On 17 January 2024 the Ministry of Industry and Information Technology, the Ministry of Public Security, the Ministry of Natural Resources, the Ministry of Housing and Urban-Rural Development and the Ministry of Transport issued the notice launching the intelligent connected vehicle “vehicle-road-cloud integration” application pilot. The pilot promotes networked cloud-control infrastructure, multi-scenario autonomous driving and higher on-board terminal penetration, and aims at a unified vehicle-road cooperation technical standard and test evaluation system. By the end of 2023 China had built 17 national test demonstration zones, 7 internet-of-vehicles pilot zones and 16 pilot cities for coordinated smart-city and intelligent connected vehicle development.
The pilot turns the vehicle into a shared problem of vehicle, road and cloud. For participating companies, compliance pressure is distributed across several lines.
The pilot builds a cloud-control base, not a road
Beyond single-vehicle intelligence, the pilot emphasises coordination between roadside equipment and cloud platforms. Infrastructure investors, platform operators, vehicle and component makers, and map and positioning providers appear in the same project. The more parties involved, the earlier the interfaces for data and liability must be written down. Who collects, who stores and who may provide data externally cannot wait until acceptance.
The first line: surveying and geographic information
Roadside sensing, high-precision maps and positioning data may all touch surveying and geographic information rules. Who collects, who holds and who provides the data externally must be assessed under the current qualification and map management rules. Handing point clouds, trajectories or road imagery to a third party for model training is not automatically permitted. Pilots often span several jurisdictions, so local requirements must be checked site by site.
Subcontracting and consortia are where problems surface. A qualified lead contractor does not make a subcontractor’s collection lawful, and consortium members collecting separately into one platform may create new holding relationships. Contracts should state the collecting entity, ownership of results, scope of use and liability for breach.
The second line: classification and important data
Vehicle-road-cloud integration generates more data types than a single vehicle: vehicle status, road environment, location trajectories, user information and platform logs. Classification is the starting point; identifying important data determines whether stricter security assessment and outbound transfer rules apply. Pilot cities and operators usually impose more detailed data requirements than ordinary projects, so interfaces should be reserved at the design stage.
The third line: accident liability and records
Liability in autonomous driving depends on data records. Which fields are recorded, for how long, who may retrieve them and how integrity is preserved affect both liability findings and personal information and trade secrets. Test data from the pilot must also be traceable. A recording mechanism that starts only after an accident has limited probative value.
Liability also turns on system state: whether automated driving was engaged, whether the driver took over, whether roadside equipment gave a valid warning and whether the cloud platform issued a command. Different parties must prove different facts. Writing recording duties into the project agreement is more reliable than retrieving logs afterwards.
Cybersecurity as the common base
Intrusion at any point in vehicle, road or cloud can affect operational safety. Graded protection, supply chain security and remote update management must be designed together with data rules. Remote updates are both a means of iteration and a point of entry; signing, rollback and authorisation of update packages need clear procedures.
For data processing and classification, see our data compliance service; for cybersecurity and graded protection of vehicle-road-cloud systems, see cybersecurity compliance.
This article is based on the notice launching the intelligent connected vehicle vehicle-road-cloud integration application pilot issued by MIIT and four other ministries on 17 January 2024, and on public information. It is for reference only and does not constitute legal advice.