FMVSS No. 135 Modernization for ADS-Equipped Vehicles

Current understanding

NHTSA has proposed amending Federal Motor Vehicle Safety Standard No. 135 (light vehicle brake systems) to create distinct compliance pathways for vehicles with and without manually operated driving controls. The proposal preserves core stopping-distance and brake performance requirements while adapting test procedures and control-actuation assumptions so that autonomous driving system (ADS)-equipped vehicles without traditional pedals or steering can be certified. Status: proposed rule (NPRM).

Evidence log

• 2026-10-26 — Federal Motor Vehicle Safety Standards; Modernization of FMVSS No. 108 To Accommodate ADS-Equipped Vehicles: cross-connection with fmvss-108-ads-modernization: Both are NHTSA FMVSS modernization proposals removing driver-operated control requirements for fully driverless ADS-equipped vehicles (108 covers lighting; 135 covers brake controls). (novelty: 3)
• 2026-07-31 — Temporary Exemption From Motor Vehicle Safety and Bumper Standards: cross-connection with nhtsa-temporary-exemption-fmvss-bumper: Expanded scope of temporary FMVSS exemptions is procedurally relevant to ADS-equipped vehicles seeking relief from legacy FMVSS provisions during rulemaking modernization. (novelty: 2)
• 2026-02-10 — ADAS Functionality and Integrity Act: 2026 — HR6688 (ADAS Functionality and Integrity Act) advanced from subcommittee to full committee, signaling parallel legislative attention to driver-assistance system integrity alongside NHTSA’s ADS-focused FMVSS 135 rulemaking (ADAS ≠ ADS but adjacent policy space). (novelty: 2)
• 2026-06-26 — ADS-Equipped Vehicle Safety, Transparency, and Evaluation Program; Withdrawal: NHTSA’s withdrawal of the parallel AV STEP voluntary transparency NPRM narrows the ADS regulatory package, leaving FMVSS-based standards like the FMVSS 135 modernization as the more prominent active ADS rulemaking track. (novelty: 3)

Open questions

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