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California requires manufacturers to report Level 2 ADAS crashes to DMV

Bill SB 572 creates a state reporting pipeline for serious crashes involving Level 2 driver‑assist systems, with public data posting, confidentiality carveouts, and steep per‑day penalties.

The Brief

SB 572 requires manufacturers of Level 2 advanced driver assistance systems (ADAS) to report qualifying crashes to the California Department of Motor Vehicles and gives the DMV authority to publish non‑proprietary, non‑PII crash data every other month. The statute ties the required report format and fields to the NHTSA Third Amended Standing General Order 2021‑01 as of June 16, 2025, and creates a civil penalty for failures to report.

The law only becomes operative if the specified NHTSA order is repealed and not replaced with a federal requirement consistent with that order, and it directs the DMV director to notify legislative transportation committee chairs of the director’s determination. The measure is designed to make ADAS‑involved serious crashes visible to regulators and the public while excluding trade secrets and personally identifying information from publication.

At a Glance

What It Does

The bill directs manufacturers to submit crash reports for Level 2 ADAS vehicles when the system was engaged around the crash and the incident meets serious‑injury or vulnerable‑road‑user criteria; reports must follow the content and format of the NHTSA standing order as of June 16, 2025. The DMV must post redacted crash data online bi‑monthly and share it with NHTSA and NTSB.

Who It Affects

Vehicle manufacturers, importers, and entities that develop or install Level 2 ADAS (including prototype and preproduction makers) must establish processes to detect crashes, assemble required data, and submit timely reports to the DMV. The DMV, NHTSA, NTSB, safety researchers, and public interest groups will consume the published dataset.

Why It Matters

SB 572 creates a state‑level ADAS crash reporting regime that mirrors a federal template, increasing transparency about serious incidents tied to partial automation. For manufacturers, it introduces ongoing operational and data‑handling obligations and exposure to daily civil penalties for noncompliance.

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What This Bill Actually Does

SB 572 targets Level 2 ADAS — defined by SAE J3016 — and makes the manufacturer responsible for reporting certain crashes to the California DMV. A report is required when a vehicle with Level 2 ADAS is involved in a crash on a public California road and the ADAS was engaged any time from 30 seconds before the crash began through its end.

The statute treats a “crash” broadly: it includes any physical impact that results or allegedly results in property damage, injury, or death, and it also covers situations where the vehicle is alleged to have contributed to another party’s impact through steering, braking, acceleration, or other performance.

A mandatory report must be submitted to the DMV no later than five calendar days after the manufacturer receives notice of a qualifying crash. The bill sets the seriousness thresholds that trigger reporting: a fatality, an individual transported to a hospital, an airbag deployment, or an impact with a vulnerable road user.

Reports must contain all applicable fields requested by the NHTSA Third Amended Standing General Order 2021‑01 as it existed on June 16, 2025, and must be submitted in that order’s format.If materially new or different information arrives about specific enumerated fields (VIN, engagement status, source, highest severity alleged, subject vehicle damage, subject vehicle precrash movement, air bag deployment status, data availability, and narrative), the manufacturer must provide an updated report by the 15th calendar day of the month following any month in which that new information was received. The DMV will publish the submitted crash data on its website every other month and simultaneously transmit the dataset to NHTSA and the NTSB.

When posting, the DMV must exclude proprietary business information and any personally identifying information; the statute also makes that excluded information confidential and not subject to disclosure under California’s Public Records Act.SB 572 attaches a monetary enforcement mechanism: a manufacturer that fails to report as required is liable for a civil penalty calculated per violation per day. Finally, the statute only becomes operable if the referenced NHTSA standing order is repealed and not replaced with a federal law or regulation that the DMV director finds consistent with that order; the director must notify the chairs of the Assembly and Senate transportation committees of the determination.

The Five Things You Need to Know

1

The bill requires a manufacturer to submit an initial crash report to the DMV within five calendar days after the manufacturer receives notice of a qualifying crash.

2

The ADAS engagement window that triggers reporting runs from 30 seconds immediately before the crash begins through the conclusion of the crash.

3

A manufacturer must send an updated report by the 15th calendar day of the month following any month in which materially new or different information arrives for specific fields, including VIN, engagement status, and data availability.

4

The DMV must exclude trade secrets and personally identifying information when it publishes data and must transmit the published dataset to both NHTSA and NTSB every other month.

5

The statute imposes a civil penalty for each reporting violation, charged per day of noncompliance.

Section-by-Section Breakdown

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38800(a)(1)(A)

Who must report and the triggering crash criteria

This subsection makes manufacturers of Level 2 ADAS vehicles responsible for reporting crashes that occur on California public roads when the ADAS was engaged in the 30‑second window before and through the crash. It ties reporting to four seriousness thresholds — death, hospital transport, airbag deployment, or impact with a vulnerable road user — and requires that the manufacturer have received notice of the crash. Practically, manufacturers will need monitoring and intake processes to determine when they have received reportable notice and whether the ADAS engagement and injury thresholds are met.

38800(a)(1)(B)–(C)

Report content and format tied to NHTSA order

The bill requires that submitted reports include all applicable information listed in the NHTSA Third Amended Standing General Order 2021‑01 as of June 16, 2025, and that the submission follow that order’s format. That linkage means California’s reporting fields and structure will track a specific federal template as frozen on a single date, which simplifies data standardization but also fixes the state requirement to the content of that order on that date unless the statute is amended.

38800(a)(2)

Obligation to provide updated reports when material information changes

Manufacturers must update prior submissions when they receive materially new or different information for enumerated fields; those updates are due by the 15th calendar day of the month following any calendar month in which the new information was received. The bill lists the fields that trigger this duty — such as VIN, engagement status, highest severity alleged, and data availability — meaning manufacturers must track investigative developments and maintain a process for monthly reconciliations and resubmissions.

4 more sections
38800(b)

DMV publishing, transmission, and confidentiality rules

The DMV must publish the crash data it receives on its website every other month and transmit the same data to NHTSA and NTSB on that cadence. When posting, the department must not disclose proprietary business information (including trade secrets) or any personally identifying information, and the statute makes that excluded information confidential and exempt from the California Public Records Act. The practical effect is a public, redacted dataset intended for transparency and analysis while shielding commercially sensitive material and personal privacy.

38800(c)

Civil penalties for failure to report

A manufacturer that fails to report as required is subject to a civil penalty assessed per violation per day. The bill sets a monetary consequence intended to incentivize timely reporting and create a clear enforcement lever for the department, so compliance systems will need to account for both reporting processes and the financial exposure tied to failures.

38800(d)

Definitions that frame coverage and scope

This subsection defines key terms used across the statute: ADAS, crash (including alleged contribution), Level 2 ADAS (SAE J3016), manufacturer (broadly covering developers, fabricators, importers, and operators), motor vehicle, motor vehicle equipment (including software), person, and vulnerable road user. Those definitions determine who is covered and how incidents are characterized, and the broad definitions (for example, of manufacturer and crash) extend the law’s reach to preproduction and prototype systems and to incidents that are alleged rather than conclusively established.

38800(e)

Operative condition and executive notification

The statute does not take effect automatically; it becomes operative only if the Third Amended Standing General Order 2021‑01 is repealed and not replaced by a federal statute or regulation consistent with that order, as determined by the DMV director. The director must inform the chairs of the Senate and Assembly transportation committees of that determination. This conditionality creates a state trigger that defers to the existence of a compatible federal framework and requires an administrative finding before statewide enforcement begins.

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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

  • Vulnerable road users and their advocates — the law increases public visibility into serious incidents involving pedestrians, cyclists, and others, which can inform advocacy and local safety improvements.
  • Regulators and safety investigators (DMV, NTSB, NHTSA) — they receive standardized, state‑level data aligned with a federal template, improving oversight, trend analysis, and cross‑agency coordination.
  • Researchers and public‑interest data users — a bi‑monthly, redacted dataset gives academics and NGOs regular access to ADAS incident data for independent study and policy work.
  • Municipal transportation planners — access to incident-level trends can support targeted infrastructure or signal timing changes where ADAS‑involved crashes cluster.

Who Bears the Cost

  • Vehicle manufacturers and importers — they must implement detection, intake, data extraction, and reporting workflows, and they face daily civil penalties for failures; small suppliers involved in preproduction prototypes may also need to support reporting obligations.
  • Corporate compliance and legal teams — companies will need to review reportable criteria, reconcile investigatory findings with required fields, and manage redaction claims for proprietary materials.
  • DMV operations — the department must take on data ingestion, redaction review, bi‑monthly publishing and transmission, and the administrative workload of assessing complaints and enforcing penalties unless additional resources are provided.
  • Insurers and fleet operators — they may see investigative and administrative burdens increase as manufacturers seek information, and they could face secondary impacts (e.g., record requests, subrogation data needs) driven by the new reporting regime.

Key Issues

The Core Tension

The central dilemma is between public safety transparency and the burdens of regulatory duplication: the bill widens public access to ADAS crash data to help detect safety problems, but doing so at the state level risks forcing manufacturers to navigate overlapping federal and state regimes, disclose commercially sensitive information, and face heavy daily penalties without a spelled‑out process for resolving disputes over proprietary content.

SB 572 balances transparency with confidentiality by tying public posting to an explicit exclusion for trade secrets and personally identifying information, but the statute does not create a clear procedural path for resolving disputes over what constitutes a proprietary field. Manufacturers and the DMV may clash over redaction scope, and the bill’s silence on a dispute resolution timeline could lead to delayed publication or litigation.

The operative condition — the statute only applies if the NHTSA order is repealed and not replaced with a consistent federal rule — transfers considerable power to federal developments and an administrative determination by the DMV director. That creates legal uncertainty for manufacturers planning compliance programs today.

Finally, the penalty structure is blunt: per‑violation, per‑day fines can accumulate rapidly, but the bill does not specify mitigation factors, notice procedures, or an administrative appeal framework, leaving key enforcement practices to future administrative rules or litigation.

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