Connected and autonomous vehicles ("CAVs") are expected to become a reality on roads across modern economies in the near future. In 2018, the EU estimated that, provided a sufficient regulatory and enabling framework is in place, CAVs could be available on a commercial basis by 2020, and commonplace by 2030. Estimates in the US are similar. On a financial level, forecasts have suggested that by 2050, the global CAVs industry could be worth upwards of $7 trillion,3 and that the CAV taxi market might be worth more than $2 trillion per year by 2030.4

It is widely recognised that before CAVs can become commonplace, they must first be adequately and appropriately regulated. Regulating CAVs remains a significant challenge for lawmakers, and specific regulations relating to CAVs are being introduced at divergent paces globally. While many countries are seeking to position themselves as leaders in the adoption of CAVs, the UK, Germany and the United States are widely regarded as being among the frontrunners with respect to the introduction of legislation and regulations in this area.

This article compares the emerging regulatory landscape in these three jurisdictions, identifying some key areas of commonality and divergence. A comparison table is included at the end for ease of reference.