Why mandated data sharing is critical to the success of automated vehicles

Introduction

The UK is on the cusp of one of the most significant changes to road transport in a generation. AVs have the potential to improve road safety, increase mobility, enhance productivity and transform the way people and goods move around the country.

The insurance industry supports that ambition. Insurers have worked constructively with government, vehicle manufacturers, technology providers and other stakeholders throughout the development of the UK's AV framework. The Automated and Electric Vehicles Act 2018 and the subsequent Automated Vehicles Act 2024 established an important principle: when an AV is driving itself, consumers should continue to benefit from straightforward motor insurance protection, with compensation paid quickly and efficiently following an incident.

However, there is a critical issue that still needs to be resolved if that promise is to be delivered in practice: mandated access to the right vehicle data, in a consistent and usable format.

For insurers, the priority is not open-ended access to every piece of information an AV may generate. In the vast majority of circumstances, the core data already collected by the vehicle’s Data Storage System for Automated Driving (DSSAD) should be sufficient to establish whether the vehicle was driving itself, understand the relevant sequence of events and enable insurers to fulfil their legal obligations. The key is ensuring that this data is available on a mandated basis, within clear timeframes and in a consistent format across manufacturers and systems.

“The fundamental question after a collision may become: who was driving, the human or the system?”

Building public confidence in automated vehicles

 Public trust will be essential to the successful adoption of AVs.

People are unlikely to embrace new technologies if they believe that collisions involving those technologies will be difficult to investigate or that responsibility cannot be determined when things go wrong.

Transparent and effective data-sharing arrangements can help address these concerns. They provide a route to understanding incidents objectively and ensuring accountability where appropriate.

This is not simply an issue for insurers. Regulators, investigators, fleet operators, manufacturers and policymakers all have an interest in ensuring that incidents can be properly understood and lessons can be identified where necessary.

A transparent data ecosystem can therefore contribute to broader public confidence in the safety and governance of AVs.

“Public trust depends on being able to understand what happened when things go wrong.”

The road ahead

The UK has established itself as one of the global leaders
in AV regulation. That leadership now needs to extend
beyond vehicle authorisation and deployment to ensuring
that the wider ecosystem can function effectively.

For insurers, mandated access to standardised DSSAD data remains a critical priority. The vehicles will already collect much of the information needed to determine whether the automated driving system was engaged and to support insurers in fulfilling their obligations in the vast majority of claims. What is needed is a clear legal framework that ensures this data is shared reliably, promptly and in a consistent format.

In a small number of very complex cases, further information may be required to understand the full technical circumstances of an incident. However, the starting point should be that DSSAD data provides the core dataset insurers need for effective claims handling, liability assessment and consumer protection.

AVs have the potential to reshape transport. But if they are to succeed at scale, every part of the system must work together. Mandated, standardised data sharing may not attract the same attention as the vehicles themselves, yet it will be one of the foundations on which public confidence, efficient claims resolution and the success of the wider AV ecosystem will depend.

Why mandated, consistent access is essential

Some may argue that data sharing can be addressed through commercial agreements or voluntary arrangements between manufacturers and insurers.

The challenge with this approach is that it would not provide the consistency, certainty or speed required for a functioning AV insurance market.

Different manufacturers may adopt different policies, use different technical standards or apply different processes for responding to requests. Data may be provided in different formats, on different timescales or subject to varying contractual conditions. For insurers, that fragmentation would make it harder to handle claims consistently, compare evidence across incidents and deliver predictable outcomes for customers.

From an insurance perspective, this creates uncertainty and operational complexity. More importantly, it risks generating disputes over data access precisely when rapid decisions are needed.

The industry’s view is that access to relevant DSSAD data should be mandated and standardised. Insurers need clear legal entitlement to the data required for claims handling, and they need that data to be provided in a consistent format so it can be interpreted and used efficiently. Without that certainty, the benefits of the UK’s automated vehicle framework risk being undermined by avoidable operational delays and disputes.

“Without mandated access, the benefits of the UK's automated vehicle framework risk being undermined by delays and disputes.”

The fundamental question: who was driving?

In conventional motor claims, insurers are generally focused on understanding what a driver did, how an incident occurred and who was responsible.

AVs introduce a new dimension to that assessment. A key question following an incident may be whether the vehicle was being controlled by a human driver or by an automated driving system. If the vehicle was driving itself, insurers may also need to understand how the automated system behaved, whether it was operating within its approved conditions and why certain decisions were made.

The answers to these questions are unlikely to be visible from physical evidence alone. In many cases, they will only be available through vehicle-generated data.

DSSAD data should provide the practical foundation for this assessment. It is designed to record key information about automated driving status and should allow insurers to confirm whether the automated driving system was engaged, whether it was operating within its authorised conditions and the timing of relevant events before, during and after an incident. In most claims, that should be enough to support liability assessment, claims handling and recovery action. There may be a small number of particularly complex cases where additional technical information is required, but this should be the exception rather than the starting point.

“Data sharing and privacy can co-exist.”

Data sharing and privacy can co-exist

Calls for mandated data sharing are sometimes portrayed as being in tension with privacy requirements. They do not need to be.

The ABI has consistently advocated for data-sharing arrangements that are proportionate, secure and supported by robust privacy safeguards. Insurers should only have access to data that is necessary for legitimate purposes such as claims investigation, liability assessment, fraud prevention and regulatory compliance.

Any framework should incorporate strong governance, clear accountability, secure transmission standards and compliance with data protection legislation.

The debate should therefore not be framed as a choice between privacy and access. It should be about creating an appropriate legal framework that delivers both.

“The priority is not access to every piece of data. It is access to the right data.”

Protecting consumers through faster claims resolution

At its heart, this debate is about consumer outcomes.

When a road traffic collision occurs, individuals want answers. They want repairs completed, injuries addressed and compensation resolved without unnecessary delays.

Where there is uncertainty over access to key evidence, those processes become harder. Liability investigations may take
longer, recovery actions may be delayed and disputes between parties may become more likely. 

A properly designed data-sharing framework can help overcome these challenges. Mandated access to DSSAD data in a consistent format would enable insurers to investigate incidents more effectively, make decisions more quickly and provide greater certainty to customers.

In turn, this supports one of the core objectives of the UK's AV framework: ensuring that injured parties are compensated promptly without becoming entangled in complex technical questions about software, vehicle systems and automated driving technologies.