Technical-Comparative Analysis of International Regulatory Frameworks on Autonomous Vehicle Safety: A Systematic Literature Review.

Resumen

The accelerated adoption of autonomous vehicles (AVs) has driven the development of regulatory frameworks and technical standards aimed at ensuring their safe, ethical, and legal operation. This Systematic Literature Review (SLR) aims to analyze and compare the main international regulatory frameworks related to the safety of autonomous vehicles, identifying strengths, weaknesses, and regulatory gaps. The review focused on studies addressing vehicles with SAE autonomy levels 3 to 5, paying special attention to the legal and regulatory frameworks applied, as well as their effectiveness in mitigating risks and incidents. Although a formal comparison was not established, works that examine regional differences between Europe, the United States, and Asia were prioritized. The bibliographic search was conducted through a structured and rigorous process that allowed the selection of relevant and high-quality scientific literature. The identified studies address both functional safety—understood as the vehicle's ability to operate without causing damage—and cybersecurity, focused on protection against digital threats and unauthorized access. The findings reveal a fragmented regulatory landscape, with diverse approaches across regions. Some countries (such as Germany) have made significant progress, while others remain in the development phase. The review underscores the need to harmonize standards and strengthen the international legal framework, integrating technical, legal, and social perspectives. This research contributes to the academic and regulatory debate by offering a comparative overview that can serve as a basis for formulating more coherent and effective public policies.