On 4 June 2024 the Ministry of Industry and Information Technology and three other departments announced the consortia for the intelligent connected vehicle access and road pilot, advancing L3/L4 product access and road-use pilots. The pilot links product access, safety assessment, road testing, data recording and liability allocation. For vehicle manufacturers, component suppliers and algorithm service providers, understanding this chain matters more than memorising the list.
What the pilot means institutionally
The pilot is not a general opening. It tests institutional tools within specified consortia, areas and conditions. Selection means entering a denser regulatory process and gaining access to real-road data. A company should understand that pilot status and mass-production approval are not the same thing: the former validates capability and methods, the latter concerns market placement. Confusing the two leads to poor resource decisions.
Product access and safety assessment
L3/L4 product access requires a company to show that the system can safely perform the dynamic driving task within its defined operating conditions and has takeover, degradation and minimal-risk strategies. Safety assessment covers functional safety, safety of the intended functionality, cybersecurity and software-update management. The completeness of documents and test reports directly affects the review pace. Where external algorithm suppliers are involved, interface boundaries and responsibility allocation must also be shown clearly.
Data recording and cybersecurity
Higher-level automated driving generates large volumes of location, image and operational data. Data recording devices, event data records and log retention are the basis for accident investigation. Outbound data transfer, cross-border transmission and cloud deployment need separate assessment. On cybersecurity, over-the-air updates, vehicle-cloud communication and external interfaces are key attack surfaces and require a corresponding management system. Writing retention periods and access permissions into policy is more persuasive than explaining afterwards.
Liability and insurance
Under L3/L4 conditions, liability is allocated among the driver, the system and the manufacturer, and the specific rules are still being tested in the pilot. Contracts should define system capability boundaries, takeover-warning duties and data-provision duties; insurance should cover product liability and cybersecurity incidents. Clear liability clauses are more effective than arguing afterwards about who was driving. For software suppliers in the chain, liability caps and recourse arrangements should also be agreed in advance.
Software updates and recalls
L3/L4 capability depends on continuous updates, and software updates are themselves a safety matter to be managed. Scope, rollback mechanisms, user notification and regulatory reporting need defined processes. If an update changes the system’s capability boundary, it may trigger reassessment. Bringing OTA updates into the access and quality-management system, rather than treating them as after-sales service, is an area where gaps show early in a pilot. For vehicles already delivered, failed updates and degradation strategies must be designed in advance; otherwise a single faulty push can become a safety incident.
For ICV access and data arrangements, see our business licensing service and cybersecurity compliance service; for data recording and outbound transfer, see data compliance.
This article is based on the announcement of the intelligent connected vehicle access and road pilot consortia by the Ministry of Industry and Information Technology and three other departments on 4 June 2024, and on public information. It is for reference only and does not constitute legal advice.