Category: Emerging risks · Reviewed by Matt Bartlett, Director · Founder · Last reviewed 2026-06-10
Autonomous vehicle (AV) insurance is the United Kingdom’s statutory motor insurance regime applicable to vehicles capable of driving themselves, framed by the Automated and Electric Vehicles Act 2018 and the Automated Vehicles Act 2024, under which the insurer is liable in the first instance for damage caused while a vehicle is driving itself.
The UK has adopted an “insurer-first” liability model: the motor insurer pays the third-party victim and may then recover from the responsible party (manufacturer, software developer or the new “Authorised Self-Driving Entity” introduced by the Automated Vehicles Act 2024). The Law Commission and Scottish Law Commission joint report on automated vehicles (HC 1144, January 2022) formed the basis of the 2024 Act.
First-party damage to the insured automated vehicle.
Product recall and product liability arising in respect of the manufacturer or ASDE following insurer subrogation.
Cybersecurity cover for over-the-air software updates and connected-vehicle data.
Operator and “user-in-charge” cover under the new categories in the 2024 Act.
Legal and regulatory basis
The UK statutory framework comprises:
Road Traffic Act 1988, Part VI — the compulsory insurance regime.
Automated and Electric Vehicles Act 2018, sections 1–8 — list of automated vehicles maintained by the Secretary of State; insurer liability when the vehicle is driving itself; rights of recovery against the person responsible.
Automated Vehicles Act 2024 — establishes the Authorised Self-Driving Entity (ASDE), No-User-in-Charge Operator licensing, and a “user-in-charge” category; creates a new safety regulator regime under the Secretary of State for Transport.
Law Commission and Scottish Law Commission, “Automated Vehicles: joint report” (HC 1144), January 2022 — the policy foundation.
FCA Handbook ICOBS — distribution of compulsory and ancillary cover.
The Motor Insurers’ Bureau (MIB) remains the body of last resort under the Untraced and Uninsured Drivers Agreements.
How it works in practice
Under the AEVA 2018 model, where an accident occurs while a listed automated vehicle is driving itself and an insured person suffers damage:
The insurer pays the third-party claimant (or the insured) for personal injury and property damage in accordance with the policy and the compulsory regime.
The insurer’s right of recovery against the person responsible (typically the manufacturer or, post-AV Act 2024, the ASDE) is preserved by section 5 of the 2018 Act.
Contributory negligence by the user is dealt with under section 3.
The Automated Vehicles Act 2024 introduces additional roles: a User-in-Charge (a human licensed driver responsible when the vehicle is not in self-driving mode) and a No-User-in-Charge Operator (a licensed operator responsible for vehicles operated without a human in the driving seat).
Common variations and subsequent developments
ABI/Thatcham AV roadmap — sets out industry expectations on cybersecurity, data sharing and insurer access to event data (the “AV Data Code”).
Fleet AV cover — bespoke wordings for ride-hailing and goods vehicle operators.
Cybersecurity warranties — adherence to UNECE Regulation 155 (cybersecurity) and Regulation 156 (software updates), retained in UK type approval.
Statutory Authorised Self-Driving Entity register — maintained by the Secretary of State under the 2024 Act.
Example
A vehicle on the section 1 list of automated vehicles drives itself on a UK motorway and is involved in a collision causing GBP 80,000 of personal injury and GBP 25,000 of property damage. Under section 2(1) of the AEVA 2018, the insurer of the automated vehicle is liable to the injured third party for the full amount. The insurer pays in accordance with motor insurance requirements, then exercises its right under section 5 to recover against the ASDE responsible for the vehicle’s automated driving system, supported by event-data downloads under the AV Data Code.
Department for Transport, “Connected and Automated Mobility 2025” (2022).
Motor Insurers’ Bureau, Untraced Drivers Agreement (current edition).
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-10. Next review: 2026-12-10.
Apex Insurance Brokers Limited. Authorised and regulated by the Financial Conduct Authority, FRN 724952. Registered in England and Wales, Companies House 07014570. This entry provides general information about UK insurance concepts and is not regulated advice. Consult your insurance broker on your specific position.
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