Federal
NHTSA Cybercab special order
A vehicle built without a steering wheel or pedals does not fit federal motor vehicle safety standards written around a human driver.
Why an exemption process exists
Federal Motor Vehicle Safety Standards assume driver-operated controls. A purpose-built autonomous vehicle therefore requires either a change to those standards or a vehicle-specific exemption before it can be sold and operated on public roads in volume.
Current status — as of 17 September 2026
Tesla began paid Cybercab rides in Austin, Texas on 3 September 2026. On 4 September NHTSA's Office of Defects Investigation opened Audit Query AQ26002 into how the Cybercab was certified. On 10 September the agency issued a special order requiring Tesla to produce, under oath and by 30 September 2026, the basis on which it certified a vehicle with no steering wheel, pedals or mirrors as compliant with federal standards written around a human driver.
The standards named include FMVSS 101 (controls and telltales), 102 (shift-position display), 108 (turn signals), 111 (mirrors and rear visibility), 126 (stability-control telltale) and 135 (light-vehicle brakes, which states that "the service brakes shall be activated by means of a foot control"). NHTSA has noted it "has publicly stated that a manufacturer of a vehicle without a foot-activated service brake could not certify to that standard."
Tesla does not hold a Part 555 exemption and, as reported, has not applied for one. By contrast, Amazon's Zoox obtained a temporary Part 555 exemption in July 2026 covering eight standards, including 135 and 111, for its steering-wheel-free vehicle.
This matters directly to this business. Kentucky permits driverless operation only for a vehicle bearing a federal certification label "including any exemptions granted by" NHTSA (KRS Ch. 186, 2024 Acts Ch. 176 §2(1)(c)). An adverse NHTSA finding on Tesla's self-certification would call into question the Cybercab's eligibility to operate driverless in Kentucky, which is the only part of this market where driverless operation is currently lawful. The outcome of AQ26002 is a material, unresolved risk.
Why it matters to this fleet
The scope and volume limits of any federal exemption determine how many vehicles may operate and under what conditions. That directly bounds fleet size and therefore the economics of the business.