles, SHC 801 and controlled pilot operations under TGA supervision.
The framework is also developing alongside practical deployment. WeRide has announced pilot operations in Riyadh with Uber and Ai Driver, following completion of the TGA’s Regulatory Sandbox for AV Piloting and the issuance of an autonomous driving permit. The TGA has also reported that more than 1,000 users have benefited from autonomous vehicle services in Riyadh.
For businesses, the key takeaway is that the legal structure around an autonomous vehicle is becoming as important as the technology inside it. The question is no longer only whether the vehicle can be approved. It is whether the operating model around the vehicle is ready for the road.
Key changes introduced by the amendments
The amendments add autonomous vehicle-specific provisions to several articles of the Executive Regulations of the Traffic Law.
The amendments:
- require approval from the competent authority before an autonomous vehicle may be deregistered;
- disapply ordinary driving authorisation requirements for self-driving vehicles that operate without human intervention;
- provide that, where a fully autonomous vehicle operates without human intervention, the vehicle owner assumes certain obligations that would ordinarily apply to the driver, for example: complying with road signs, complying with official instructions and driving appropriately around emergency vehicles;
- apply the traffic accident framework to autonomous vehicles, including fully autonomous vehicles; and
- bring autonomous vehicles within the existing traffic accident liability framework, by making the owner of an autonomous vehicle liable for accidents as if it were the driver of the vehicle.
Two aspects are particularly important for market participants: regulatory visibility over autonomous vehicles throughout their lifecycle, and the allocation of responsibility where there is no human driver.
Regulatory visibility: why deregistration approval matters
One of the most important amendments is the requirement for competent authority approval before an autonomous vehicle may be deregistered. On its face, this may look like an administrative requirement. In practice, it is a significant regulatory control.
Autonomous vehicle regulation is not only about whether the vehicle is technically safe. It is also about whether the authority can identify the responsible party at each stage of the vehicle lifecycle. Who owns the vehicle? Who operates it? Who controls the autonomous driving system (ADS)? Who holds the operational data? Who responds to incidents? Who is accountable to the authority?
In a conventional vehicle model, these questions are usually easier to answer. In an autonomous vehicle deployment, responsibility can fragment quickly across a technology provider, vehicle manufacturer, fleet owner, platform provider, maintenance provider, and public authority counterpart.
The approval requirement therefore operates as a regulatory visibility control. It helps ensure that autonomous vehicles do not exit the competent authority’s line of sight without approval, particularly where the vehicle operates without a human driver.
This is also what we are seeing in Dubai. Dubai’s autonomous vehicle regime is built around licensing, approved operators and continuing oversight by the Roads and Transport Authority. Dubai Law No. 9 of 2023 also provides that ownership of an autonomous vehicle may not be transferred from one operator to another without prior approval from the RTA.
The legal mechanics in Saudi Arabia and Dubai are not identical. The Saudi amendment is framed around deregistration, while the Dubai provision is framed around transfer of ownership between operators. However, the policy direction is closely aligned. Autonomous vehicles should not operate, change hands or leave the regulated environment without the authority knowing who is responsible for them.
For businesses, the practical point is that ownership is no longer just an asset question. In an autonomous vehicle deployment, ownership can become a regulatory accountability question.
Owner liability: where responsibility sits without a human driver
The liability provisions are likely to be the most closely watched aspect of the amendments.
The amendments recognise that traditional driver authorisation rules do not apply neatly to fully autonomous vehicles. Where a self-driving vehicle operates without human intervention, there may be no human driver in the conventional sense to authorise.
However, the amendments do not leave a responsibility gap. Where a fully autonomous vehicle operates without human intervention, certain traffic law obligations are placed on the owner. This includes obligations relating to traffic rules, road signs, emergency vehicles, traffic accidents and liability.
It is noteworthy that the approach is to impose liability and obligations on owners of autonomous vehicles and to ignore the difference between a vehicle owner and the developer/provider of the ADS itself.
In the commercial operation of autonomous vehicles, the vehicles themselves are often owned by a fleet operator, rather than by the developer of the ADS. The Saudi approach will almost certainly lead to a different contractual allocation of liability being put in place, to avoid vehicle owners taking liability for issues caused by ADS providers.
That allocation is also interesting from a regional perspective. By contrast to the Saudi approach, in Dubai, the autonomous vehicle framework distinguishes between operators (who must own the autonomous vehicles) and agents (who distribute the vehicles). Whilst the operator is civilly liable for harm caused by autonomous vehicles, the agent is also required to hold a permit from the RTA and is responsible for the ADS.
That distinction matters. A structure that works in Dubai may not automatically work in Saudi Arabia, particularly where ownership, platform operation, technology control and on-ground services sit with different entities. For market participants, the practical point is that ownership, licensing, insurance, data access and contractual risk allocation need to be considered against the specific framework in each market.
