The Czech and European automotive industry stands at a critical crossroads. Maintaining the EU’s position as an economic power requires more than a long-term strategy – a fundamental change in the EU’s regulatory approach is essential. Without an industrial policy that reflects global competition, Europe risks becoming a mere outlet for foreign manufacturers instead of a leader in innovation and manufacturing.
The European Commission’s Industrial Action Plan (“the Action Plan”) recognises the urgency of the situation and opens the way for the necessary debate. However, its success will depend on swift and realistic action. While some of the Action Plan’s proposals are in line with our recommendations (see our input to the public consultation), their real effectiveness will only become apparent once the details of practical implementation have been worked out. Moreover, in several areas the Action Plan relies only on recommendations and guidelines, effectively shifting the responsibility and burden to Member States. This approach risks political paralysis and fragmentation of the legislative framework in the EU, leaving the industry without the necessary legislative certainty and predictability. While Member States have a key role to play, the EU must take clear enforceable action where coordination is necessary and not leave key issues unresolved. The emphasis on science, research and innovation is also completely missing from the published action plan. We are convinced that only systematic support in this area will enable the EU to maintain its competitiveness.
Flagship action: Harmonized framework for testing and deploying autonomous vehicles
The highest priority must be to establish clear legal parameters and conditions for the testing and deployment of systems enabling Level 4 and Level 5 automation. However, we note that full harmonisation of rules at EU level will be a complex and lengthy process. We therefore propose to set out a concrete roadmap with a gradual harmonisation of the rules. This must include a timetable that takes into account the rapid progress of regulatory work in other parts of the world.
Key requirements:
- Support for the development and research of automated driving technologies: a clear definition of financial instruments and support for the development and testing of automated driving technologies is essential to ensure their effective development. In the Czech Republic, we have ambitions, among other things, for the creation of a state-of-the-art testing polygon that would clearly advance the development of automated driving technologies and then the operation of autonomous vehicles themselves. We also consider it necessary to support existing polygons where the capacities of OEMs, Tiers and universities are cumulated. We suggest that these and other specific activities should be subject to co-financing from European sources. At the same time, it is crucial to ensure that the funding is used in a truly efficient way and does not go towards maintaining inefficient or outdated processes that hinder innovation rather than fostering it. The direction of support must be industry-driven and reflect the current needs of industry.
- Harmonisation of testing conditions: Testing conditions in the Czech Republic are at a very good level and we therefore insist that harmonisation of rules at European level should not lead to a deterioration of these conditions. Any new rules that emerge must be based on the needs and experience of the industry itself, while respecting the well-functioning practices of those countries that are ahead of the curve in this area. Regulation should encourage innovation and development, not create administrative barriers that impede progress. Therefore, we propose to focus on standardising test operations for SAE Level 5 as a first step.
- Coherence with UN regulations: It is essential that new EU regulations are in line with UNECE international regulations or are properly and timely incorporated into EU law to ensure interoperability and legal stability.
- A rational approach to fragmentation: Europe’s strategic lag behind global competition is also a consequence of inconsistent rules. At the same time, we are of the opinion that strong interventions in specific national rules are in our view not desirable at this point in time. We therefore propose:
- A gap analysis to assess the current situation in the Member States and examples of good practice.
- On the basis of this, prepare a concrete roadmap defining the steps to ensure that emerging rules related to road traffic and road vehicle operation apply uniformly across EU countries.
Flagship action: Cross border test-beds
We see cross-border testing as a key opportunity for the development of automated control technologies. In the Czech Republic, the legislative framework for testing is well set up, but there is still a lack of uniform rules at EU level. It is essential to ensure that European regulation does not restrict best practice in the Czech Republic, but instead supports it.
Key requirements:
- Inclusion of the Czech Republic in the European test corridor: we demand that the test corridor should also run through the Czech Republic in relation to the existing Via Carolina corridor and at the same time include Prague as an important transport hub. In the Czech Republic we have top university teams that are able to create a desirable competitive environment through quality teaching and building tesbeds (in the spirit of the Mobility Living Lab). We therefore propose to include the university city of Ostrava in the test corridor.
- Technology neutrality: The conditions for the test corridors must be set in a technology-neutral way so as not to limit innovation and the development of different autonomous mobility solutions.
- Use of existing infrastructure: It is recommended to select test corridors in locations with existing necessary infrastructure, e.g. with good internet coverage. Such corridors do not require complex investments and preparations before it can be realistically used.
Flagship action: European Connected and Autonomous Vehicle Alliance
This initiative is in line with our vision, but we prefer an approach that is primarily industry-led. The formation and operation of the Alliance, its structure and expected outcomes raise a number of questions for us. We have doubts about its ability to deliver concrete outputs in the time needed.
Key requirements:
- We call for the creation of a separate body to identify strategic research areas, prevent duplication and maximise impact. The alliance should be separate from existing associations so that it can operate independently.
- The Alliance should not bind innovation with predefined objectives, but should create space for the natural development of new technologies.
- Fostering cooperation between start-ups, SMEs and established manufacturers in the automotive technology sector is key.
- We call for more effective funding for research and development, the introduction of tax deductions for research activities and simplified access to European financial instruments.
- It is essential to prevent the Alliance from being misused by non-EU actors (e.g. from China or the US) to promote their business interests on the European market.
- Cooperation between European manufacturers is crucial as our real competitors are outside the EU borders. The Alliance should actively promote this approach.
Flagship action: Access to vehicle data
We understand that in the rapidly evolving area of digital technology, the European Commission wants to provide clear guidance on the handling of vehicle data. However, introducing new legislation goes against the objective of simplifying regulation (pages 17-18) and is not in line with the main objective of the roadmap – strengthening the competitiveness of the European automotive industry. Without an assessment of the impact of the Data Act and other recently adopted (and often not yet implemented) legislation, we cannot support this activity.
Key requirements:
- Do not adopt further data sharing legislation without properly assessing the impact of existing legislation.
Cybersecurity
With the rise of connected and autonomous vehicles, cybersecurity is also growing in importance. The safety of the vehicle and its crew and other road users must always be a priority. Here too, a predictable and, where possible, uniform legislative environment is paramount.
Key requirements:
- To complete the process of adoption of the NIS2 Directive and its implementation into national legislation, to the extent necessary and not excessive (financially and administratively).
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