This paper provides a focused academic response to the Public Consultation Paper (PCP) for the Development of Malaysia's Autonomous Vehicle (AV) Roadmap. It recommends that crashworthiness, injury evidence and post-crash safety be included as core elements of the national AV Roadmap, alongside crash avoidance, automation technology, infrastructure readiness, data governance and regulation.
Autonomous vehicles are often presented as technologies that can prevent crashes through sensing, connectivity and automation. However, AVs will still operate in a complex real-world environment involving conventional vehicles, ADAS-equipped vehicles, motorcycles, pedestrians, cyclists, buses, trucks, children, elderly users and persons with disabilities. Crashes may still occur due to mixed traffic, infrastructure limitations, system boundaries, environmental conditions, false positives, false negatives, human interaction and operational design domain limitations.
Malaysia therefore needs an AV Roadmap that addresses two safety questions:
1. How can AVs prevent crashes?
2. How can Malaysia reduce injury severity when crashes still occur?
The second question requires a dedicated crashworthiness and injury evidence strategy. This submission recommends that MOT and MIROS adopt a safety-first AV Roadmap that includes:
(refer attach file: Proposal_PCP_AV_Crashworthiness

I strongly support Malaysia approving a clear Autonomous Vehicles Roadmap. Autonomous driving is no longer just a future concept. Tesla’s Full Self-Driving Supervised, Waymo robotaxis in the United States, and autonomous vehicle trials in China, Europe and the Middle East show that the world is already moving in this direction.

The safety potential is significant. Tesla reports that its FSD Supervised system is measured through large-scale real-world fleet telemetry and collision reporting. Waymo has already recorded large-scale rider-only driverless operations and reports 82% fewer injury-causing crashes, 83% fewer airbag-deployment crashes, and 92% fewer serious injury or worse crashes compared with human-driver benchmarks in its operating areas.

Malaysia has serious road safety challenges, including crashes caused by fatigue, distraction, speeding and human error. Autonomous vehicles are not perfect, but with proper regulation they can become an important tool to reduce risk, improve logistics efficiency and modernise public transport.

The government should approve the roadmap in stages, starting with controlled pilot zones, logistics and industrial park trials, public transport pilots, cybersecurity rules, insurance guidelines, mapping standards and independent safety audits.

Malaysia should not wait until the technology is fully mature overseas. We should learn early, regulate safely and build local capability in AI, EVs, sensors, software and smart mobility.

I am writing in response to the ongoing public consultation on Malaysia’s Autonomous Vehicle (AV) Roadmap. I strongly support the Government’s effort to develop a clear, phased, and safety-driven national strategy. However, I wish to highlight a critical concern that must be addressed in the final roadmap.
Malaysia continues to suffer a high number of road traffic fatalities and injuries every year. With capable, supervised autonomous driving systems already proven in real-world conditions and available for large-scale deployment today, any unnecessary delay in adopting these technologies comes at a direct human cost.
Proven technology exists today
Systems such as Tesla’s Full Self-Driving (Supervised) have already demonstrated strong safety performance in multiple countries, with collision rates significantly lower than the average human driver based on billions of kilometres driven. The Netherlands, Denmark, Lithuania, Estonia, and regions in Belgium have approved supervised FSD following rigorous testing. These approvals show that mature Level 2+ supervised systems can be safely introduced without waiting for fully driverless (Level 4/5) technology.
The cost of waiting
Malaysia does not need to wait for domestic players to independently develop equivalent technology from scratch. While nurturing local industry is important, doing so at the expense of delaying proven safety-enhancing systems will result in preventable deaths and injuries on our roads. Every month of delay means more Malaysian families lose loved ones in accidents that advanced driver assistance and supervised autonomy could help reduce.
Malaysia can and should move independently
Malaysia operates under non-European UNECE regulations and has its own regulatory authority through JPJ and MOT. We are not bound by the slower decision-making processes seen in some other regions. Other countries have successfully adopted national or regional approvals for supervised systems while continuing to support local development in parallel. Malaysia can do the same.
Recommendations for the Roadmap
I respectfully urge the Government to include the following in the final AV Roadmap:

Fast-track evaluation and approval of proven supervised autonomous systems (such as Tesla FSD Supervised) based on existing international safety data and local validation, rather than requiring full domestic redevelopment.
Establish controlled national or regional pilots for supervised AV technology on selected highways, urban corridors, and low-risk routes as soon as possible. This will allow Malaysia to gather local data, build regulatory experience, and improve road safety without waiting years.
Adopt a pragmatic, evidence-based approach that prioritises reducing road deaths and injuries in the near term, while supporting local industry development as a parallel long-term goal.
Ensure the roadmap distinguishes clearly between supervised systems (which still require an attentive driver) and fully driverless operations, allowing faster progress on the former.

Malaysia has a real opportunity to become a forward-thinking nation in mobility by embracing proven technology responsibly and quickly. Delaying action while capable systems exist elsewhere is not a neutral decision — it carries a human cost that our roads and families cannot afford.
Thank you for considering this submission. I am happy to provide further data or participate in any follow-up discussions.

Malaysia’s road traffic has more cars than people. Accelerating autonomous driving technology for commercial use would greatly reduce congestion, unnecessary waste, and improve safety.
I recommend Tesla’s Robotaxi and FSD—it looks very safe and can solve the problem quickly.

Autonomous driving is not just a technology trend — it represents a major transformation in the future of transportation.
If Malaysia plans to implement autonomous driving policies in the future, I believe the government should not only focus on technological advancement, but also strengthen road infrastructure, legal accountability, safety standards, and data governance mechanisms.

Malaysia’s road conditions, driving culture, and traffic environment are different from those in many Western countries. Therefore, it may be more practical to begin with limited pilot zones, such as industrial areas, logistics hubs, airport shuttle routes, or selected highways, before expanding nationwide.

At the same time, public education and awareness are equally important. People need to better understand how autonomous driving systems work, including both their benefits and potential risks, in order to build public confidence and acceptance.

Technology development should not simply be about “keeping up with the world,” but about creating solutions that are truly suitable for Malaysia.

Hope future autonomous driving policies will ultimately achieve the following: improving efficiency, reducing accidents, enhancing mobility, while ensuring the safety of the people.