When a driverless taxi runs a red light in San Francisco, there is no one behind the wheel to hand a ticket to. Starting in 2025, California gave police officers a way to do the next best thing: cite the company whose software was driving.
Assembly Bill 1777, signed into law as part of a package of autonomous vehicle reforms, created a new enforcement mechanism called a “notice of autonomous vehicle noncompliance.” Under Vehicle Code sections 38751 through 38753, any peace officer who witnesses a traffic violation committed while a vehicle’s autonomous technology is engaged can issue a formal notice directed not at a driver, but at the manufacturer responsible for the self-driving software. The California Department of Motor Vehicles has spent months building the regulatory framework to make that authority operational, and as of spring 2026, the agency’s rulemaking documents show the system is nearing completion.
How the notice system works
The noncompliance notice is not a traditional traffic ticket. It does not carry points on a license or a fine payable by a human driver. Instead, it functions as an official record that a specific autonomous vehicle, operated by a specific manufacturer’s software, allegedly violated the Vehicle Code or a local traffic ordinance.
The DMV designed a dedicated form for the process. Its Initial Statement of Reasons for the rulemaking identifies Form OL 325 (revised December 2024) as the official notice document, created under Vehicle Code Section 38752. The Initial Statement of Reasons is part of the DMV’s formal rulemaking process under the California Administrative Procedure Act; it represents the proposed-rule stage, in which the agency publicly explains and justifies the regulations it intends to adopt before they become final. Officers would be able to place the form inside the driverless vehicle at the scene or mail it directly to the manufacturer. Once a manufacturer receives a notice, it is required to respond and to submit the form’s contents back to the DMV.
The DMV’s revised proposed regulations, which went through a public comment period, spell out these logistics in detail, covering everything from where inside a vehicle the notice should be placed to the timeline for manufacturer responses.
Why California built this tool
The law did not emerge in a vacuum. California’s autonomous vehicle industry has grown rapidly. According to the DMV’s annual AV testing mileage report, permit holders logged more than 9 million test miles in the state in the 2023 reporting year, the most recent period for which public data is available. Robotaxis operated by Waymo now serve paying customers across San Francisco and parts of Los Angeles, and the vehicles interact with pedestrians, cyclists, and other drivers thousands of times a day.
That expansion brought friction. Residents and city officials reported driverless cars blocking intersections, stopping in crosswalks, and behaving unpredictably in construction zones. The October 2023 incident in which a Cruise robotaxi struck and dragged a pedestrian in San Francisco intensified pressure on Sacramento to strengthen oversight. Cruise’s California permits were subsequently suspended, and the company eventually ceased operations entirely.
Against that backdrop, AB 1777 gave law enforcement a tool they had been lacking. Before the bill, officers who witnessed an autonomous vehicle commit a traffic violation had no standardized way to document it or hold the operator accountable. The noncompliance notice fills that gap by creating a paper trail that feeds into the DMV’s broader AV monitoring system, alongside crash reports and disengagement data.
Part of a broader regulatory push
AB 1777 was not the only AV bill to take effect. The DMV’s summary of new 2025 laws lists several companion measures, including AB 1978, AB 2186, and AB 2807, each targeting different aspects of autonomous vehicle regulation. Together, they represent the most significant update to California’s AV rules since the state first began issuing testing permits more than a decade ago.
The noncompliance notice system is designed to sit within this larger architecture. The DMV’s annual mileage report already references law enforcement notices as part of its oversight framework, signaling that the agency views traffic enforcement data as a complement to the crash and disengagement statistics it already collects from manufacturers.
What no one knows yet
For all the regulatory scaffolding, key questions remain unanswered.
The DMV has not published data on how many noncompliance notices, if any, officers have actually issued. The form exists, the authority exists, but no public tally shows whether police departments are using the tool or which manufacturers have been cited. Without that information, it is difficult to assess whether the system is functioning as intended or gathering dust.
Equally opaque is what happens after a manufacturer receives a notice. AB 1777 requires a response, but no public records from Waymo or other AV operators detail what those responses contain, whether they trigger software updates, or how quickly any corrections follow. The feedback loop between a traffic violation and a tangible change in vehicle behavior has no documented track record.
Consistency across jurisdictions is another open question. Police departments in San Francisco and Los Angeles, where robotaxis are a daily presence, may develop training and internal protocols for issuing notices. Departments in smaller cities that rarely encounter autonomous vehicles may never use the form at all. The regulations outline what officers are authorized to do, but they cannot guarantee uniform enforcement statewide.
There is also no baseline data comparing AV violation rates before and after the regulations took shape, which means any claim about whether the notice system is reducing dangerous driving by autonomous vehicles would be premature.
Sourcing and limitations of this analysis
This article is based entirely on publicly available California state documents: the text of AB 1777, the DMV’s Initial Statement of Reasons, the agency’s public comment announcements, its annual AV testing mileage report, and its summary of new 2025 laws. It does not include original interviews with DMV officials, law enforcement officers, or AV manufacturers, nor does it draw on records obtained through public records requests or on-the-ground observation of enforcement activity. Readers should treat it as a secondary analysis of primary government sources rather than as original investigative reporting. Key claims about how the system will work in practice remain untested until the DMV finalizes its regulations and enforcement data becomes available.
What comes next for robotaxi enforcement in California
The practical test arrives when the DMV finalizes its regulations and the first wave of noncompliance notices moves through the system. The agency’s decision to create a dedicated form, establish mailing procedures, and integrate the notices into its reporting infrastructure suggests it expects active use once the rules are formally adopted.
For the robotaxi industry, the stakes are straightforward. Every notice creates a record that regulators, lawmakers, and the public can scrutinize. If manufacturers respond with meaningful software improvements, the system could become a model for other states grappling with how to police vehicles that have no human driver to hold responsible. If the notices pile up without visible changes in vehicle behavior, California legislators will almost certainly revisit the law and push for stronger consequences.
Either way, the era of driverless cars operating in a regulatory gray zone is closing. California has decided that when a robot breaks a traffic law, someone has to answer for it.
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*This article was researched with the help of AI, with human editors creating the final content.
