AB 2193 defines autonomous vehicles against SAE J3016 levels 3–5 and establishes a department-led regime for testing and deployment on California public roads. Manufacturers may test with a seated, licensed operator after obtaining a $5 million insurance, bond, or self-insurance instrument; wider deployment requires an approved DMV application that certifies a list of safety and performance features and ongoing insurance.
The bill mandates a crash data capture system that records at least 30 seconds of sensor data preserved for three years, allows ADS marker lamps beginning 2026, and empowers the Department of Motor Vehicles to write implementing regulations, set additional requirements (including limits on deployments and operator licensing), collect fees to recover costs, and require zero-emission status for certain later-model light autonomous vehicles as a condition of deployment permits starting in 2030 (rulemaking not to begin before 2027). It also specifies how traffic citations are issued depending on whether a person occupies the driver’s seat.
At a Glance
What It Does
Creates definitions and a DMV-controlled process for testing and permitting autonomous vehicles, requires manufacturers to certify safety features and maintain $5 million in insurance or equivalent, mandates on-board sensor-data capture and retention, authorizes ADS marker lamps, and conditions future deployment permits on zero-emission status for certain vehicles.
Who It Affects
Vehicle and AV-system manufacturers, fleet operators seeking deployment permits, insurers and sureties providing the $5M instruments, the California Department of Motor Vehicles (DMV) and California Highway Patrol (for consultation), and registered vehicle owners who may be ticketed for violations when no driver is present.
Why It Matters
This bill centralizes AV oversight at the DMV, creates firm technical and financial prerequisites for testing and deployment, introduces a long-term electrification condition for light AV deployments, and builds in sensor-data preservation that will affect litigation, privacy, and compliance.
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What This Bill Actually Does
AB 2193 starts by tying California’s definition of an autonomous vehicle to widely used SAE automation levels (Levels 3–5) and by excluding common driver-assist systems from that definition. That sets the gate for which technologies fall under the bill’s requirements.
The bill creates a two-track approach: limited testing with a seated, licensed human monitoring the vehicle, and a fuller approval process for operation on public roads without that limitation.
For testing with a human operator, manufacturers must supply evidence of financial responsibility—a $5 million insurance policy, bond, or proof of self-insurance—and ensure the human monitor is in the driver’s seat and ready to take over. For broader operation, manufacturers must file an application with the DMV certifying a set of concrete safety features: accessible engage/disengage controls, an in-cabin indicator when autonomy is active, an operator-alert system that either transfers control or brings the vehicle to a stop if the operator doesn’t respond, multiple physical ways for the operator to retake control, and conformity with federal and state motor vehicle safety standards.AB 2193 requires an independent, read-only data capture mechanism that records at least 30 seconds of autonomous-vehicle sensor data before a collision and preserves that data for three years.
The DMV will adopt implementing regulations that can add testing and equipment standards, limit aggregate deployments, create special registration and licensing rules, set procedures for notices of noncompliance, and establish revocation or suspension rules. The department must hold public hearings before adopting rules that allow vehicles to operate without a driver physically present.The bill also permits the use of ADS marker lamps starting January 1, 2026, and gives the DMV authority to assess application fees to recoup its administrative costs.
It includes a phased electrification element: beginning January 1, 2030, and to the extent allowed by federal law, light autonomous vehicles with model years 2031 and later must be zero-emission vehicles to operate under a deployment permit. Finally, AB 2193 clarifies enforcement: citations go to the registered owner when no person occupies the driver’s seat; when a person is present they generally receive the citation, with a narrow exception for permitted passenger-transport services where a customer in the driver’s seat who is not controlling the vehicle can shift liability to the registered owner.
The Five Things You Need to Know
Manufacturers must hold a $5 million insurance policy, surety bond, or proof of self-insurance for testing and ongoing operation as specified by DMV regulations.
The bill requires a read-only data recorder that captures at least 30 seconds of autonomous-vehicle sensor data prior to a collision and preserves that data for three years.
DMV may impose additional conditions for vehicles operating without a person in the driver’s seat, including requiring a driver to be present until safety is demonstrated.
Starting January 1, 2026, vehicles may display SAE J3134-compliant ADS marker lamps; beginning January 1, 2030, deployment permits for certain light autonomous vehicles (model year 2031+) may be limited to zero-emission vehicles.
If no person occupies the driver’s seat when a traffic violation occurs, the citation is issued to the registered owner; different rules apply when a person is seated or when the vehicle is a permitted passenger transport service.
Section-by-Section Breakdown
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Definitions and scope (SAE levels and exclusions)
This subsection anchors the bill to SAE J3016 Levels 3–5 to define which vehicles are treated as autonomous and explicitly excludes typical driver-assist features like AEB or lane-keep assist. For compliance teams, that matters because an aftermarket or OEM system must meet SAE criteria, not merely include advanced assists, to trigger permitting and data-retention obligations.
Limited public-road testing with seated, licensed operator
Manufacturers may conduct on-road testing with an operator in the driver’s seat provided they secure the required $5M financial instrument and the operator is licensed and ready to take control. This creates a short-term legal pathway for ‘safety-driver’ testing while preserving a clear financial backstop for incidents during such tests.
Application certifications for broader operation
The application must certify concrete technical features: easy engage/disengage controls, interior engagement indicators, an alert system that either forces operator takeover or executes a safe stop, multiple takeover mechanisms, and compliance with FMVSS and other standards. It also requires proof of prior testing and the continuing $5M coverage. This places the burden on manufacturers to demonstrate both design features and operational testing before receiving approval.
DMV rulemaking authority and public-process safeguards
The DMV gets broad regulatory authority: it will define evidence submissions, testing and equipment standards, notices of noncompliance, and may limit total deployments, create registration rules, or require new operator licenses. The DMV must consult CHP and may hold public hearings before allowing driverless operation, and cannot approve applications until 30 days after posting adopted regulations—giving stakeholders a structured opportunity to respond to implementation rules.
Federal preemption, disclosure, and cost recovery
The bill explicitly yields to NHTSA where federal safety rules conflict, and it requires manufacturers to disclose to purchasers what the autonomous system collects. The DMV may charge manufacturers application fees to recover its administrative costs, signaling that industry will finance the state’s oversight expenses rather than general funds.
ADS marker lamps authorized
AB 2193 permits the use of SAE J3134-compliant ADS marker lamps starting Jan 1, 2026, and references SAE chromaticity standards. That technical allowance gives manufacturers a standard visual indicator to signal ADS engagement, but it also creates a new compliance line around lamp standards and potential local lighting rules.
Zero-emission deployment requirement and citation rules
The bill conditions deployment permits for light AVs (GVWR < 8,501 lbs) of model year 2031+ on zero-emission status beginning Jan 1, 2030, subject to federal authorization, and delays rulemaking until at least 2027. It also establishes that registered owners receive citations when no person occupies the driver’s seat and clarifies citation procedures when a passenger in the driver’s seat is not controlling the vehicle—practical details that shift enforcement and liability considerations toward vehicle registration and permit holders.
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Explore Transportation in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Autonomous-technology manufacturers: They get a clear, device-level certification path and a predictable DMV process to move from supervised testing to permitted operation, which reduces legal uncertainty compared with ad hoc local rules.
- Fleet operators planning deployment: The permit framework and DMV oversight create a transparent pathway for scaling fleets if they can meet the technical, insurance, and data-retention requirements.
- DMV and state safety agencies: The bill consolidates oversight authority and fee recovery powers, allowing regulators to shape safety standards and recoup enforcement costs rather than relying on uncertain statutory crumbs.
- Zero-emission vehicle producers: The phased electrification requirement for certain future model years creates a market incentive for ZEV makers to integrate AV-ready platforms into their roadmaps.
- Insurers and sureties: The explicit $5M instrument requirement generates a definable market for underwriting AV testing and deployment risk, enabling product development and pricing strategies.
Who Bears the Cost
- Manufacturers and converters: They must field the $5M insurance or bond, install compliant sensor-data recorders, meet FMVSS and other certification requirements, and pay DMV fees—raising upfront deployment costs.
- DMV and CHP (implementation burden): The agencies must build regulatory capacity, run public hearings, consult experts, and enforce deployment limits and noncompliance notices, likely requiring new resources even if fees offset some costs.
- Owners of non-ZEV light AVs and fleet operators with legacy vehicles: Subject to the 2030/2031 rule, these stakeholders may face fleet replacement costs or restrictions on permits for later-model vehicles that are not zero-emission.
- Local law enforcement and court systems: Receiving mailed citations tied to registration instead of in-person stops changes processing patterns and may require new protocols for contesting and enforcing AV-related violations.
- Data controllers and privacy officers: Retaining three years of collision sensor data increases storage, access-control, and legal-hold responsibilities, with attendant technical and legal costs.
Key Issues
The Core Tension
The bill tries to reconcile two legitimate goals—protecting public safety through detailed technical and financial prerequisites, and fostering innovation by permitting on-road testing and an approval pathway—yet every safety device or financial requirement raises deployment costs and may slow commercial rollouts; choosing how strict to make regulations is fundamentally a trade-off between risk reduction and the pace of technological adoption.
AB 2193 establishes concrete safety and financial thresholds, but it leaves several implementation choices to regulation—creating both flexibility and uncertainty. The read-only sensor-data recorder requirement is precise about capture duration and retention, but silent on access rules, encryption, who may compel extraction, and how privacy statutes like the California Consumer Privacy Act intersect with mandatory preservation.
Similarly, the bill’s certification list requires conformance with FMVSS and other standards, yet does not specify testing protocols, performance metrics, or how the DMV will evaluate the sufficiency of manufacturer testing beyond a broad ‘‘satisfied’’ standard.
The phased zero-emission deployment requirement introduces a policy lever for decarbonization, yet it ties enforceability to federal law and defers rulemaking until 2027. That creates planning ambiguity for fleets and manufacturers regarding technology investments and model-year transitions.
Finally, routing citations to registered owners when no person is present simplifies enforcement but may shift liability away from system designers and operators toward owners in ways that could distort insurance markets and reduce incentives for technological improvements unless accompanying liability rules or fault standards are clarified in regulation or other law.
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