Introduction
Allianz Insurance recently made headlines for underwriting a fully driverless autonomous vehicle ("AV") service in Singapore. This follows a string of local AV news, including the Ministry of Transport's recent announcement of its intention to roll out AV shuttle services on public roads in Q4 2025, which should unlock more opportunities for private actors to enter the Singapore AV scene. Set out below is a summary of some of the key considerations in the application process for AV trial and use in Singapore.
Under Singapore law, the use of AVs on public roads is governed by the Road Traffic Act 1961, as amended by the Road Traffic (Amendment) Act 2017, and regulated in detail by the Road Traffic (Autonomous Motor Vehicles) Rules 2017 (the "AV Rules"). The AV Rules permit AV use on public roads on an "opt in" basis. Under the AV Rules, an application must be made to the Land Transport Authority ("LTA") for authorisation to operate AVs in Singapore. Any person or company can make an application.
Who will be the specified person?
The applicant must first choose a ‘specified person’. The specified person is the main point of contact who makes the application, produces documents and liaises with the LTA on the applicant's behalf. The specified person can be a natural person or body corporate. For simplicity, the applicant can be the specified person but where the AV project is small-scale, appointing a natural person may be a way to streamline correspondence with the LTA or reduce compliance burden.
The specified person is generally responsible for compliance with, and will therefore bear the consequences of any breach of, the AV Rules. For example, the specified person can be fined up to $2,000 if the authorised AV is not properly maintained.
Trial or use?
Next, the applicant must decide whether they are applying for authorisation to carry out AV trials or to use AVs in Singapore.
If they wish to carry out AV trials on Singapore roads, they must apply under Rule 5 of the AV Rules ("Rule 5 Application"). If they wish to use AVs in Singapore, an application is made under Rule 6 ("Rule 6 Application"). To make a Rule 5 Application, applicants must file Forms AV01, AV02 and AV03 with the LTA. If the applicant intends to progress the trial to driverless operations, Form AV04 must also be submitted as part of the application process. Very limited information has been made publicly available regarding the procedure for a Rule 6 Application at this stage. A small administrative fee is payable for each AV to be approved for trial and/or use.
Conditions and restrictions
If an application to carry out AV trials is approved, the LTA will issue: (i) written authorisation for the commencement of the trial of the AV to the specified person; and (ii) conditions and restrictions to be complied with during the trial of the AV ("the Requirements").
While the Requirements are technically tailored to each applicant on a case-by-case basis, common Requirements include the following:
- a safety driver to be seated in the AV at all times;
- a restricted zone in which the AV can be operated;
- AV to be equipped with a black box or data recorder;
- daily submission of data captured by the black box or data recorder to the LTA; and
- liability insurance coverage (if the specified person cannot obtain such insurance, they can alternatively deposit $1.5 million with the LTA).
Although historically applicants faced challenges obtaining appropriate liability insurance, news such as Allianz Insurance's venture into the AV sector suggests that AV liability insurance may become more accessible for prospective applicants.
Liability
There is not a specific liability framework for accidents involving autonomous vehicles in Singapore. In the absence of such a framework, existing legal principles — such as the tort of negligence — would apply in determining liability. However, these principles have yet to be tested in the AV context before the Singapore courts.
In the event of an AV-related incident, liability may rest with one or more parties, including the AV manufacturer, the vehicle owner, and/or the safety driver/operator. Recognising the legal uncertainty this creates, the LTA has mandated that all AV developers obtain third-party liability insurance as a condition for conducting AV trials under the AV Rules.
This insurance requirement plays a critical role in ensuring that victims of AV-related accidents are adequately compensated, regardless of whether fault can be clearly established. As highlighted in parliamentary debates, the government views this insurance mandate as a necessary safeguard to uphold public safety during AV trials. It mirrors the coverage required for human-driven vehicles and extends to losses or damages suffered by third parties — including bodily injury, death, or property damage — caused by the AV, its owner, or an authorised safety driver.
Importantly, the Ministry of Transport and LTA have acknowledged that, as Singapore moves towards fully autonomous transport, the liability framework will need to evolve, and there are ongoing consultations with legal experts and insurers aimed at developing a more robust and future-ready approach to assigning liability in cases involving autonomous driving systems.
What's next?
Prospective applicants should keep a close eye on the AV regulatory landscape in Singapore as recent developments indicate greater clarity and guidance is on the horizon. A steering committee consisting of members from across industry, academia and government has been formed to supervise near-term AV deployment in the city state and to coordinate initiatives, such as the development of AV-specific regulation. Singapore's AV landscape is one to watch as the nation seeks to position itself as a global leader in the mass deployment of autonomous driving technology.
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