In its response to the Department for Transport’s Automated Passenger Services (APS) consultation, Open Road Access calls for accessibility and safeguarding to be built into the foundation of self-driving vehicle regulation.
London, UK — September 2025 — Open Road Access (ORA), the purpose-driven company redefining accessible mobility across the UK, has responded to the Government’s Automated Passenger Services (APS) Permitting Scheme consultation, urging ministers to ensure that accessibility, inclusion, and passenger safeguarding are non-negotiable principles in the rollout of self-driving passenger services.
The consultation, part of the implementation of the Automated Vehicles Act 2024, will shape how commercial self-driving services are licensed and monitored. ORA’s submission — led by Catherine Marris, ORA’s Director of Partnerships, Policy & Impact — warns that without early and explicit accessibility standards, automated transport could replicate or even worsen the barriers disabled and older people already face in traditional transport systems.
‘Autonomous vehicles could transform mobility — but only if they work for everyone,’ said Catherine Marris. ‘If accessibility is left as an afterthought, we risk building a high-tech transport future that excludes the very people who stand to benefit most.’
A Once-in-a-Generation Opportunity for Inclusive Design
The Automated Passenger Services (APS) scheme will create a new legal pathway for fully self-driving passenger services, sitting alongside traditional taxi, PHV, and bus regulation.
For ORA, the consultation represents a once-in-a-generation opportunity to ensure inclusion is embedded from the outset. The company argues that accessibility must not be left to voluntary good practice — it must be a statutory requirement of every APS permit.
ORA’s submission highlights the growing body of evidence from TRL, RiDC, Motability Foundation, and others showing that self-driving services introduce new accessibility risks: from boarding and alighting without human assistance, to communication with automated systems, and emergency evacuations without trained support staff.
To address this, ORA calls for:
- Mandatory co-design with disabled and older people in every pilot and service design phase.
- Evidence of accessible vehicles, including wheelchair accommodation, ramps or lifts, and adequate interior space.
- Accessible digital interfaces, including screen reader compatibility, alternative booking channels, and clear communication for passengers with sensory or cognitive impairments.
- Accessibility testing with real users in pilot phases to validate design and safety performance before scaling.
- Transparent accessibility metrics and data reporting, including usage, service refusals, incidents, and customer satisfaction.
‘Technology alone doesn’t guarantee progress,’ said David Dew Veal, ORA’s CEO. ‘It’s how we design, regulate, and deploy it that determines whether it’s inclusive. The APS scheme is a chance to set the global benchmark for equitable autonomous transport.’
Embedding Safeguarding and Human Support
ORA’s response also focuses on safeguarding and human assistance, identifying that even in fully automated services, some passenger needs cannot be met by technology alone.
Drawing on research by TRL and Motability, ORA emphasises the concept of ‘red roles’ — essential tasks such as helping a wheelchair user board, securing mobility aids, or providing reassurance and communication during emergencies.
ORA therefore recommends that APS permits explicitly require:
- Trained passenger assistants (either onboard or remote) who can provide assistance when needed.
- Clear policies and published data on how disabled and older passengers are supported during boarding, alighting, and emergencies.
- Accessible emergency procedures covering fire, breakdown, and medical scenarios, ensuring communication for passengers with sensory or cognitive impairments.
- Accessible complaints and incident-reporting systems, allowing disabled passengers to easily raise issues and see how they are resolved.
‘The safety case for automation must include the human experience,’ said Marris. ‘If an older passenger can’t safely get in or out of the vehicle, or doesn’t understand the interface in an emergency, then the service has failed its duty of care.’
Accountability Through Data and Transparency
ORA’s response strongly supports the Government’s intention to require permit holders to report on how their services meet the needs of disabled and older passengers — a statutory condition under the Automated Vehicles Act.
However, the company argues this duty must be robust, transparent, and meaningful. ORA recommends that accessibility reporting include:
- Disaggregated usage data by age and disability status.
- Rates of successful vs. denied booking requests.
- Incident data (e.g. assistance failures, mobility-aid damage, falls).
- Accessibility performance measures (e.g. ramp functionality, wait times, satisfaction levels).
- Independent auditing and public publication of results.
This data, ORA says, should not be treated as bureaucratic reporting but as a feedback mechanism for continuous improvement — enabling government, local authorities, and disability organisations to hold providers accountable.
‘Data drives improvement,’ said Dew Veal. ‘By measuring accessibility outcomes, not just technical performance, we can make sure self-driving services genuinely expand mobility, not restrict it.’
Accessible Design for Emergency Scenarios
In response to consultation questions about coordination with emergency services and traffic authorities, ORA calls for guidance that explicitly addresses how disabled passengers will be protected in emergencies.
Recommendations include:
- Scenario-based testing involving disabled and older users.
- Accessible communication systems — audible, visual, and tactile.
- Standardised emergency signage and access points for rescue personnel.
- Clear protocols for managing mobility aids and service animals.
These details, ORA notes, are critical for public trust and safety, and must be integrated into the permitting guidance from the start.
Smart Regulation for a Fast-Moving Sector
ORA supports the proposal for short initial permit periods (12–18 months) for early pilots, allowing accessibility performance to be tested and refined before full commercial rollout.
However, the company warns that longer-term permits (up to five years) should only be granted where there are clear accessibility conditions, interim audits, and reporting obligations in place.
In its response, ORA also endorses:
- No immediate permit fees, to encourage small and innovative accessible service providers to enter the market.
- Conditional renewal and suspension powers, allowing regulators to act if accessibility standards are not met.
- Strong data-sharing requirements, ensuring transparency on accessibility performance, not just safety metrics.
‘The Government’s approach is broadly sound,’ said Marris, ‘but success will depend on how accessibility is enforced over time. We must avoid creating a system where compliance is measured once and forgotten.’
From Pilot to Policy: Building the World’s Most Inclusive AV System
The UK has a global opportunity to lead not just in autonomous technology, but in autonomous inclusion. ORA’s response makes clear that success will require continuous collaboration between innovators, policymakers, and the disabled community.
‘Autonomous vehicles could be revolutionary for people who have been left out of traditional transport systems,’ said Dew Veal. ‘But that revolution will only be real if we design for everyone — from the earliest prototype to the final permit.’
ORA is calling for Government to fund and support pilot projects co-designed with disabled and older passengers, creating real-world testbeds for inclusive automation. The company also recommends the creation of an Accessibility Advisory Panel within the Department for Transport’s AV programme to guide standards, review data, and advise on enforcement.
A Call for Partnership
As part of its policy engagement, ORA continues to work closely with the Department for Transport, the British Standards Institution, and industry partners to advance inclusive mobility frameworks.
‘We want to help government make this work,’ said Marris. ‘Accessibility is not a constraint — it’s a catalyst for innovation. With the right standards and accountability, the UK can set a world-leading example of inclusive automation.’
‘ORA exists to prove that accessible transport can also be smart, sustainable, and commercially scalable,’ added Dew Veal. ‘We’re ready to collaborate with policymakers, technologists, and local authorities to make self-driving mobility a force for inclusion.’
About Open Road Access (ORA)
Open Road Access (ORA) is a purpose-driven innovation company transforming accessible transport and closing the UK’s transport accessibility gap. Its mission is to ensure that everyone can move freely, independently, and with dignity.
Founded in 2023, ORA combines technology, co-design, and community engagement to deliver scalable, flexible mobility solutions. Its flagship Wheelchair Accessible Vehicle (WAV) hire service offers nationwide coverage, flexible rental terms, and delivery direct to customers’ doors.
ORA aims to enable 15 million accessible journeys annually by 2030, redefining how accessible transport is conceived, designed, and delivered.
Website: www.openroadaccess.co.uk
Media contact: press@openroadaccess.co.uk
