1. INTRODUCTION
A new regulation concerning the role of artificial intelligence in the Turkish legal system has recently come into force in Turkey. The Regulation on the Type Approval of Motor Vehicles Equipped with Autonomous Driving Systems, published in the Official Gazette on 1 December 2024, No. 32739, has entered into force. The purpose of this regulation is to establish the procedures and principles for the installation of Autonomous Driving Systems (ADS) in motor vehicles of categories M and N, as well as special test procedures and technical requirements for the type of approval of vehicles equipped with ADS. The regulation has been drafted in line with European Union standards. It includes comprehensive testing and approval procedures to ensure vehicle safety.
2. VEHICLE FEATURES AND PROCESS
2.1. ADS and Vehicle Categories
Autonomous driving systems must be able to operate safely without human intervention in all traffic conditions. The Regulation provides a detailed definition of the technical specifications, performance criteria and safety standards for autonomous driving systems. It also subjects these systems to various inspections, examinations and tests to ensure that they are safe and ready for use on public roads.
The regulation, issued by the Ministry of Industry and Technology, applies to vehicles categorised into M and N groups. For clarification, category M vehicles are classified as passenger transport vehicles, while category N vehicles are classified as freight transport vehicles.
2.2. Process
The legislation sets out detailed procedures for the testing and certification processes required for autonomous vehicles to be type-approved. These procedures include driving system tests, environmental impact assessments and software safety assessments.
The information to be provided on autonomous vehicle systems is also specified in detail. .The type-approval of the autonomous driving systems of fully autonomous vehicles is subject to the technical specifications set out in the performance requirements of the Regulation. These technical specifications include
- Dynamic Driving Task (DDT) in nominal traffic scenarios: Assessment of ADS performance in predictable traffic conditions within its Operational Design Domain (ODD).
- Critical Traffic Scenario Response: To test the ability of the ADS to respond safely and operate effectively in unexpected or extreme conditions.
- Safeguards against component failure: Assessing the reliability of the system and the measures taken to prevent hazards caused by malfunction of ADS components.
- Environmental and user error safety mechanisms: Assessment of the mechanisms to ensure that the ADS operates safely under environmental conditions or potential operator error.
- Ability to ensure a safe state in the event of malfunctions or unexpected situations: Test the ability of the ADS to bring the vehicle to a safe state in the event of a malfunction or unforeseen circumstances.
- Emergency Response: Evaluate the ADS's responses to emergency situations and its ability to maintain safe operation.
- Cybersecurity Resilience: Evaluating the ADS's resilience to potential cyberattacks and the measures taken against such threats.
- User Notification Capacity: Assessing the ADS's ability to accurately and promptly inform in-vehicle operators or passengers about the system's status and any required interventions.
- User Intervention Ability and System Responses: Evaluating the ability of users to intervene with the ADS when necessary and the system's responses to such interventions.
Additionally, the regulation comprehensively addresses topics such as dynamic driving tasks within the limits of the operational design domain (ODD), dynamic driving tasks in malfunction scenarios, minimum risk maneuvers (MRM), and minimum risk conditions (MRC). Other key aspects include human-machine interaction, functional and operational safety, cybersecurity and software updates, ADS data requirements, event data recorder elements, manual driving mode, and periodic roadworthiness inspections.
2.3. Compliance
To introduce autonomous vehicles to Turkey, the regulation's conditions must be met. Otherwise, it will not be possible.
3. CONCLUSION
Under the regulation, motor vehicles in categories M and N equipped with Autonomous Driving Systems (ADS) will undergo type approval and necessary technical evaluations conducted by approval authorities or technical services. Autonomous vehicles that successfully complete the testing and inspection processes, and meet the additional requirements outlined in the regulation, will be permitted to enter the Turkish market.
Successfully completing these processes and ensuring that autonomous vehicles comply with all the features specified in the regulation is critical for their introduction to the Turkish market. Considering that a significant proportion of new vehicles are expected to feature autonomous driving capabilities in the near future, it is essential for autonomous vehicles intended for the Turkish market to meet the regulatory requirements. This compliance is vital for their market entry and authorization for road use.
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