Subject: Support for the Adoption of Phase 3 of UN Regulation No. 171 at the March 2026 WP.29 Session

Dear Representatives of the European Commission and UNECE WP.29,

On behalf of the organisation representing electric-vehicle drivers and the broader e-mobility community across Europe, we respectfully submit this letter to express our strong support for the timely adoption of Phase 3 of UN Regulation No. 171 (Driver Control Assistance Systems) at the WP.29 session scheduled for March 2026.

1. Importance of Phase 3 for Road Safety and Regulatory Clarity

Phase 3 of UN R171 provides an essential update to the existing regulatory framework for supervised Level 2 driver-assistance systems. By enabling system-initiated manoeuvres in urban and peri-urban environments—while maintaining the fundamental requirement that the driver remains fully attentive, responsible, and in control—Phase 3 introduces clearer, more harmonised performance requirements without altering the established distinction between driver assistance and automated driving.

These systems already operate lawfully within the current Phase 1–2 framework and fall outside the scope of Regulation (EU) 2019/2144 on automated driving systems. Phase 3, therefore, represents a natural, evidence-based evolution rather than a regulatory shift.

2. Evidence of Safety Benefits

Supervised Level 2 systems in large-scale real-world use have demonstrated significant potential to reduce crash risk. For example, aggregated fleet data published by manufacturers indicate markedly lower crash frequencies when such systems are engaged, compared to both baseline vehicle operation and regional averages. Comparable supervised assistance systems from multiple manufacturers have shown consistent safety improvements across billions of kilometres travelled globally.

These findings support the European Union’s Vision Zero objectives and the EU Strategy for Sustainable and Smart Mobility, both of which emphasise data-driven approaches to reducing road fatalities.

3. Addressing Concerns Regarding Driver Attention and Misuse

We recognise that policymakers and national authorities have legitimate concerns regarding drivers’ attentiveness and the potential misuse of advanced assistance systems. To complement the harmonised technical requirements of Phase 3, we propose introducing a simple and effective safeguard that has already been successfully tested by some Member States:

• a one-time, digitally recorded driver acknowledgement, in which the user confirms that they:

• have been informed of the system’s operational design domain and limitations;

• understand that the vehicle is not capable of autonomous driving; and

• accept full responsibility for the safe operation of the vehicle at all times.

This measure reinforces existing legal obligations, enhances user awareness, and could be implemented by member states immediately and without regulatory delay.

4. The Need for Timely Adoption

Swift adoption of Phase 3 of UN R171 will provide regulatory certainty to manufacturers, Member States, and consumers. It will help maintain Europe’s leadership in safe, intelligent mobility technologies while ensuring high standards of road safety and consumer protection.

Moreover, advancing Phase 3 supports the EU’s broader climate and competitiveness objectives by enabling the safe deployment of technologies that enhance the driving experience, reduce energy consumption, and accelerate the transition to zero-emission mobility.

5. Request to the European Commission and UNECE Representatives

In light of the above, we respectfully ask the European Commission to:

• actively support and advocate for the adoption of Phase 3 of UN Regulation No. 171 at the March 2026 WP.29 session, and

• encourage EU Member States to introduce the proposed driver acknowledgement as a proportionate and effective interim measure that strengthens safety without impeding technological progress.

• We remain fully available for dialogue with the Commission, Member States, and UNECE experts and would welcome the opportunity to contribute further data or stakeholder perspectives.

I appreciate your consideration.

Yours faithfully,
Ignac Završnik

Slovenian e-Mobility Society