RE: LeoThread 2025-12-09 09-54

Full Self-Driving (Supervised) has been under active development for shipment in Europe for more than 12 months. FSD demonstrations have been provided to regulators in nearly every EU country. Early access, pilot-release programs, or exemptions have been requested where feasible

Detailed safety evidence for FSD has been developed and published in the latest Safety Report. Over 1 million kilometers have been driven safely on EU roads across 17 countries during internal testing

The primary route to deployment is cooperation with the Dutch approval authority RDW to secure an exemption. This requires demonstrating compliance with existing regulations (UN-R-171 DCAS) and filing an exemption under EU Article 39 for behaviors not yet regulated, such as Level 2 systems off-highway and system-initiated lane changes with hands-off steering

Certain regulations are outdated and rule-based, effectively rendering FSD illegal in its current form. Modifying FSD solely to meet those rules would, in many cases, reduce safety and usability. Adjustments have been made where logical and reasonable to increase compliance, but safety and practical usability will not be sacrificed

Consequently, evidence is being assembled to obtain exemptions on a rule-by-rule basis. Real-world, fleet-proven safety alone has been deemed insufficient

RDW has committed to granting Netherlands national approval in February 2026. Once Dutch national approval is granted, other EU countries can recognize the exemption and allow rollout domestically, after which it will be brought to a TCMV vote for potential EU-wide approval

Anticipation remains to make FSD available to owners in Europe in the near future