NHTSA has not finalized a comprehensive national rulebook for self-driving cars. On June 25, 2026, the agency announced a proposal to update Federal Motor Vehicle Safety Standard No. 135 so that a vehicle designed to be driven exclusively by an automated driving system would not necessarily need a manually operated brake pedal.
The proposal would preserve the vehicle’s braking-performance requirements, including strict stopping-distance requirements. The larger twist is that NHTSA is modernizing the physical design rules for driverless vehicles while it is still working on objective, nationwide standards for judging whether the automated driving system itself is safe enough.
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What NHTSA actually proposed
The announcement is best understood as an equipment-rule proposal, not a final approval of autonomous cars.
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1Fix the driver behind crashes, sound loss and screen glitches2Clear out junk files and repair common Windows errors3Scan for outdated or missing drivers - takes under a minuteNHTSA’s proposed update to FMVSS No. 135, the federal standard governing light-vehicle service brakes, would remove the requirement for a manually operated brake pedal from vehicles designed to be driven exclusively by an automated driving system. The agency announced the proposal on June 25, 2026, and the proposal appeared in the Federal Register on June 26 under Proposed Rules.
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That distinction matters. A proposal indicates what NHTSA wants to change and invites public comment; it does not yet change the legal requirement. The Federal Register proposal would have to proceed through the rulemaking process before the change could become final.
In plain English, NHTSA is asking whether a purpose-built driverless vehicle should have to include a brake pedal that no human occupant is expected to use.
The key correction: NHTSA proposed to modernize one vehicle-equipment requirement. It did not declare that self-driving cars are approved for unrestricted use, establish a universal autonomous-driving safety test, or legalize driverless cars nationwide.
The brake pedal could disappear; the brakes cannot
The proposal is not an exemption from stopping safely. It addresses the method used to command the brakes.
Under the proposed language, a vehicle’s service-brake control could include an electronic or electronically commanded component that activates the physical braking system. A vehicle without a pedal would therefore still need a functioning service-brake system and would still have to satisfy the applicable performance requirements.
For a conventional vehicle, a stopping-distance test can begin when a human driver applies the brake pedal. For a pedal-free automated vehicle, NHTSA proposes measuring from the initial electronic brake command until the vehicle comes to a complete stop. The agency’s reasoning is that this should remain functionally equivalent to the existing stopping-distance test rather than giving a driverless vehicle an easier standard.
| Question | What the proposal would mean |
|---|---|
| Would the vehicle need a manually operated brake pedal? | Not necessarily, if the vehicle is designed to be driven exclusively by an automated driving system and the proposal is finalized. |
| Would the vehicle still need physical brakes? | Yes. The proposal concerns the manually operated control, not the vehicle’s obligation to stop safely. |
| Would stopping-distance requirements disappear? | No. NHTSA said other braking requirements, including strict stopping-distance requirements, would remain. |
| Could every vehicle remove its pedal immediately? | No. The change is proposed, not final, and other federal standards, exemptions, operating restrictions, and state or local requirements may still apply. |
Why conventional safety standards need updating
Many Federal Motor Vehicle Safety Standards were written around an ordinary assumption: a human driver sits in the vehicle, steers, shifts, looks through the windshield, operates the controls, and responds when something goes wrong.
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A vehicle designed never to be driven by a human may not need every one of those conventional features in the same form. NHTSA’s 2025 automated-vehicle framework identified several areas that may require modernization for vehicles without manual controls, including:
- transmission shifting;
- windshield defrosting and wiping;
- tire-information placards; and
- braking systems.
The agency’s stated objective is to remove requirements that serve no meaningful safety purpose in a vehicle that will never be operated by a human while retaining requirements that still protect occupants and other road users.
That is a reasonable regulatory distinction, but it is also a limited one. Eliminating an obsolete control does not demonstrate that the automated system can drive safely in traffic. It only addresses whether the vehicle’s hardware and controls are described in a way that matches its intended operation.
The important twist: hardware rules are moving faster than driving-performance rules
The difficult regulatory question is not whether a computer can send an electronic brake command. It is how reliably an automated driving system must perform the entire driving task before it can operate without a human ready to take over.
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NHTSA’s National Automated Vehicle Safety Forum stated that the agency is still working toward minimum performance standards for automated-driving-system competency. NHTSA has also acknowledged that no government has yet created objective performance requirements for automated driving that satisfy the demanding statutory criteria for a Federal Motor Vehicle Safety Standard.
That creates an unusual sequence:
- Vehicle-design requirements are being adapted. Regulators are examining whether rules written for human-operated cars should continue to require steering wheels, pedals, mirrors, wipers, and other conventional controls in a purpose-built automated vehicle.
- Deployment pathways already exist in limited forms. Exemptions, testing programs, pilot operations, and restricted commercial deployments can allow some vehicles onto public roads.
- A universal behavioral-safety standard is still unfinished. Regulators have not completed one objective national test that establishes how an ADS must perceive, predict, plan, communicate, obey traffic rules, handle unusual road users, respond to emergencies, and avoid crashes across all operating conditions.
The result is not necessarily a contradiction. Hardware modernization and behavioral-safety regulation are separate jobs. But it does mean that a vehicle can become easier to certify or exempt because its design no longer resembles a conventional car before the government has completed a single comprehensive test for the computer doing the driving.
Where this fits in NHTSA’s broader AV framework
The brake proposal is one step in a larger series of federal actions.
2024: AV STEP
In December 2024, NHTSA proposed AV STEP, a voluntary review and reporting framework for vehicles equipped with automated driving systems. The framework was described as covering ADS-equipped vehicles, including vehicles that require exemptions.
AV STEP is primarily a transparency and operational-data concept. It should not be confused with a complete mandatory safety-performance certification system. Participation would provide a structured way to review and report information, but it would not by itself create a comprehensive pass-or-fail test for autonomous driving competence.
2025: more flexible exemption pathways
In September 2025, NHTSA announced three rulemakings intended to modernize FMVSS requirements for ADS vehicles without manual controls. The agency also described streamlined exemption processes under the Automated Vehicle Exemption Program and the existing Part 555 exemption process, including expansion of the AVEP to domestic vehicles.
If the underlying standards are eventually modernized, NHTSA said individual vehicle exemptions may become unnecessary in situations where a purpose-built automated vehicle can comply directly with the updated rules.
August 2025: Zoox receives a notable exemption
In August 2025, NHTSA granted Zoox an exemption for its American-built driverless vehicle. The agency described it as the first-ever exemption for an American-built vehicle under the expanded program.
That action illustrates the difference between an exemption and a generally applicable rule. A specific vehicle can receive permission for a limited demonstration or deployment pathway while the broader FMVSS framework is still being rewritten. It does not mean every similarly designed vehicle is automatically approved.
What the proposal does not mean for car buyers
It does not mean fully self-driving cars are available to consumers
NHTSA’s current automated-vehicle safety guidance says vehicles with automated driving systems—sometimes called self-driving cars—are not available for consumers to purchase and use today.
Vehicles currently sold in the United States require the driver’s full attention for safe operation. Higher-level automated vehicles are operating in more limited testing, research, pilot, or restricted-deployment settings. A vehicle advertised with advanced driver assistance is therefore not automatically a vehicle that can drive itself without supervision.
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It does not mean every robotaxi may remove its pedal
Even if the proposed brake rule is finalized, a vehicle would still need to satisfy the rest of the applicable federal safety framework or obtain an appropriate exemption. Its deployment could also depend on the vehicle’s design, operating domain, fleet oversight, and other conditions.
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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchState and local rules remain relevant as well. Federal vehicle-safety compliance is not the same thing as permission to provide passenger service on every road in every jurisdiction. The proposal would not erase operating restrictions, enforcement authority, or local requirements.
It does not approve Tesla, Waymo, or any other company nationwide
Zoox is the clearest named example in this research because NHTSA granted it an exemption for an American-built driverless vehicle. Amazon is relevant because it owns Zoox, but the federal action is a NHTSA exemption and rulemaking—not an Amazon consumer-vehicle approval.
Waymo and other robotaxi operators are part of the broader automated-driving ecosystem, but the June 2026 brake proposal does not itself grant any particular Waymo fleet a new operating authorization. Tesla is relevant to the competitive and policy debate, but this proposal should not be described as an exemption for Tesla or as approval for Tesla robotaxis.
Level 2 assistance is not the same as an ADS
Much of the confusion around “self-driving” comes from grouping different technologies together.
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The SAE J3016 taxonomy defines six levels of driving automation, from Level 0 through Level 5. In NHTSA’s regulatory usage, the ADS category covers Levels 3 through 5. Level 2 driver-assistance systems can control steering and speed at the same time, but the human driver must continue supervising the driving task and remain responsible for safe operation.
That is why the brake-pedal proposal is mainly relevant to purpose-built vehicles intended to operate without a human driver, not to an ordinary consumer vehicle whose driver is expected to remain engaged.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Why “safe enough” is harder to measure than a brake test
A brake test can specify a command, a measurement point, a stopping distance, and a repeatable result. Automated driving performance is broader and more context-dependent.
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- detects vehicles, pedestrians, cyclists, emergency responders, animals, road debris, and other unusual hazards;
- predicts the behavior of road users whose actions are uncertain;
- handles construction zones, temporary lane markings, blocked lanes, unusual intersections, and poor visibility;
- follows traffic laws while responding to conflicting or incomplete information;
- chooses safe speeds, gaps, and maneuvers;
- degrades or stops safely when sensors, computing systems, maps, communications, or other components fail;
- communicates with police, firefighters, tow operators, and other emergency personnel; and
- avoids crashes over a sufficiently broad and representative range of real-world conditions.
SAE’s J3237 recommended practice, issued August 20, 2025, provides metrics for assessing dynamic-driving-task performance of ADS-operated vehicles. It is useful technical context for understanding how performance might be measured, but it is not itself a federal approval rule or a nationwide legal certification regime.
That distinction is essential: a technical metric can help regulators and engineers describe performance without automatically becoming the legal standard that every vehicle must meet.
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What NHTSA’s crash-reporting system can—and cannot—tell us
NHTSA’s Standing General Order requires identified manufacturers and operators to report certain crashes involving ADS or Level 2 advanced driver-assistance systems. For ADS incidents, the reporting criteria include use of the ADS within 30 seconds before a crash, together with specified injury or property-damage conditions.
The system gives NHTSA timely information that can support defect investigations, enforcement, and risk analysis. However, NHTSA’s public crash-data page warns that:
- reports can be duplicated;
- system classifications may later be corrected;
- some information is redacted; and
- the available reports can be incomplete.
Those limitations mean the data should not be read as a standardized safety rating or as a controlled national comparison of autonomous-driving performance. The reporting system is an oversight and information tool, not proof that a particular fleet is safer than human drivers or another automated fleet.
This is the policy tension at the center of the new proposal. Industry needs rules that describe vehicles without steering wheels, mirrors, wipers, or pedals. Safety advocates and some policymakers want objective evidence that the automated system itself performs safely before deployments scale. NHTSA is pursuing both goals, but they are progressing at different speeds.
What to watch next
- Whether the brake-pedal proposal becomes final. Until that happens, the announced change remains a proposal.
- The final treatment of other manual-control requirements. Shifting, visibility equipment, tire information, and other standards may need separate amendments or exemptions.
- Whether NHTSA develops measurable ADS competency requirements. This is the harder question because it involves system behavior across many conditions rather than one component.
- How AV STEP develops. A voluntary review and reporting framework could improve transparency, but it would not automatically replace mandatory safety standards.
- What exemptions actually authorize. A company-specific exemption, demonstration approval, or restricted deployment should not be generalized into nationwide permission for all driverless vehicles.
- Whether crash reporting becomes more useful for comparisons. Better data can support investigations, but readers should still account for duplicates, corrections, missing information, and differences in operating environments.
The practical takeaway
NHTSA is beginning to make federal vehicle rules fit cars that do not need a human driver’s controls. The proposed brake-pedal change could help purpose-built automated vehicles avoid a requirement designed for conventional cars, while still requiring them to meet braking-performance standards.
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But it is not the finished self-driving rulebook suggested by the headline. The proposal does not make autonomous cars available for personal purchase, does not approve robotaxis nationwide, and does not answer the central safety question: how should the government prove that an automated driving system is competent enough to operate without a human driver?
The United States is moving toward vehicles that do not need a human driver’s controls while regulators are still deciding how to prove that the computer driving them is safe enough. That is a policy transition—not a single finished rule.
Frequently Asked Questions
Is NHTSA’s new self-driving-car rule final?
No. The June 2026 brake-pedal measure is a notice of proposed rulemaking. It appeared in the Federal Register as proposed rules and would need to be finalized before changing the requirement.
Would a pedal-free automated vehicle still need brakes?
Yes. The proposal concerns the manually operated brake pedal, not the physical braking system or stopping-performance requirements. For a vehicle without a pedal, NHTSA proposes measuring stopping distance from the initial electronic brake command to a complete stop.
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1Repair Windows errors before they cause bigger problems2Scan for outdated or missing drivers - takes under a minute3Clear out junk files and repair common Windows errorsCan consumers buy a fully self-driving car under this proposal?
No. NHTSA’s current public guidance says ADS-equipped vehicles are not available for consumers to purchase and use today. Vehicles sold to consumers still require the driver’s full attention for safe operation.
Does the proposal approve Tesla, Waymo, or all robotaxis?
No. It does not grant a nationwide operating authorization to Tesla, Waymo, or any other fleet. Individual vehicles may still need to comply with other safety standards or obtain exemptions, and state and local operating rules continue to matter.
The Bottom Line
Bottom line: NHTSA proposed removing a human-only brake-pedal requirement from exclusively automated vehicles, but it has not finished defining the objective driving-performance standard that would show those vehicles are safe enough to operate broadly.
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