How International Road-Transport Law Built Itself Around a Country That Never Signed, and What the Freight Industry’s Own Numbers Say About the Predictions Made Along the Way
August 2026
Why this brief exists
Every major international body working on autonomous vehicle policy operates through Geneva. The treaty framework, the vehicle safety regulators, the trucking industry’s own trade group, and the global labor federation all trace back to the same city and the same overlapping cast of institutions.
This brief checks what those bodies did against what the United States (US) is legally bound by. It also tests one concrete prediction those same bodies made in 2017 against what happened on American roads by 2026.
Every claim below is sourced to a primary document: a United Nations (UN) treaty depositary record, a government regulator’s own filing, an industry group’s adopted policy position, or a company’s Securities and Exchange Commission (SEC) filing. Where sourcing is thinner than that, this brief says so directly rather than smoothing it over.
Part I: two treaties, one absent signatory
Two international treaties sit under most of the world’s road traffic law. The Geneva Convention on Road Traffic, signed in 1949, and the Vienna Convention on Road Traffic, signed in 1968.
The US ratified Geneva in 1950. It is still in force. It has never been amended for automated driving, not once, in 76 years.
The US never joined Vienna. Neither did China.
Vienna has been amended twice for automated vehicles. In 2016, Article 8 was changed to allow a vehicle to take over the driving task from a human, as long as the system can be overridden or switched off. In 2021, a new Article 34bis was added, defining an “automated driving system” and allowing the system itself, not a human, to serve as the legal operator.
Only four countries formally notified the UN Secretary-General that they accept Article 34bis: Finland, Switzerland, the United Kingdom (UK), and the Netherlands (for its European territory only). Zero countries filed a formal objection. Under Vienna’s amendment rules, silence counts as acceptance unless a party objects within the notice period. Out of roughly 91 parties to the treaty, four bothered to say yes on the record. Nobody said no.
Germany shows what acceptance looks like once it leaves the treaty page. It folded the 2016 Article 8 amendment into its own domestic law in December 2016.
Legal scholars who have studied both conventions, including a widely cited 2014 analysis by Bryant Walker Smith and the UK government’s own 2021 explanatory memorandum on the 34bis amendment, reach the same conclusion: automated driving was never prohibited by either treaty. The treaties are silent on the question, not hostile to it.
Source: UN Treaty Collection, Chapter XI.B.19 (Convention on Road Traffic, Vienna, 1968), depositary notifications C.N.5.2021 and related acceptances. Bryant Walker Smith, “Automated Vehicles Are Probably Legal in the United States,” 1 Tex. A&M L. Rev. 411 (2014). UK Explanatory Memorandum on the Proposal of Amendment to Article 1 and new Article 34 bis (2021). Library of Congress Global Legal Monitor, Germany country report (2016).
Part II: the track the US sits on instead
The US has no legal stake in the Vienna Convention fights. It has a full seat at a different table.
A separate structure called the 1998 Agreement runs through the World Forum for Harmonization of Vehicle Regulations, known as WP.29, part of the United Nations Economic Commission for Europe (UNECE). The National Highway Traffic Safety Administration (NHTSA), the US Department of Transportation’s vehicle safety regulator, is the official US delegation lead to that body.
Canada sits in the exact same position as the US. It is a Geneva party, not a Vienna party, and it holds one of six seats, alongside China, the European Union (EU), the UK, Japan, and the US, on the bureau that led development of a new safety framework called the Global Technical Regulation (GTR) on Automated Driving Systems (ADS). The arrangement is structural, repeated one country over.
In January 2026, the Working Party on Automated/Autonomous and Connected Vehicles, known as GRVA, adopted a draft GTR built around a “safety case” approach rather than fixed performance numbers. On June 22 through 26, 2026, WP.29’s 199th session formally adopted the GTR and a companion UN Regulation by vote of all contracting parties. It is the first global technical regulation on automated driving ever adopted.
It does not automatically become US law. NHTSA opened a public comment docket, NHTSA-2026-0034, specifically to gather input on the draft before deciding whether or how to use it domestically. Fourteen comments came in before the deadline. Consumer Reports filed one, focused on how the GTR’s provisions would interact with existing US safety authority. A private individual filed another, flagging that UN work on automated ships and rail sits alongside the road vehicle framework. No trucking industry commenter turned up in the sample this brief reviewed, though the full docket was not exhaustively checked.
The US domestic track is not standing still either. NHTSA’s own proposed rule on ADS safety reporting and transparency, opened under the prior administration in January 2025, was formally withdrawn on June 26, 2026, the same week WP.29 adopted the international framework.
Source: Sidley Austin LLP, “A New Global Milestone for Autonomous Vehicles” (March 2026) and “NHTSA Announces a Host of Actions on Autonomous Vehicles” (August 2026). Federal Register, Docket NHTSA-2026-0034 (January 23, 2026, and February 26, 2026 extension notices). Federal Register, Docket NHTSA-2024-0100 withdrawal notice (June 26, 2026). UNECE GRVA session records, January and June 2026. Consumer Reports comment letter to NHTSA, February 23, 2026.
Part III: trucks were never excluded
It would be easy to assume the international framework only ever meant passenger cars. It does not.
The UN’s own vehicle classification system explicitly covers heavy trucks, under categories N2 and N3, alongside passenger vehicles. UN Regulation No. 157, covering Automated Lane Keeping Systems, was extended by amendment in 2022 from cars and vans to trucks, buses, and coaches, under the same safety requirements.
The European Union’s General Safety Regulation separately covers all heavy trucks over 3.5 tonnes.
Compare that to how the American conversation usually runs. Most domestic coverage and most state legislation still frames autonomous vehicles around passenger robotaxis first. The international regulatory bodies have been more truck-literate about American trucks than most of the American conversation about them.
Source: UNECE press release, “UN regulation on Automated Lane Keeping Systems (ALKS) extended to trucks, buses and coaches” (2022). EU General Safety Regulation, vehicle scope provisions.
Part IV: remote driving is an international question too
Teleoperation, meaning a human driving or supervising a vehicle from outside it, has its own standing item on the international agenda.
The Global Forum for Road Traffic Safety, known as WP.1, has carried “Remote activities related to driving” across at least its 90th and 91st sessions, submitted jointly by Finland, Germany, and the UK.
That is a direct international counterpart to the state-by-state teleoperation patchwork already documented elsewhere in this library. Nobody had connected the two tracks before this research.
Source: UNECE WP.1 session documents, 90th and 91st sessions (2025), informal document “Remote activities related to driving.”
Part V: the industry’s own position, and the legal gap inside it
The International Road Transport Union (IRU), the Geneva-based global trade body for truck, bus, coach, and taxi operators, adopted an updated formal position on autonomous vehicles at its General Assembly on May 12, 2023, updating an earlier 2018 position.
The position states plainly that higher automation “will not address the current shortage of drivers.” That sits in tension with how the driver shortage gets used elsewhere in industry messaging, as the reason automation is needed in the first place.
IRU’s liability framework runs straight through Article 8(5) of the Vienna Convention, the same clause requiring a driver able to control the vehicle at all times. IRU maps that clause against the driving automation levels set by SAE International, the Society of Automotive Engineers, zero through five. At Levels 0 through 2, the driver holds liability. At Level 3, IRU calls the liability question unclear. At Levels 4 and 5, liability shifts entirely to the vehicle manufacturer.
Here is the problem. The US is not a party to Vienna. IRU’s entire liability logic is built on a treaty clause that does not legally reach the country running the world’s most active driverless trucking operations right now. The freight industry’s own foundational liability framework does not attach cleanly to its biggest live market.
IRU’s position also calls for data ownership to stay with the operator rather than the authorities, freight-specific cybersecurity provisions, and mandatory training on automated systems for drivers and operators.
On the driver shortage itself, precision matters. IRU’s 2025 Global Driver Shortage Report, its most recent full survey, found 2.9 million unfilled truck driver positions across 18 markets, 11 percent of the surveyed workforce. An earlier IRU figure of 3.6 million across 36 countries comes from a different publication with a different scope and should not be blended with the 2025 number.
Source: IRU, “Updated IRU Position on Autonomous Vehicles,” adopted at IRU General Assembly, Geneva, May 12, 2023. IRU, “Global Driver Shortage Report 2025.”
Part VI: labor’s global voice, and a real contract
The International Transport Workers’ Federation (ITF), a London-based global union federation representing roughly 19.7 million transport workers across 149 countries, holds its own standing position on automation. It calls for no deployment of driverless technology in public spaces until it passes stringent safety testing and is secured against hacking, and for mandatory training for workers around autonomous machines.
Note on naming. A second, unrelated organization, the International Transport Forum, an intergovernmental policy body linked to the Organisation for Economic Co-operation and Development (OECD), also uses the acronym ITF. The two bodies are not the same, and both are active in this space.
ITF (the union) treats remote driving as its own labor issue, separate from full automation, and draws a direct comparison to railway signaling, where digital monitoring already expanded the territory a single worker covers. That comparison is ITF’s own stated position, not an independently measured finding.
Labor’s advocacy has produced at least one enforceable contract, not just position papers. The Transport Workers Union of America, a US ITF affiliate, secured a first-of-its-kind agreement with the Central Ohio Transit Authority (COTA) in 2024 giving the union veto power over the deployment of autonomous vehicles, along with a guarantee that bus operators and mechanics cannot be laid off or have wages cut because of new technology. COTA’s own 2024 Impact Report confirms the underlying agreement as a milestone contract. Independent reporting has since cited it as a template other transit unions are pursuing.
Source: International Transport Workers’ Federation, standing automation policy (itfglobal.org). Transport Workers Union, press releases on the Central Ohio Transit Authority agreement (2024, 2026). Central Ohio Transit Authority, 2024 Impact Report. Billy Penn, reporting on transit union AV contract precedent (August 2026). Ohio State Employment Relations Board, filed Memorandum of Agreement, Local 208.
Part VII: the prediction that did not happen
In 2017, the International Transport Forum published Policy Paper No. 32, “Managing the Transition to Driverless Road Freight Transport,” through the OECD. IRU, ITF (the union), and the European Automobile Manufacturers Association contributed data, insights, and funding to the study, according to the OECD’s own publication record.
The report projected that automated trucks could eliminate 1.5 million driver jobs in Europe and another 1.5 million in North America within ten years. That window closes at roughly 2027. It recommended governments set up a temporary transition advisory board, seating labor, industry, manufacturers, and government together, along with a permit system funded by automation’s beneficiaries to support displaced drivers.
Nine years later, the prediction has not materialized. It has inverted.
The US currently employs roughly 3.0 to 3.1 million truck drivers, essentially flat against 2017 levels. The American Trucking Associations puts the 2026 US driver shortage at approximately 82,000, still rising. The Bureau of Labor Statistics’ own median driver age sits at 57, and the agency projects 4 percent employment growth for the occupation through 2034, not a decline.
Actual driverless deployment remains small relative to the workforce. Aurora Innovation’s own SEC-filed second quarter 2026 shareholder disclosures show 20 to 25 driverless trucks operating by the end of the third quarter of 2026, with a target of more than 200 by year-end, fully allocated to customers already under contract. That is one company’s fleet, not the whole industry, and it is a rounding error against a 3-million-driver workforce.
What is happening on the ground looks like substitution at the margin. Automation is filling specific long-haul lanes that carriers cannot staff anyway, not displacing an existing workforce. The mechanism the 2017 report modeled, mass automation outpacing labor demand, never showed up. What showed up instead was a deepening shortage.
Source: International Transport Forum, “Managing the Transition to Driverless Road Freight Transport,” OECD Publishing, Policy Paper No. 32 (2017), DOI 10.1787/0f240722-en. American Trucking Associations, 2026 workforce report. US Bureau of Labor Statistics, Occupational Outlook Handbook, heavy and tractor-trailer truck drivers. Aurora Innovation, Inc., Second Quarter 2026 shareholder letter and earnings call transcript (July 29, 2026).
Part VIII: the pattern underneath all of it
Every major body in this space, the treaty framework, the vehicle safety regulators, the trucking industry’s own trade group, and the global labor federation, routes itself through Geneva-based process that does not cleanly reach the country where the technology is running today.
And the one time all of them sat at the same table and put a number on paper, the number came out backwards.
International road transport governance has a strong record of talking to itself about a future that keeps declining to show up on schedule. The disruption, when it does arrive, keeps arriving somewhere these bodies were not quite looking.
Sources
• United Nations Treaty Collection, Chapter XI.B.19, Convention on Road Traffic (Vienna, 1968), depositary status and notifications.
• Bryant Walker Smith, “Automated Vehicles Are Probably Legal in the United States,” 1 Texas A&M Law Review 411 (2014).
• UK Government, Explanatory Memorandum on the Proposal of Amendment to Article 1 and new Article 34 bis of the 1968 Convention on Road Traffic (2021).
• Library of Congress, Global Legal Monitor, “Germany: Road Regulations Amended to Allow Autonomous Vehicles” (2016).
• Sidley Austin LLP, “A New Global Milestone for Autonomous Vehicles: What the UN Global Technical Regulation on Automated Driving Systems Means for Autonomy in the U.S. and Around the World” (March 4, 2026).
• Sidley Austin LLP, “NHTSA Announces a Host of Actions on Autonomous Vehicles” (August 2026).
• US Federal Register, Docket NHTSA-2026-0034, Notice and Request for Comment (January 23, 2026, and February 26, 2026 extension).
• US Federal Register, Docket NHTSA-2024-0100, ADS-Equipped Vehicle Safety, Transparency, and Evaluation Program, Withdrawal (June 26, 2026).
• Consumer Reports, Comments to NHTSA on the UN Global Technical Regulation for Automated Driving Systems (February 23, 2026).
• UNECE, “UN regulation on Automated Lane Keeping Systems (ALKS) extended to trucks, buses and coaches” (2022).
• UNECE, WP.1 (Global Forum for Road Traffic Safety) session documents, 90th and 91st sessions (2025).
• International Road Transport Union, “Updated IRU Position on Autonomous Vehicles,” adopted at IRU General Assembly, Geneva (May 12, 2023).
• International Road Transport Union, “Global Driver Shortage Report 2025.”
• International Transport Workers’ Federation, standing automation policy, itfglobal.org.
• Transport Workers Union, press releases on the Central Ohio Transit Authority collective bargaining agreement (2024, 2026).
• Central Ohio Transit Authority, 2024 Impact Report.
• Billy Penn, reporting on transit labor and autonomous vehicle contract precedent (August 2026).
• Ohio State Employment Relations Board, filed Memorandum of Agreement, Transport Workers Union Local 208 and Central Ohio Transit Authority.
• International Transport Forum, “Managing the Transition to Driverless Road Freight Transport,” OECD Publishing, International Transport Forum Policy Papers No. 32 (2017), DOI 10.1787/0f240722-en.
• American Trucking Associations, 2026 workforce and driver shortage report.
• US Bureau of Labor Statistics, Occupational Outlook Handbook, heavy and tractor-trailer truck drivers.
• Aurora Innovation, Inc., Second Quarter 2026 Shareholder Letter and earnings call transcript (July 29, 2026).