The bill directs the National Highway Traffic Safety Administration (NHTSA) to prescribe regulations requiring covered manufacturers and operators to submit monthly, machine-readable reports about autonomous driving systems (ADS) and Level 2 Advanced Driver Assistance Systems (ADAS). Required content ranges from disaggregated miles traveled to detailed records of collisions involving vulnerable road users and so-called “unplanned stoppage events,” with specific vehicle identifiers, geolocation, environmental context, and timing metrics.
The measure makes submitted data public and establishes short, statutory timeframes for rulemaking and public posting while carving out a limited, defined role for Level 2 ADAS data. It also creates a 10-year review point at which NHTSA may rescind or narrow reporting obligations, raising questions about trade-offs between public transparency, commercial confidentiality, and operational burdens for covered entities.
At a Glance
What It Does
The bill requires NHTSA—within 90 days of enactment—to adopt rules forcing each covered entity to deliver monthly datasets that include disaggregated miles driven by make/model/software, incidents causing injury to vulnerable road users or other vehicles, and detailed reports on unplanned stoppage events (VIN/license plate, lat/long, road type, environmental factors, interventions, and event duration). NHTSA must publish the submissions in machine-readable form within 120 days of enactment.
Who It Affects
Entities defined by NHTSA’s Third Amended Standing General Order 2021-01—manufacturers and operators deploying ADS or Level 2 ADAS—will be directly regulated. Researchers, state and local transportation agencies, insurers, and safety advocates will gain access to monthly operational data.
Why It Matters
The law would create a recurring, standardized feed of operational safety data from production and test fleets—potentially enabling comparative oversight, independent research, and faster identification of recurring safety patterns. At the same time, it formalizes data elements and timing that could become a de facto industry reporting standard.
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What This Bill Actually Does
The AV Safety Data Act tasks NHTSA with concrete rulemaking and public disclosure duties aimed at improving incident visibility for vehicles equipped with Automated Driving Systems and Level 2 ADAS. Within 90 days of enactment NHTSA must issue regulations that compel each covered entity—per the agency’s Third Amended Standing General Order 2021-01—to submit two things: the data elements already required by that Order, and a separate monthly report covering the prior month’s operations.
The monthly report must break out miles traveled by make, model, model year, major software version, road type, location down to county, and whether a human occupant was present.
Beyond mileage, the bill forces covered entities to report collisions that cause injury to vulnerable road users or occupants of other vehicles and to file standardized reports on any “unplanned stoppage event.” The stoppage report is highly granular: it must include plate and VIN, precise time and lat/long, a description of the event, environmental context, whether law enforcement or first responders were involved, the event’s impact on people and traffic, how it was resolved, any intervention by the covered entity, and timing data measuring from event start to resolution and to any intervention.To limit intrusion into driver privacy and reduce scope creep for lower-level systems, Level 2 ADAS data can be submitted only if it was captured while the system was engaged or during the 30 seconds before an unplanned stoppage, and the submission must exclude personally identifiable information about the human driver. The bill also mandates that NHTSA post all submissions in machine-readable datasets on its website beginning 120 days after enactment, making operational safety data accessible to the public and stakeholders.Finally, the Act includes a built-in review mechanism: not earlier than 10 years after enactment NHTSA may rescind or narrow the regulations—or amend them at any time consistent with statutory requirements.
The statute defines core terms by reference to NHTSA’s June 16, 2025 Third Amended Standing General Order 2021-01 and specifies what counts as an unplanned stoppage and a vulnerable road user, anchoring the new duties to existing agency definitions.
The Five Things You Need to Know
NHTSA must promulgate regulations within 90 days of enactment requiring covered entities to submit monthly operational reports and the data elements in the Third Amended Standing General Order 2021-01.
Monthly reports must disaggregate miles driven by make, model, model year, major software version, road type, State and county, and whether an occupant was present.
An unplanned stoppage report must include VIN and license plate, exact lat/long, time stamps, environmental context, law-enforcement involvement, impact on persons/traffic, resolution, any operator intervention, and event-duration timing in seconds.
Level 2 ADAS data is admissible only if captured while the system was engaged or during the 30 seconds before an unplanned stoppage and must not contain personally identifiable information about the driver.
NHTSA must publish all submitted information as machine-readable datasets no later than 120 days after enactment; the agency may rescind or narrow the regulations beginning 10 years after enactment.
Section-by-Section Breakdown
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Mandatory reporting and monthly dataset requirements
This subsection is the operative reporting mandate. It directs NHTSA to require each covered entity to submit the information already required under the Third Amended Standing General Order 2021-01 and a separate monthly report with specific fields. Practically, covered entities must operationalize automated data exports that capture fleet-level mileage breakdowns and incident-level narratives and metadata on collisions and unplanned stoppages. The breadth of required fields (from software version to county-level location) means vendors must align telemetry, recordkeeping, and legal review to ensure accuracy and consistency.
Limits on Level 2 ADAS data submission
Congress narrows the flow of data from Level 2 systems: only telemetry collected while the system was engaged or during the 30 seconds before an unplanned stoppage may be submitted, and driver-identifying information must be excluded. This creates a temporal and privacy boundary intended to distinguish semi-automated driver-assist systems from higher-level ADS operations, but it also requires covered entities to tag data with system engagement state and to implement de-identification processes that reliably strip PII before submission.
Public release in machine-readable format
NHTSA must post all submissions to its website in machine-readable datasets starting 120 days after enactment. That requirement transforms these reports from internal regulatory filings into publicly consumable data feeds suitable for researchers, journalists, and third-party auditors. It raises practical questions about data formats, update cadence, access controls for large datasets, and how NHTSA will present aggregated versus raw records while balancing transparency and privacy.
Ten-year review and regulatory flexibility
The statute permits NHTSA—no earlier than 10 years after enactment—to rescind or reduce the reporting frequency or scope. It also clarifies the agency may amend the rules at any time consistent with the statute. The 10-year marker creates a hard point for legislative or regulatory re-evaluation but does not impose interim review requirements, potentially locking in operational expectations for a decade unless the agency proactively revises them.
Definitions and incorporation of NHTSA’s Order
Congress anchors key terms—'covered entity,' 'covered vehicle,' 'unplanned stoppage event'—to NHTSA’s Third Amended Standing General Order 2021-01 and to existing federal definitions (for example, vulnerable road user via 23 U.S.C. §148(a)). That approach imports NHTSA’s operational definitions into the statute but can also freeze a cross-reference to a specific Order effective June 16, 2025, making future definitional changes dependent on NHTSA’s regulatory processes.
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Who Benefits
- Vulnerable road users and other road users: The law directs standardized incident reporting on collisions that injure pedestrians, cyclists, and occupants of other vehicles, increasing the likelihood of pattern detection and targeted safety interventions.
- Researchers and public-interest analysts: Machine-readable monthly datasets provide a recurring, standardized feed for independent analysis, enabling longitudinal studies of safety trends by make/model, software version, location, and road type.
- State and local transportation planners: County- and road-type-level mileage and stoppage data can inform infrastructure adjustments, signal timing, and local policy decisions where ADS/ADAS deployments affect traffic flow or public transit.
Who Bears the Cost
- Manufacturers and operators subject to the Order (covered entities): They must build data pipelines to extract, de-identify, validate, and transmit extensive telemetry and incident metadata on a monthly cadence, incurring engineering, legal, and operational expenses.
- NHTSA and its data teams: Publishing, hosting, and curating large machine-readable datasets—while also vetting privacy concerns and maintaining data quality—will increase administrative burden and require technical investment.
- Privacy and data-protection stakeholders: Although Level 2 data has limits, detailed vehicle identifiers, precise locations, and event timing raise re-identification risks for occupants and third parties, creating privacy management obligations and potential reputational costs for covered entities.
Key Issues
The Core Tension
The bill pits two legitimate goals against each other: expanding public, research, and regulatory visibility into how ADS and ADAS perform in real-world operations versus protecting driver privacy and firm-level intellectual property; achieving useful, granular transparency will necessarily increase privacy and competitive risk, and the statute leaves the hard trade-offs about aggregation, de-identification, and commercial confidentiality to implementing regulations.
The bill pushes transparency far beyond ad hoc reporting by formalizing a monthly feed of operational data, but it does not prescribe enforcement mechanisms or civil penalties within the statutory text—leaving questions about compliance incentives and remedies to NHTSA’s forthcoming regulations. The reliance on the Third Amended Standing General Order 2021-01 for definitions is practical from an implementation standpoint but effectively imports a snapshot of agency policy into statute; future definitional shifts will require regulatory action rather than simple statutory clarification.
That coupling may create ambiguity where the Order and statute interact, particularly around who qualifies as an 'operator' when multiple parties share control of a vehicle or its software.
The law’s data prescription creates competing demands: researchers and advocates will want raw, high-fidelity records to detect systemic issues, while covered entities will assert trade-secret and competitive harms from disclosing software-version-specific performance and location-linked operational data. Machine-readable public posting mitigates opacity but magnifies commercial concerns.
Additionally, while Level 2 submissions are restricted by a 30-second engagement window and PII limits, the statute does not define a technical standard for de-identification or the methods NHTSA should use to aggregate data to reduce re-identification risk. Finally, the 10-year window for possible rescission gives NHTSA a long runway; absent interim review triggers or sunset provisions for specific reporting elements, industry and public stakeholders could operate under the same mandates for a decade despite rapid technological change.
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