Analysis of Insurance Liability Division Solutions for Changan Automobile's L3-Level Autonomous Driving

Based on the latest collected information, I will provide a systematic analysis of the insurance liability division solutions for Changan Automobile’s L3-level autonomous driving.

On December 15, 2025, the Ministry of Industry and Information Technology (MIIT) officially announced access permits for China’s first batch of L3-level conditional autonomous driving models, with Changan Deep Blue SL03 and Arcfox Alpha S being the first two models to obtain the qualification for “legal road access” [1]. Among them, Changan Automobile has obtained China’s first special license plate for L3-level autonomous driving, “渝AD0001Z”, and is approved to conduct road trial operations on designated sections such as Chongqing’s Inner Ring Expressway and New Inner Ring Expressway, with a maximum speed not exceeding 50 km/h [2].

In accordance with the national standard “Classification of Automobile Driving Automation” and relevant pilot policies, liability determination for L3-level autonomous driving accidents is mainly divided based on

[3]:

Within the Operational Design Domain (ODD) — including operation in limited scenarios or designated sections — if an accident is caused by vehicle system failures, algorithm defects, or hardware issues, such as technical malfunctions like misjudgment by the perception system or failure of the decision-making algorithm, the automobile manufacturer shall bear primary liability and fulfill corresponding compensation obligations [3]. This means:

• Liability Subject Transfer
  : In scenarios where the autonomous driving system fully takes over dynamic driving tasks, the liability subject has been partially transferred from the driver to the vehicle manufacturer [3]
• Data Black Box Support
  : Currently, all L3-level autonomous driving models are equipped with data recording devices (Event Data Recorder, EDR), which will play a key role in accident liability tracing [3]
• Technical Redundancy Guarantee
  : Changan Deep Blue SL03 has built a safety moat through over 400,000 simulated test scenarios and over 5 million kilometers of road tests (36% of which are extreme scenarios) [4]

When operating beyond the designated scope or when the driver fails to perform their duties, another set of standards applies to liability determination [3]:

• Failure to Respond to Takeover Requests
  : If the driver fails to respond promptly after the system issues a takeover request
• Operating Beyond Design Conditions
  : Using the autonomous driving function in non-pilot sections, severe weather, or other conditions beyond the design operating conditions declared by the vehicle manufacturer

Ping An Property & Casualty Insurance Chongqing Branch has developed a

for L3-level autonomous driving vehicles, providing a for the targeted autonomous driving models [5]. This product plan precisely covers:

• Risks of autonomous driving system defects
• Software risks
• Comprehensive system risks such as cybersecurity
• Full-range intelligent driving scenarios including automatic parking, city navigation assist, and highway navigation assist [5]

Ping An Property & Casualty Insurance Chongqing Branch has implemented an

for insurance liability determination for different levels of intelligent driving, which can accurately define insurance liability for accidents in “human-machine co-driving” scenarios [5], providing comprehensive protection for:

• Rights and interests of vehicle manufacturers (system providers)
• Rights and interests of drivers and passengers
• Rights and interests of third parties [5]

A forward-looking “intelligent driving insurance” model has emerged in the industry [4]:

• Huawei HarmonyOS Intelligent Mobility has launched the “Intelligent Driving Assurance Service Benefits” for AITO models
• Ping An Property & Casualty Insurance and Seres jointly launched the industry’s first intelligent driving protection service plan
• The maximum coverage amount reaches millions of RMB, with prerequisites such as “intelligent driving function was activated at the time of the accident and the vehicle is liable” [4]

Chongqing Changan Connected Car Technology Co., Ltd. serves as the operating entity for Changan Automobile’s L3-level autonomous driving models, conducting batch road trial operations in designated areas [6]. A fleet-based, professional management model is adopted to reduce uncertainties in the initial implementation of L3-level conditional autonomous driving.

Changan Automobile has established a comprehensive safety guarantee mechanism based on its self-developed “TIANSHU Intelligence” technology system [7]:

• Multi-sensor fusion environmental perception solution
• Strict operating condition restrictions (speed below 50 km/h, designated sections)
• Full-link safety redundancy design
• Comprehensive data recording and tracing system

According to Changan Automobile’s plan [8]:

• Q1 2026: Conduct road trial applications with the user entity Changan Connected Car Technology
• L3-level autonomous driving in urban areas is expected to be implemented in 2026
• After the official release and implementation of relevant national laws and policies, product access and market launch for C-end users will commence

• Complexity of Liability Subjects
  : Shifting from the past driver-centered model to multi-subject liability division among humans, autonomous driving systems, vehicle manufacturers, and suppliers [9]
• Difficulty in Data Acquisition
  : Insurance companies find it difficult to accurately assess risks without access to vehicle manufacturers’ data [9]
• Outdated Pricing Models
  : The institutional foundation of traditional auto insurance, which centers on individual liability, has been impacted [9]

• Technical Aspect
  : Establish a comprehensive data black box system to accurately reconstruct key facts such as whether the function was activated at the time of the accident, whether it was operating within design conditions, and whether the system issued a takeover prompt [9]
• Regulatory Aspect
  : The pilot notice jointly issued by four ministries and commissions requires that user entities must have the ability to bear civil liability, and losses shall be mainly compensated through insurance channels [3]
• Legal Aspect
  : Local legislation in Beijing, Shenzhen, and other regions further clarifies the right of vehicle manufacturers to recover compensation from system developers or equipment suppliers after assuming compensation liability [3]

With the maturation and promotion of L3-level autonomous driving technology, the insurance liability division system will continue to be optimized [3]. Industry experts stated that future liability determination systems will focus more on

, providing a reliable basis for accident investigations through complete records of vehicle operating status. Meanwhile, as technology advances, liability determination standards will continue to be adjusted to meet the development needs of the intelligent transformation of the automotive industry.

The establishment of this liability determination standard marks the gradual improvement of China’s autonomous driving accident handling mechanism. From technical guarantees to legal support, from insurance claims to liability tracing, a complete institutional system has taken initial shape, providing a solid foundation for the high-quality development of the intelligent connected vehicle industry.

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[1] Securities Times - China’s First Batch of L3-Level Autonomous Driving Models Approved for Road Trials, Marking a New Stage in Commercial Exploration

[2] Xinhua News Agency - China’s First Special License Plate for L3-Level Autonomous Driving Issued

[3] Auto Complaint Network - L3-Level Autonomous Driving Accident Liability Determination Standards Released, Vehicle Manufacturer Liability Becomes the Norm

[4] 36Kr - The Era of L3 Autonomous Driving Has Arrived: Putting Aside Parameters, I Only Want a “Liability Bearer”

[5] Xinhua News Agency Chongqing Channel - Ping An Property & Casualty Insurance Chongqing Branch Guarantees the Smooth Operation of the First Batch of Target L3-Level Autonomous Driving Vehicles

[6] Jiemian News - First Batch of L3 Models “Legally on the Road”: Can China’s Autonomous Driving Usher in Its “ChatGPT Moment”?

[7] OFweek New Energy Vehicle Network - 2025 Unmanned Driving Observation (1): “Admission Ticket” for L3-Level Autonomous Driving Issued

[8] The Beijing News - L3-Level Autonomous Driving Models to Start Road Trials in Q1 2026: Is Mass Production Still Far Off?

[9] The Beijing News - Auto Insurance Faces L3: Autonomous Driving Arrives, Liability Division for Claims Becomes “Challenging”