Automated Driving: Swiss Regulatory Framework

Self-driving vehicles have been in use for quite some time now. But how is automated driving actually regulated in Switzerland and what is permissible?

Where is automated driving regulated in Swiss law?

Last year, Switzerland introduced new regulations governing automated driving in several respects. On March 1, 2025, Title IIa: "Vehicles with an automation system" (Art. 25a – 25h) was added to the Road Traffic Act (RTA). At the same time, the Federal Council enacted the Ordinance on Automated Driving (OAD). You can read about what is meant by "automated driving" in our blog post.

The RTA defines vehicles with an automation system as those capable of permanently and comprehensively taking over the driving tasks of the driver, at least under certain conditions (Art. 25a RTA). This refers to SAE Levels 3–5 (conditional, highly automated, and fully automated vehicles). These vehicles can therefore steer, accelerate, and brake independently under predetermined conditions.

Further (mostly technical) details on automated driving can be found in the Ordinance on Technical Requirements for Road Vehicles (VTS), the Ordinance on the Approval of Persons and Vehicles for Road Traffic (VZV), and the Ordinance on the Type Approval of Road Vehicles (TGV).

What types of automated driving does Swiss law regulate?

The RTA (Art. 25a RTA) laid the foundations for regulating all levels of automation (i.e., up to SAE Level 5). However, only automated driving for parking or on certain routes, i.e., SAE Levels 3 and 4 (conditionally automated and highly automated), is currently permitted in Switzerland (Art. 25b and 25c RTA). Fully autonomous vehicles that can drive anywhere at any time and anywhere (SAE Level 5 – fully automated) can currently only be approved by FEDRO for trial purposes (Art. 25h RTA).

In the OAD, the Federal Council specifies three types of automated vehicles (Art. 2 OAD):

• Vehicles with takeover requests can manage various traffic situations automatically (independently). However, a driver must always be present ready to take control if prompted by the system (SAE Level 3). Alternatively the vehicle can bring itself into a safe state if the system reaches its limits (SAE Level 4). Vehicles with takeover requests can be used on the highway, for example (see Art. 23 VAF, "Highway Pilot").
• Vehicles with an automation system for parking can park independently, even without a driver (SAE Level 4). However, this is only permitted in appropriately approved parking areas (i.e., in designated parking garages) (see Art. 25 OAD). Monitoring by a driver is not required, in contrast to previous parking assistance systems, where the parking process still had to be monitored by a person (possibly outside the vehicle).
• Driverless vehicles can cover entire routes without a driver. Currently, this highly automated autonomous driving is only permitted on certain routes (SAE Level 4). The routes are determined by the canton of registration (Art. 22 and 25c RTA). Vehicles with only an automation system for parking are not considered driverless vehicles.

Therefore, Swiss law currently permits automated driving in the following specific three scenarios:

• Automated driving on the highway with a highway pilot
• Automated parking in designated parking garages
• Automated autonomous driving of driverless vehicles on canton-approved routes

According to FEDRO, as of February 2026 no vehicle has the necessary type approval for any of these three scenarios. However, this is expected to change in due course.

What requirements apply to the registration of automated vehicles?

Vehicles with an automation system must meet (additional) vehicle requirements that deviate from the general requirements in order to be approved, including:

• General requirements (Art. 3 OAD): The system must: be able to guide the vehicle in longitudinal and lateral directions; be able to be deactivated intuitively at any time; have accident avoidance functions and safeguards against unlawful interference by third parties; be able to handle all traffic scenarios in accordance with recognized international regulations.
• Requirements during operation (Art. 3 para. 2 and 3 OAD): The system must: control vehicle operation continuously, comprehensively, and reliably; comply with all relevant traffic rules (i.e., speed, distance, safety); detect technical malfunctions; if necessary, signal for human intervention with a sufficient time reserve.
• Driving mode memory (Art. 7 OAD): The automated vehicle must be equipped with a driving mode memory that records certain events (e.g., emergency maneuvers, collisions, technical malfunctions) and data elements (e.g., type of event, time stamp, position in the case of driverless vehicles).
• Manufacturer management systems (Art. 8 OAD): Vehicle manufacturers must hold valid certificates from a national type approval authority throughout the entire service life of the vehicle they support in order to maintain and improve data and operational safety. These are certificates for the management systems cybersecurity (UN Regulation No. 155), software updates (UN Regulation No. 156), and safety for driverless vehicles (Regulation (EU) 2022/1426).
• Type approval (Art. 11 ff. OAD): Vehicles with an automation system are subject to this type approval requirement. Type approval means the official confirmation that a type complies with the relevant technical requirements and is suitable for its intended use (Art. 2(b) TGV). Switzerland currently does not have its own type approval regulations for automation systems; instead, it recognizes the requirements of the EU and the UNECE (United Nations Economic Commission for Europe). Consequently, automated vehicles to be registered in Switzerland must have type approval from a foreign authority. FEDRO conducts a conformity check, i.e., a random inspection of a vehicle against the approved type. Manufacturers and importers of driverless vehicles must report safety-related incidents (i.e., accidents involving personal injury or significant property damage, or if an airbag has been deployed) to FEDRO.

Important: FEDRO may also declare new regulations for automation systems applicable to vehicles that have already been approved and placed on the market (e.g., if certain vehicle types have been affected by a hacker attack, see Art. 6 OAD).

What regulations govern the operation of automated vehicles?

If an automation system is used in a vehicle, drivers may be exempted from their obligation to control the vehicle and pay attention to road traffic (Art. 25b RTA). However, depending on the intended area of use (highway pilot, parking, or autonomous driving), other (additional) requirements must be met for the operation of automated vehicles:

• Instruction manual (Art. 9 f. OAD): Manufacturers of vehicles with an automation system must create an instruction manual for it. This must (also) specify the design-related area of application of the vehicle. The manual must be made available by the responsible persons (i.e., vehicle owners, parking garage operators, or anyone who allows third parties to use such a vehicle). Anyone with duties related to the vehicle's operation (including vehicle owners or those activating the automation system) must follow the instructions for use and operation.
• Vehicles with takeover request (Art. 22 f. OAD): When selling, renting, or leasing an automated vehicle, the contracting party must be informed about the proper use of the automation system. The person driving the vehicle may only let go of the steering wheel on the highway after successfully activating the highway pilot and must be able to resume control at any time.
• Vehicles with an automation system for parking (Art. 25 ff. OAD): The designated parking area must be separated from other traffic and have a specially marked handover location. The parking system may only be activated and deactivated (by the driver or the parking garage operator) at this location.
• Driverless vehicles (Art. 33 ff. OAD): Driverless vehicles must undergo a mandatory departure check before being put into service. Depending on the vehicle's self-diagnostic capabilities, it may be able to perform parts of the pre-departure check. Other aspects can be checked via remote communication, while others (e.g., checking the tires for damage) must be checked regularly by humans. The pre-departure check must include the tires, wheels, suspension, brakes, steering wheel, and lighting. During operation, driverless vehicles must be supervised by a human (operator) (see also Art. 25c RTA); this is a new role that did not previously exist in road traffic law. The operator monitors the driverless vehicle remotely via a communication link and can therefore monitor several vehicles at the same time. However, the operator does not perform any driving maneuvers themselves but rather issues appropriate instructions to the automation system as needed. Operators must (currently) be based in Switzerland, hold a valid driver's license for the relevant vehicle category (at least category B), and undergo special training. If a driverless vehicle is operated manually (by a vehicle occupant), that person is considered the driver. Owners of driverless vehicles must update and maintain the automation system in accordance with the manufacturer's specifications.

What to consider in an international context?

Automated driving (and its regulation) is, of course, developing rapidly not only in Switzerland but also internationally. Swiss regulations on the approval and use of automated vehicles are closely aligned with international standards. According to Art. 3a VTS, the EU directives, EU regulations, and UNECE regulations listed in Annex 2 of the VTS also constitute binding international regulations for Switzerland. These international requirements ensure the technical harmonization of road vehicles and promote road safety, environmental protection, and the free movement of goods between Switzerland and other countries.

The following international regulations are of particular interest for automated driving:

• Regulation (EU) 2022/1426 (in conjunction with Regulation (EU) 2019/2144 and Delegated Regulation (EU) 2022/2236) on "uniform procedures and technical specifications for the type approval of automated driving systems (ADS) in fully automated vehicles"
• UNECE Regulations concerning "Cybersecurity" (No. 155), "Software Updates" (No. 156), "Automated Lane Keeping Systems (Highway Traffic Jam Pilot)" (No. 157), "Driver Assistance Systems" (No. 171)
• International Convention of November 8, 1968, on Road Traffic concerning the use of vehicles in road traffic (SR 0.741.10) (in particular on the question of whether a driver must be present).

What does the regulation mean for "the taxi and the red light"?

In our fictional example (see our blog post), passenger Linda Punctual uses a self-driving taxi to reach her appointment.

The "taxi service" provided by Innovate Mobility AG qualifies as autonomous driverless driving (Art. 25c RTA and Art. 33 ff. OAD), as it is limited to use on specific routes. Innovate Mobility AG must have these routes approved by the canton of registration.

The control center of Innovate Mobility AG, where the "operator" is stationed, must be in Switzerland, as the operator's place of work is restricted to Switzerland.

Foreign type approval for the Sentinel Pod is permissible; FEDRO must conduct random conformity checks to ensure that individual Sentinel Pod vehicles comply with the type approval.

Under these conditions, Innovate Mobility AG's passenger transport with driverless Sentinel Pods is permissible under Switzerland's (new) automated driving regulations. There is therefore nothing to prevent the operation of the taxi service for Linda Punctual.

Our upcoming blog posts will examine the liability issues arising in connection with the accident and the data protection regulations applicable to automated driving.

Key Takeaways

Since March 2025, Switzerland has regulated automated (autonomous) driving in greater detail. Currently, three scenarios for "autonomous vehicles" are possible on Swiss roads:

• Automated driving on the highway with a highway pilot
• Automated parking in designated parking garages
• Automated autonomous driving of driverless vehicles on canton-approved routes

Vehicles with an automation system must meet specific, heightened requirements in accordance with internationally recognized standards, including a special type approval. At present, no vehicle is approved for this new automated operation in Switzerland.

Should such approval be granted in the future and an automated vehicle be operated in Switzerland, specific terms of use must be observed, particularly clear instructions and compliance with the user and operating manual. Driverless vehicles must be remotely monitored during the journey by an operator based in Switzerland.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.