Autonomous Vehicles

Considerations for Personal and Commercial Lines Insurers

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Executive Summary
Since the early 1960s the insurance industry has been a major force behind
the most significant advances in highway and vehicle safety including
electronic stability control requirements, seat belt use and automobile crash
worthiness. Now, autonomous vehicle (AV) technologies offer an opportunity
for us to advance another milestone in vehicle safety, going beyond keeping
people safe in a crash to avoiding the crash altogether.
According to the National Highway Transportation Safety Administration
(NHTSA) more than 32,000 fatalities occurred in the United States as a result
of vehicle crashes in 2014, with human error as a primary cause. Analysts
agree that Autonomous Vehicles (AVs) have the potential to dramatically
reduce human error and, therefore, the frequency of vehicle crashes. Savings
related to economic costs, including accident-related, fuel and productivity,
vary widely. McKinsey estimates savings at US$ 200bn US$ 1.9tr by 2025,
while Morgan Stanley puts savings at US$ 1.3tr.
In October 2010 Google publicly announced plans to develop automated
vehicle (AV) technology with the aim of preventing traffic accidents, reducing
carbon emissions and helping people make better use of time spent
commuting. Since then much has been written and reported with regard
to AVs, resulting in a wide range of estimates attempting to predict the timing
of their widespread adoption and quantify their impact.

Many AVs in development use a

combination of cameras, sensors,
GPS, RADAR, LIDAR and an
on-board computer. These
technologies work together to map
the vehicles position and its
proximity to everything around it.

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There are uncertainties: How will autonomous cars

perform amongst a mix of autonomous and
manually-operated vehicles? How will AVs impact people
whose livelihoods depend on driving, like truck and taxi
drivers? Will driving skills diminish and, if so, what will be
the impact to road safetyif any?
As the debate about the social and economic benefits
of AVs continues, the insurance industry is contemplating
the impact, particularly as it applies to liability exposures.
Who will be liable when an AV is involved in an accident?
Will liability shift from driver to manufacturer as vehicle
control shifts from human operator to autonomous
systems? Will accidentrelated liability exposure all but
disappear? How will we manage cyber liability exposures
that arise from the cameras, sensors and computers
integral to AV technology, or from vehicletovehicle
(V2V) and vehicletoinfrastructure (V2I) systems?

Our role as insurers is twofold: to enable a technology

that has the potential for significant positive impact on
vehicle and highway safety while also helping our clients
to recognize and manage the impact of AV technology on
their businesses. Insurers and reinsurers who understand
the issues will be in the best position to stay ahead of
market disruptions and capitalize on opportunities.
Working with a network of knowledge partners that
include research, industry and academic organizations,
combined with Munich Res vast knowledge network, we
aim to anticipate these changes, educate our stakeholders
and develop innovative insurance solutions to manage the
impacts of AV technologies for ourselves and our clients.

Besides liability, how will AVs impact the tools

underwriters use to evaluate risks? What new products
will be needed, both for traditional auto manufacturers
and suppliers faced with new risks and for new entrants
into the AV supply chain?
Regulation and legislation will also be important factors
for insurers as AV technology evolves. The Insurance
Institute for Highway Safety (IIHS) predicts that even with
a theoretical 2016 government mandate for some crash
avoidance and lanekeeping safely features, largescale
integration into the US fleet is almost 25 years away.
Some industry analysts warn of the risk that autonomous
technologies will impact insurers sooner than expected.

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Autonomous Vehicle Technology:

Evolution of Insurance Exposures
Analysts agree that autonomous vehicle technology has the potential
to create significant safety benefits by reducing driver error. There is
debate over the timeframe for complete integration of fully autonomous
vehicles on US roadways. However, data from tests conducted by IIHS
show vehicle safety systems that are considered the building blocks of
fully autonomous vehicles, have been successful at reducing accidents.

Source: iStock

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At the same time, AV technology could give rise

to new and potentially costly liability exposures with
characteristics that emerge along with the technologys
evolution from partially to fully autonomous.
With no historical data on which to base any firm
conclusions, our examination of these evolving exposures,
the parties that might be affected, and how the interested
parties might address these exposures is based on
reasonable assumptions regarding the technology, the
distribution channels used to get the product to market,
how the product will ultimately perform and how it will
be used by the consumer.

of the vehicle shifts from manual operator-controlled to

automatic computer-controlled, liability may shift from
the operator to the manufacturer of the technology. How
actual liability scenarios play out will, of course, be
decided by the courts on a case-by-case basis.
Therefore, our examination of exposures during
Levels 13, where the vehicle may be operated manually
or autonomously, focuses on vehicle operators. At Level 4,
where the vehicle operates in autonomous mode, we focus
on exposures to the manufacturer. We explore coverage
implications, liability, underwriting, and data and analytics
from these perspectives.

In addition, our analysis aligns with five levels of

automation outlined by NHTSA, in which vehicles operate
progressively more autonomously.
We believe the exposures will change over time as AV
technology is adopted by the public. In general, as control

NHTSAs Five levels of automation

(Level 0) No automation
The driver is in complete control of brakes, steering, throttle, and motive power at all times.
(Level 1) Function-specific automation
Automation of one or more specific control functions. Example: electronic stability control or pre-charged brakes
(Level 2) Combined function automation
Automation of at least two primary control functions designed to work in unison. Example: adaptive cruise control
in combination with lane centering
(Level 3) Limited self-driving automation
Full control of all safety-critical functions transitioned between driver and vehicle, depending on conditions
(Level 4) Full self-driving automation
Vehicle can perform all safety-critical driving functions for entire trip. Driver provides destination or navigation input,
but is not required for control at any time during the trip.
Source: National Highway Transportation Safety Administration, Preliminary Statement of Policy Concerning Automated Vehicles

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Six states and the District of

Columbia currently allow testing
of autonomous vehicles on public
roads. Many other states have
legislation at various stages of
development.
Source: Insurance Institute for
Highway Safety/Highway Loss
Data Institute

D.C.

Various requirements; testing up to

level 3; prohibits equivalent of level 4
Authorizes testing; requirements
are basic or undefined

Implications for manufacturers

To date, Arizona, California, Florida, Michigan, Nevada,
Virginia and the District of Columbia (D.C.) allow testing
of autonomous vehicles on public roads. Generally, test
vehicles are dual control and can be operated fully
automatically, or operated manually by the operator. Most
of the states require a licensed operator to be in the car
and ready to take over the controls at any moment.
Floridas and D.C.s laws provide liability protection for the
manufacturer. Other states draft legislation addresses
liability in various ways or not at all.
As AVs move out of research and testing environments
and into the consumer marketplace, consumer and
commercial insurance coverage will likely be impacted,
particularly liability coverage.
Liability increases with autonomous functionality
As public acceptance grows and AVs progress from
partially to fully autonomous, liability for loss caused
by the AV may shift from the operator of the AV to the
manufacturer of the AV technology. Assigning liability,
in turn, will likely hinge on whether the driver or the
component part/technology caused the accident, or
some combination of the two. Whether current
automotive product liability case law will apply remains
to be seen and outcomes difficult to predict. In any
case, it could be costly for manufacturers to defend
against lawsuits.
Assigning liability may be more complicated during
Levels 13, when the operator is more likely to be driving
the vehicle, than at Level 4 when the computer is likely
to operate the vehicle.

The exposure to liability may depend on the amount of

control allowed to the operator: the more autonomous
the vehicle, the more exposure to the manufacturer.
Operators of fully autonomous vehicles will need to make
sure that they maintain the AV properly and avoid
tampering with the AV operating system to avert
assertions of liability against them. How actual liability
scenarios play out will, of course, be decided by the courts
on a case-by-case basis.
Increased scrutiny leads to greater reputational risk
Recent surveys of public acceptance with regard to fully
autonomous vehicles indicate that while drivers would
consider purchasing AVs (especially if they could reduce
insurance premiums), many are skeptical that a computer
can make better decisions than a human behind the
wheel. Therefore, any serious loss involving an AV will
likely be carefully scrutinized and widely reported in the
news media, which presents a potential reputational risk
to the manufacturer of the technology.
Cyber liability exposures arise
The potential for hacking a vehicles computer system to
gain information or to cause injury or disruption presents
significant data security exposures. While those
exposures exist today, the auto industry has
acknowledged the growing potential for cyber security
threats as vehicles become more connected to each other
and to the Internet or other networks.
Liability exposures could arise, for example, from the
collection and storage by the AV systems of data and
personal information that is protected under state or
federal laws. The potential also exists for widespread
harm from hacking or cyber attacks.

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Currently, auto manufacturers require indemnification

from their downstream vendors and subcontractors
including dealerships, repair/installation facilities, etc.
This practice may be carried forward and extend to
autonomous vehicle manufacturers of the future,
however their vendors and subcontractors may change
as the technology evolves.
Liability shift may occur
During Levels 13, there may be little change in terms
of the necessary products liability and/or products
recall/withdrawal coverage to protect the manufacturers
interest. Traditional general liability coverages that clearly
distinguish parts and components the manufacturer
produces from those that are outsourced and that contain
products-completed operations coverage may prove to
be sufficient.
Additionally, vehicle manufacturers may require hold
harmless agreements with autonomous component
suppliers. A scenario in which the autonomous system
is bolted on to an existing production vehicle may be
no different from any new technology introduced into
a car today, i.e. new braking systems, new transmissions,
etc. If the technology can impact safe operation of the
vehicle, the manufacturer of the component may have
a traditional products liability and product recall/
withdrawal exposure.
The impact to liability will likely become more
apparent as vehicles transition to Level 4, when fault
may be more clearly attributed to the technology.
Since the autonomous system is operating the vehicle,
liability exposure may, in turn, shift from the operator
to the manufacturer.

Underwriting classes revisited

Underwriting for products liability and/or products
recall/withdrawal covers during this stage of the product
may be the same as for any other product. Currently class
codes exist for computer manufacturing and auto
manufacturing. However, since there is a computer
technology involved within the auto manufacturing
process, there is potential for a hybrid insurance
classification to be developed that contains features
of both classes.
Generally speaking, underwriters classify vehicle parts
into either critical or non-critical depending on their
function in the vehicle. For example, brakes are
considered a critical component whereas interior lights
would be considered non-critical. The computer
component that allows the vehicle to act independently
will likely become more critical and be classified as such,
especially as the vehicle becomes more fully autonomous.
Product knowledge ramps up
The underwriter will need some comfort level with
and understanding ofthe vehicles reliability and
functionality. In order to gain consumer acceptance,
AVs will need to handle situations like construction zones,
road and bridge closures, all weather conditions, and
more. But if, in certain conditions, the car will not function
autonomously, i.e. blizzard conditions, the underwriter
will likely want to have a complete understanding of those
conditions and their impact on vehicle operation.
The underwriter will also need to understand the shelf life
of the autonomous system and what diagnostics are in
place to keep the autonomous vehicle running as
intended, and will likely rely on those diagnostics to notify
the vehicle owner when the vehicle must be maintained
or, eventually, replaced.

Liability comparison
Level 1 Level 2 Level 3
As long as AV systems
and operator share
control, liability hinges
on determining which
was in control at the
time of an accident

Increased
reputational risk
New cyber liability
exposures

Level 4
Downstream
vendors and
contractors
liability emerges

AV systems control the

vehicle. Liability shifts
to manufacturers,
including downstream
vendors and contractors
Reputational risk levels
as AVs become
established
Cyber liability exposure
remains high

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Risk management considerations & recommendations

Any problems with the operation of the product would
likely be a setback to adoption of the technology. If losses
occur, it will likely be critical to determine whether the
vehicle was being operated by a human driver or the
AV system, since this technology may eventually impact
everyone who operates a vehicle on public roads. Media
coverage will likely be extensive as the technology evolves
from experimental to a consumer product.
Therefore, from a risk management perspective,
manufacturers should consider:
Creating simple and conclusive schemes to record
when the driver overrides the AV computer.
Reputational risk insurance coverage
as media focus on autonomous technology grows.
A disabling function as a response to any attempts
to alter or enhance the software.
Requiring hold harmless, defense, indemnification
and additional insured language on all contracts with
downstream vendors and sub-contractors.
Clearly defining maintenance procedures to be
followed by the operator. If the AV operating system
detects a problem that is not addressed by the owner,
it should disable autonomous functionality to prevent
potential loss.
Preventing the moral hazard that arises when the
operator has little or no exposure for a loss by
developing an insurance product that includes both
the manufacturer and the operator on the policy in order
to align the financial interests of the operator and the
AV manufacturer.

Implications for commercial and personal operators

By reducing accidents caused by human error, the
market for liability coverage, and perhaps the coverages
themselves, may be impacted significantly, not just for
manufacturers but also for vehicle owners and operators.
Personal auto insurance providers have publicly
acknowledged that advancements in vehicle technology
and safety features including the development of
autonomous or partially autonomous vehicles represent
a significant business risk.
Regardless of the impact on the size of the market for
liability coverage, participation in the liability market
may change significantly.
Liability shifts with autonomous functionality
As with manufacturer liability, responsibility for loss will
likely be assigned based on whether a human driver or
the AV system was operating the vehicle at the time of
loss. Exposure for loss may still be largely borne by the
owner/operator during Levels 13, as the vehicle will more
likely be controlled manually. No substantive change in
coverage for the driver/owner of the vehicle is anticipated.
At Level 4, the majority of responsibility will likely shift to
the manufacturer in circumstances where the operation
of the vehicle is handled solely by the AV system.
However, the operator may still be required to maintain
the vehicle, and liability could attach to the operator for
a loss arising out of a failure to maintain it properly.
There is also a potential for the vehicle to be considered
a permissive user or an agent of the operator, thus making
the operator responsible for a loss.
As with manufacturer liability, personal and commercial
liability ultimately will be decided by the courts on a
case-by-case basis and, as such, is difficult to predict
with certainty.

Image: Flickr/Steve Jurveston/CC BY 2.0

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Coverages shift with liability

As vehicle safety improves during Levels 13 of AV
development, traditional bodily injury and property
damage liability coverage as well as optional and
mandatory physical damage coverages, uninsured/
underinsured motorist coverages and personal injury
protection (no fault) coverages may not change
significantly. This is because it may still be necessary
to determine whether the driver, the component part/
technology, or some combination of the two, caused
an accident.
One may envision that any shift in the coverages,
may not occur until automation reaches Level 4.
During this phase liability to the operator or owner
may decrease significantly. Auto physical damage
coverage may increase due to costlier after market
replacement parts.
Development of this phase and the nature of insurance
coverages will likely be heavily regulated, perhaps
bolstering coverage requirements.
New coverage options may emerge
Physical damage covers are designed to protect the
vehicle owner from losses that cause damage to the
vehicle, including collision, theft or vandalism and other
perils. Some notable coverage considerations that may
emerge as vehicles add parts and systems that make
them more autonomous include:
Physical Damage Coverages (First Party)
Stated amount physical damage coverage: This
valuation method, which pays the lesser of actual cash
value, repair cost, or limit listed as a result of a covered
accident, may become more prevalent due to the
potentially high replacement and/or repair cost as a
result of an accident.

Custom equipment/furnishings: As the technology

evolves and less input from an operator of the vehicle
is necessary for safe operation, the living space of the
vehicle could start to resemble living quarters, complete
with entertainment systems and furnishings not
typically associated with a traditional auto.
Liability Coverages and Physical Damage Coverages
(Third Party and First Party)
Weather-related exclusions: Due to potential weatherrelated limitations of AVs on snow or ice covered roads,
insurers could implement weather-related operation
limitations and exclusions.
Radius of operation and road-type limitations and
restrictions: Insurance coverage may specify certain
distances or types of roads, such as public roads.
Failure to maintain or adhere to self-driving
AV protocols: Since these vehicles are highly technical
and complex, they will likely be held to rigorous
technical standards that may require maintenance
on a routine basis.
Cyber liability coverages: AVs employ wireless
communications systems to communicate with other
vehicles or networks. Manufacturers may need coverage
for the risks of cyber attacks, hacking, and breeches
of data privacy.
Resurgence of no-fault type coverage: If assigning
fault in an auto accident involving autonomous vehicles
proves difficult and time consuming, resulting in delays
in compensating injured victims of auto accidents, there
could be a resurgence of no-fault type coverage.

Exceptions to the mechanical or electrical breakdown

or failure exclusion: Traditional personal and
commercial auto policies generally exclude loss due and
confined to mechanical or electrical breakdown.
Revamping of the audio, visual and data electronic
equipment coverage exclusions: Traditional personal
and commercial auto policies generally exclude any
electronic equipment that reproduces, receives or
transmits audio, visual or data signals, with an exception
for equipment permanently installed. The original focus
of this exclusion was sound systems and
communication devices (i.e. citizens band radios,
cellular phones, etc), however, since visual and data
signals are a major component of AVs and will likely be
costly to replace, revisions to the exclusion are likely.

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Tools of the trade may change

Underwriting tools will also likely be impacted as AVs
become more common. Todays underwriter relies on
a number of tools to evaluate a risk. One such resource,
a drivers motor vehicle record (MVR), is very important
when underwriting an account requiring automobile
insurance. As manually operated vehicles (MOV) and AV
technologies merge, will certain infractions shown on an
MVR be seen more frequently? Will others decline? Is a
traffic violation such as running a red light treated
differently for an MOV versus an AV? Until vehicles
become completely autonomous, MVRs will likely remain
a key tool in analyzing the exposure any driver presents.
Just as certain losses among todays MOVs may lead
an underwriter to decline an account, the same will likely
be true of AVs in the fleet of the future. Is a fender-bender
between two MOVs different from one between two AVs?
What if, when MOV meets AV, the AV is at fault? Does this
claim indicate a systemic problem that the underwriter
should analyze further? Careful observations and analysis
of any emerging trends will be critical to expanding or
restricting the underwriters appetite.
Like any new technology, the cost of repair or replacement
is typically higher initially which, in theory, will increase
the cost of coverage. However, this will likely be offset
by the drop in frequency of claims. Over time the cost
to produce the technology should decline. In the long run,
many analysts agree that safer roads will likely lower the
cost of insurance significantly.
Data remains key
Industry analysts seem to agree that an AV will be
inherently safer than a MOV and, as such, would generate
a lower frequency of crashes. Assuming severity remains
stable or declines, pure premium (the product of
frequency and severity) would decline and it would cost
less to insure the vehicle.
However, in order to properly determine how much
safer an AV is and to calculate the appropriate insurance
premium, one needs to analyze a sufficient sample
of accurate historical data to compare to MOVs.
Recent advances in telematics systems, which record
driver behavior and other data electronically, offer
new and more reliable sources of data compared to
driver-reported information. In order for these new data
to successfully translate safety enhancements into lower
insurance rates there must be a sufficient amount of
quality data available for analysis.

Telematics systems provide new data that can be used

to price auto insurance more accurately. These data points
recorded by and accessible from the AVs system can be
analyzed and potentially used in rating.

Miles driven
More time on the road indicates higher
risk of loss. A subset of this may be
miles driven in AV mode versus
miles in operator mode. Fewer miles
driven in AV mode may require the
insurer to revert to more traditional
rating of the operator.
Time of day
Regular driving in heavy (or light)
traffic could impact a risks rating.
Location
Analysis of location data may be
blocked by regulators concerned about
privacy. Location might also include
the percentage of driving time spent
on mapped vs. non-mapped roads.
Speed
Instances of excessive speed could
be recorded via GPS information.
Driver identification
Even with telematics it is difficult to
know who is really driving the vehicle
and it matters to insurers whether
parents or their young drivers are
behind the wheel.
Hazards/Near-misses
Validation of how well the AV avoids
hazards that a human would not avoid
could support claims that AVs are safer
and lead to lower insurance rates.
Weather data
Knowing what driving conditions were
like at the time of an accident could
help with claims handling.

Crash sensor data

Sensor data that can be used to
re-construct a crash can also be
useful in determining fault.

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Data quantity. A sufficient number of road miles

should be logged in order to create a credible data set
for analysis. What is sufficient? A large auto insurance
company can easily rely on a historical data set of
100150 billion miles driven to produce credible results.
Small insurance companies typically dont have that
quantity of data, and will likely pool their experience data
(with the Insurance Services Office, for example) to create
data sets large enough to perform credible analysis.
Data availability. A number of regulatory practices may
need to change in order to realize the full impact of AVs
on insurance. Regulators currently prohibit insurers from
using certain data in their rating models, including
location, speed, or other data considered private. This
limits the usefulness of the data captured by the AV.
The more insurance companies must rely on traditional
pricing information, the more insurance is likely to remain
the same.

Shared vehicles
The future of autonomous vehicles goes beyond
individual vehicle owners to shared vehicles, and to
fleets of autonomous vehicles that include cars, trucks,
and public transportation. Shared AVs, for example,
could be available for rental on an as-needed basis.
Insurance might be included as part of the price of rental,
thereby easing consumers into the idea of the
autonomous functionality in a more economically feasible
manner than purchasing a fully autonomous vehicle.

Source: US DOT

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Social acceptance
Active safety technologies
will ease acceptance of fully
autonomous vehicles.

Legislation and oversight

Insurance regulation will focus
on privacy and preventing
adverse selection.

Outlook: Many factors will temper development

Development of all of these visions could be impacted
by a host of social, economic and regulatory factors
that make the timing of a shift to fully autonomous
vehicles and the insurance implications of that shift
difficult to predict.
Social acceptance
Surveys show the majority of people would not purchase
an autonomous vehicle if it were available today, yet they
would be willing to spend a little more equipping their
next vehicles with features like crash avoidance and
lane-keeping systems that are the building blocks of
tomorrows fully autonomous vehicles. It seems the
general population isnt ready to give up control of their
vehicles or trust that a computer might make better
decisions at the wheel.
Even with a theoretical 2016 government mandate
in place, IIHS predicts vehicles equipped with
crash-avoidance and lane-keeping systems would
not reach 95% of fleet penetration until 2039.

Level 4
Acceptance

Economic disruption
Personal lines insurers, professional
drivers and accident economies will
be affected.

Driverless vehicle laws and legislation for US states

is compiled periodically by the American Insurance
Association. To date, enacted legislation has focused
on testing of AVs on public roads rather than envisioning
AVs in the consumer marketplace.
As AVs get closer to the public, lawmakers will likely
pay close attention and introduce legislation designed
to protect the public across a wide range of AV impacts,
including licensing and certification of vehicles,
infrastructure, cyber security and, of course, safety
standards. In insurance, regulators may seek to prevent
adverse selection and moral hazards, protect privacy
and personal information. Litigation associated with
determining liability will also likely lead to legislation.
As laws are changed, insurance coverages will likely
change to meet the needs of customers.
In any case, insurers will likely be impacted, and those
who remain informed on autonomous vehicle issues will
be better positioned to manage that impact successfully.

Legislation and oversight

NHTSA has outlined its position in its paper Preliminary
Statement of Policy Concerning Automated Vehicles.
The organization is currently engaged in evaluating safety
and setting standards for in-vehicle safety features like
automated breaking systems. It has also issued a set of
recommendations for states seeking guidance on safe
testing of AVs on public highways. These
recommendations include provisions for licensing and
testing of vehicles and their operators as well as data
recording. Besides studying safety related to electronic
control systems, performance requirements and human
factors, NHTSA intends to issue a baseline set of
requirements to ensure cyber security in AVs.

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Sources
Gorzelany, James. 2013. Most consumers say theyll steer clear
of self-driving cars, survey says.
February 23.
Insurance Institute for Highway Safety/Highway Loss Data
Institute. 2015. Which states regulate testing on public roads?
November.
McKinsey & Company. 2013. Disruptive technologies: Advances
that will transform life, business, and the global economy.
May.
Morgan Stanley. 2013. Autonomous cars: Self-driving the new
auto industry paradigm.
November 6.
National Center for Statistics and Analysis. 2015. Early estimate of
motor vehicle traffic fatalities in 2014. DOT HS 812 160.
Washington, D.C.: NHTSAs National Center for Statistics and
Analysis.

Vallet, Mark. 2014. Autonomous Cars: Will you be a co-pilot

or a passenger?
July 28.
Zuby, David. 2014. Do smart cars equal safer roads?
July 29.
Munich Re contributors
Specialty Markets:
Christopher Amendo
Paul Hamm
Jim Kelly
Lauren Maerz
John Willemsen
New Strategic Markets:
Michael Scrudato
Underwriting Services:
Gerard Finley

Schoettle, Brandon and Sivak, Michael. 2014. A survey of public

opinion about autonomous and self-driving vehicles in the U.S.,
and the U.K. and Australia.
July.
US Department of Transportation. National Highway Traffic
Safety Association. 2008. National motor vehicle crash causation
survey. DOT HS 811 059. Springfield, VA: National Technical
Information Service.
US Department of Transportation. National Highway Traffic
Safety Association. 2013. Preliminary statement of policy
concerning automated vehicles.
May 30.

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