Safety Principles draft

Annex C: Vehicle safety law and physical AI

October 18, 2026 Draft for public comment, version 0.1

U.S. vehicle standards are grouped by when they act: before, during and after a crash. This annex maps each group, and the reporting rules around them, to the articles of these Safety Principles.

A draft for public comment, not yet in force. Please read the status notice before relying on any part of it.

The mapping

U.S. vehicle ruleWhat it doesPhysical AI ruleArticles
FMVSS 100 series, crash avoidance: brakes (135), stability control (126), automatic emergency braking (127)Prevents the crashDetect people, then slow or stop before contact; stay stable9, 10
FMVSS 200 series, crashworthiness: occupant crash protection (208), interior impact (201)Limits injury during the crashLimit force and pressure on contact; soft, rounded, yielding surfaces13, 14
FMVSS 300 series, post-crash: electric-vehicle shock and electrolyte protection (305)Limits harm after the crashSafe state after an event; battery and electrical isolation; nobody left trapped11, 17
Lamps (FMVSS 108) and minimum sound for hybrid and electric vehicles (FMVSS 141)Makes presence and intent knownLight, sound and speech signals before and during motion7
Theft protection and rollaway prevention (FMVSS 114); accelerator control (FMVSS 124)Prevents unauthorized or unintended motionChecked identity before start; no motion on a fault8, 17
Manufacturer self-certification (49 CFR Part 567)The maker certifies each vehicle to the standardsThe maker certifies each unit to the Safety Principles before shipment34
Defect report within 5 working days and a free remedy (49 CFR 573.6)Gets unsafe vehicles fixed in the fieldDefect decision, fleet hold, free fix11, 21
Event data recorders (49 CFR Part 563)Standardizes the data captured before a crashA robot event recorder22
NHTSA Standing General OrderRequires crash reports when driving automation was engagedAn incident report whenever autonomy was engaged22
SAE J3016 levels, operational design domain, minimal risk conditionSays who is driving and where the system may operateAutonomy levels, operating envelope, safe state3, 9
State driver licensing and vehicle registrationTies each driver and vehicle to a recordEnrolled operators and identified units8, 19

FMVSS 127 has a September 2029 compliance date and was still under court challenge in April 2026, so it serves here as a model, not settled law.

Comments

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