The issuance of an EU type approval for fully automated vehicles (Level 4) in small series production is possible for vehicles of classes M and N and for the following use cases according to Article 1 of Regulation (EU) 2022/1426:

a) Vehicles, including dual-mode vehicles, designed and build for the transportation of passengers or goods within a specified area.

b) Vehicles, including dual-mode vehicles, designed for the transport of passengers or goods or freight transport on a fixed route with fixed starting and ending points of a trip.

c) Dual-mode vehicles that have a fully automated drive mode for parking applications in predefined parking facilities.

Questions regarding the issuance of an EU type approval for motor vehicles with a fully automated driving function (level 4) in small series production should be directed to af@kba.de

To get in contact is not mandatory prior to the application, but is recommended for an early clarification of open questions.

If a meeting between the applicant and the KBA is desired prior to the application, the vehicle owner will typically present the vehicle and its fully automated driving function, followed by a discussion to clarify open questions between the manufacturer and the KBA. Depending on the complexity of the project, one to two hours should be planned for this meeting.

The application for an EU type approval must be submitted by the manufacturer.

A general application template for the granting of an EU type approval also for vehicles with a fully automated driving function in small series production can be downloaded from the download area. (Form 9.1 of the Information Sheet on Initial Assessment)

It is generally not possible to indicate the processing time for the granting of an EU type approval for vehicles with a fully automated driving function in small series production.

Process for granting an EU type approval for a vehicle with a fully automated driving function in small series productionPDF, 35KB, File does not meet accessibility standards

The application for EU type approval for vehicles with a fully automated driving function in small series production must be accompanied by the following additional documents, among others:

a) The Operating Manual for the fully automated driving function,

b) a general description of the fully automated driving function,

c) the safety concept,

d) a description of the handling of cybersecurity threats,

e) The functional description of the fully automated driving function.

The information document set out in Annex I to Regulation (EU) 2022/1426 is mandatory to be used.

In the event that the applicant does not yet have a completed initial assessment, this procedure must also be followed.

For the purpose of easy and secure transfer of large files, our server-based document exchange system E-Typ is available.

Detailed information on the E-type transmission procedure

Other already established document exchange systems can still be used.

According to Article 1 of Regulation (EU) 2022/1426, an EU type approval is intended exclusively for vehicles that operate within a fixed area or on a fixed route. Depending on the member state of the EU in which the operating area is located, the respective national regulations on the operating area must be observed.

For Germany, the following applies: The application for approval of the operating area within the meaning of § 1d (2) StVG of the vehicle with a fully automated driving function is submitted to the respective authorities responsible under state law, or on federal highways to Autobahn GmbH.

At the KBA, however, approval of an “abstract operating area” is granted when the EU type approval is issued, for which the technical suitability of the vehicle with a fully automated driving function in small series production must be proven with the application documents.

According to Article 1 of Regulation (EU) 2022/1426, an EU type approval is intended exclusively for vehicles that operate within a fixed area or on a fixed route. Depending on the member state of the EU in which the operating area is located, the respective national regulations on the operating area must be observed.

For Germany, the following applies: The EU type approval is the basis for a national operating area approval in accordance with § 9 of the “Verordnung zur Genehmigung und zum Betrieb von Kraftfahrzeugen mit autonomer Fahrfunktion in festgelegten Betriebsbereichen (AFGBV)”.

In the context of an EU type approval, the decision as to whether a technical supervisor is provided for in the vehicle concept is incumbent on the manufacturer of the fully automated driving vehicle.

For Germany, the following applies: For the approval of an operating area and thus for the operation of type-approved vehicles, the existence of a technical supervisor is mandatory, analogous to fully automated vehicles according to § 1e StVG.

This depends on the national regulations of the EU country in which the operating area is located.

For Germany, the following applies: Within the scope of the approval of an operating area for EU type-approved vehicles with a fully automated driving function in small series production, the requirements for the natural person appointed as technical supervisor specified in § 14 of the “Verordnung zur Genehmigung und zum Betrieb von Kraftfahrzeugen mit autonomer Fahrfunktion in festgelegten Betriebsbereichen (AFGBV)” apply analogously to fully automated vehicles pursuant to § 1e StVG with national operating approval.

The natural person appointed as technical supervisor may, with the consent of the vehicle owner, make use of other natural persons suitable in accordance with § 13 (2) AFGBV to fulfil his duties.

In principle, the assessment of the technical supervisor is the responsibility of the authority responsible for the approval of the operating area and thus not the responsibility of the KBA.

The granted type approval of fully automated vehicles corresponds to an EU type approval for vehicles in small series production according to Article 41 of Regulation (EU) 2018/858. This means that the number of units of a vehicle type registered, made available on the market or put into service annually in the European Union is limited to 1,500 units for fully automated vehicles of categories M and N.