Basic Report
RESEARCH
KOTI - Korea Transport institute
(RR-24-01) Proposed Legal Framework Reforms for the Introduction of Unmanned Autonomous Mobility Services
- Date
July 01 2025
- Authors
Sehyun TAK, Kyeong-pyo KANG, Harim JEONG, Ah-hae CHO
- Page(s)
20 page(s)
1. Research Overview
Autonomous vehicles (AVs) are receiving increasing attention not only for their potential to improve driver convenience and reduce traffic accidents, but also as a key sector leading the development of next-generation technologies. In response to these trends, countries around the world, including South Korea, are actively investing in and supporting AV development.
The temporary permit system for AVs, introduced in 2016, has allowed real-world road testing of developed autonomous vehicles and plays a key role in verifying and improving their performance. By 2023, around 417 AVs had been granted such permits for road testing. The Korean government is now accelerating commercialization, particularly for Level 3 AVs that require conditional human takeover in specific scenarios.
More recently, challenges such as driver shortages and rising transport costs—especially in sparsely populated areas—have intensified the need for efficient transportation services. As a result, demand is growing for Level 4 AV-based mobility services. Level 4 AVs are capable of fully autonomous operation within a predefined Operational Design Domain (ODD), and unlike Level 3 vehicles, they can manage risk scenarios independently without requiring human takeover thanks to features such as Minimum Risk Maneuver (MRM). This enables the provision of fully unmanned mobility services, which could help resolve labor shortages and strengthen the financial stability of transport service providers.
To support this transition, the Korean government has launched a variety of policies aimed at integrating AV technology with existing mobility services. Since 2020, the government has implemented a “Pilot Operation Zone” program for AVs with paid services in 34 designated areas. In addition, plans are underway to develop a performance certification system and revise the AV Act to permit vehicle sales and establish a market-driven AV ecosystem.
Despite these efforts, several limitations persist. First, Korea’s AV industry is relatively small and heavily reliant on government subsidies compared to the United States and Europe. This has made it difficult to attract sufficient private investment, hindering the development of sustainable business models and delaying commercialization. A strategy that promotes technological development in tandem with service deployment and encourages private sector participation is needed.
Second, there is a lack of a comprehensive legal framework to support the stable implementation of AV-based mobility services. Current laws are focused on testing and pilot programs and do not adequately address the legal foundations necessary for actual service delivery, such as training test drivers, vehicle management, and safety standards. For AV mobility services to become commercially viable, a full legal and institutional infrastructure must be in place.
In particular, the existing legal structure is based on the assumption that a safety driver is always present. Even if the AV system can perform driving functions, human oversight is still required in the event of emergencies or for verifying passenger safety. This poses a major obstacle to full automation. Addressing driver shortages and rising operational costs will require legal and institutional reforms that permit services to operate on a fully unmanned basis.
This study aims to propose legal and institutional reform measures to overcome the limitations of the current AV testing-focused framework and to support the development of a market-led AV ecosystem with the convergence of autonomous driving technology and mobility services. It analyzes issues among drivers, roads, and transportation services, and compares domestic and international laws to assess Korea’s current standing. Special attention is given to the relationship between the temporary operation permit system and service provision authorization to identify the unique characteristics of each service type and provide tailored legal responses. In particular, the study focuses on transitioning from drivered AV mobility services to unmanned AV mobility services and offers a legal foundation for both technical efficiency and service stability.
Autonomous vehicles (AVs) are receiving increasing attention not only for their potential to improve driver convenience and reduce traffic accidents, but also as a key sector leading the development of next-generation technologies. In response to these trends, countries around the world, including South Korea, are actively investing in and supporting AV development.
The temporary permit system for AVs, introduced in 2016, has allowed real-world road testing of developed autonomous vehicles and plays a key role in verifying and improving their performance. By 2023, around 417 AVs had been granted such permits for road testing. The Korean government is now accelerating commercialization, particularly for Level 3 AVs that require conditional human takeover in specific scenarios.
More recently, challenges such as driver shortages and rising transport costs—especially in sparsely populated areas—have intensified the need for efficient transportation services. As a result, demand is growing for Level 4 AV-based mobility services. Level 4 AVs are capable of fully autonomous operation within a predefined Operational Design Domain (ODD), and unlike Level 3 vehicles, they can manage risk scenarios independently without requiring human takeover thanks to features such as Minimum Risk Maneuver (MRM). This enables the provision of fully unmanned mobility services, which could help resolve labor shortages and strengthen the financial stability of transport service providers.
To support this transition, the Korean government has launched a variety of policies aimed at integrating AV technology with existing mobility services. Since 2020, the government has implemented a “Pilot Operation Zone” program for AVs with paid services in 34 designated areas. In addition, plans are underway to develop a performance certification system and revise the AV Act to permit vehicle sales and establish a market-driven AV ecosystem.
Despite these efforts, several limitations persist. First, Korea’s AV industry is relatively small and heavily reliant on government subsidies compared to the United States and Europe. This has made it difficult to attract sufficient private investment, hindering the development of sustainable business models and delaying commercialization. A strategy that promotes technological development in tandem with service deployment and encourages private sector participation is needed.
Second, there is a lack of a comprehensive legal framework to support the stable implementation of AV-based mobility services. Current laws are focused on testing and pilot programs and do not adequately address the legal foundations necessary for actual service delivery, such as training test drivers, vehicle management, and safety standards. For AV mobility services to become commercially viable, a full legal and institutional infrastructure must be in place.
In particular, the existing legal structure is based on the assumption that a safety driver is always present. Even if the AV system can perform driving functions, human oversight is still required in the event of emergencies or for verifying passenger safety. This poses a major obstacle to full automation. Addressing driver shortages and rising operational costs will require legal and institutional reforms that permit services to operate on a fully unmanned basis.
This study aims to propose legal and institutional reform measures to overcome the limitations of the current AV testing-focused framework and to support the development of a market-led AV ecosystem with the convergence of autonomous driving technology and mobility services. It analyzes issues among drivers, roads, and transportation services, and compares domestic and international laws to assess Korea’s current standing. Special attention is given to the relationship between the temporary operation permit system and service provision authorization to identify the unique characteristics of each service type and provide tailored legal responses. In particular, the study focuses on transitioning from drivered AV mobility services to unmanned AV mobility services and offers a legal foundation for both technical efficiency and service stability.
[ Contents ]
1. Research Overview
2. Legal and Institutional Analysis of Unmanned Autonomous Mobility Services
2-A. Definition and Necessity of Unmanned Autonomous Mobility Services
2-B. Analysis Targets and Methodology
2-C. Analysis of Domestic Legal Framework – Operation
2-D. Analysis of Domestic Legal Framework – Driving
2-E. Analysis of Domestic Legal Framework – Transportation
2-F. Key Legal and Policy Challenges Identified
3. Risk-Based Prioritization and Strategy for Legal Reform
3-A. Risk-Based Prioritization of Legal and Institutional Improvements
3-B. Legal Reform Strategies by Implementation Phase
3-C. Key Focus Areas for Legal and Institutional Reform
4. Conclusion and Policy Recommendations
4-A. Conclusion
4-B. Policy Recommendations and Future Research Directions
1. Research Overview
2. Legal and Institutional Analysis of Unmanned Autonomous Mobility Services
2-A. Definition and Necessity of Unmanned Autonomous Mobility Services
2-B. Analysis Targets and Methodology
2-C. Analysis of Domestic Legal Framework – Operation
2-D. Analysis of Domestic Legal Framework – Driving
2-E. Analysis of Domestic Legal Framework – Transportation
2-F. Key Legal and Policy Challenges Identified
3. Risk-Based Prioritization and Strategy for Legal Reform
3-A. Risk-Based Prioritization of Legal and Institutional Improvements
3-B. Legal Reform Strategies by Implementation Phase
3-C. Key Focus Areas for Legal and Institutional Reform
4. Conclusion and Policy Recommendations
4-A. Conclusion
4-B. Policy Recommendations and Future Research Directions