Análisis comparativo de marcos regulatorios en seguridad de vehículos autónomos: RSL

The accelerated adoption of autonomous vehicles (AVs) has driven the development of regulatory frameworks and technical standards aimed at ensuring their safe, ethical, and legal operation. This Systematic Literature Review (SLR) aims to analyze and compare major international regulatory frameworks related to autonomous vehicle safety, identifying strengths, weaknesses, and regulatory gaps. The review focused on studies addressing vehicles with SAE Levels 3 to 5 of autonomy, paying particular attention to applied legal and regulatory frameworks, as well as their effectiveness in mitigating risks and incidents. While no formal comparison was established, priority was given to works examining regional differences between Europe, the United States, and Asia. The bibliographic search followed a structured and rigorous process to select relevant, high-quality scientific literature. The identified studies address both functional safety—understood as the vehicle’s ability to operate without causing harm—and cybersecurity, focused on protection against digital threats and unauthorized access. The findings reveal a fragmented regulatory landscape with diverse regional approaches, where some countries (e.g., Germany) show significant progress, while others remain in developmental phases. The review underscores the need to harmonize standards and strengthen international legal frameworks by integrating technical, legal, and social perspectives. This research contributes to the academic and regulatory debate by offering a comparative analysis that may serve as a foundation for more coherent and effective public policies.