SAFE’s Coalition for Reimagined Mobility (ReMo) Comments on Proposal for a New United Nations Global Technical Regulation on Automated Driving Systems

On February 23, 2026, SAFE’s Coalition for Reimagined Mobility (ReMo) submitted comments in response to the National Highway Traffic Safety Administration’s (NHTSA) request for comment on the draft United Nations Global Technical Regulation (GTR) for Automated Driving Systems (ADS).

As transportation systems increasingly incorporate advanced software and artificial intelligence technologies, Automated Driving Systems (ADS) are becoming central to safety, competitiveness, and national security, and the sector is quickly becoming a key arena in the global race to set AI standards, as noted in ReMo’s AI in Motion report. Without proactive engagement in standard-setting and with allies, the United States risks becoming a rule-taker—adopting standards that entrench supply-chain dependencies and embed security risk in ADS ecosystems.

While we support the goal of international safety harmonization, certain technical mandates in the draft ADS Global Technical Regulation (GTR), particularly standardized data access and post-deployment reporting, could inadvertently create data security and supply chain vulnerabilities, potentially creating pathways for coerced disclosure, surveillance, and reverse engineering.

We urge NHTSA to prioritize cybersecurity, data governance, supply chain security, and “minimal viable dataset” principles so that no provision in the GTR allows data to be easily accessed and used to compromise the security interests of the U.S. and its allies. Doing so allows the U.S. to advance the technology and global safety standards, while also ensuring national security.

Read SAFE’s full comments here.