5GAA response to the MoRTH draft notification introducing V2V requirements for type approval of L, M, N category vehicles in India 

5GAA would like to thank MoRTH for the opportunity to comment on the draft notification introducing V2V requirements for type approval of L, M, N category vehicles in India.

5GAA applauds the Government of India’s commitment to improving road safety and accelerating the deployment of connected vehicle technologies. 5GAA welcomes the objective to establish a regulatory framework that enables interoperable V2X services and contributes to safer and more efficient transport systems.

5GAA strongly supports the development of a standard that establishes interoperable implementation of V2X applications in India. In this context, 5GAA congratulates MoRTH and TEC (Dept. of Telecommunication) on the progress made in the Task Force on ITS and endorses that the proposed standardization activity will carry forward with the agreements on ETSI TC ITS Rel 2 stack with 20 MHz for LTE-V2X Direct as a starting point.

The proposed mandatory fitment is closely linked to compliance with AIS-230, a standard that is still under development and not yet finalised [1]. 5GAA recognizes that category-L may need additional consideration in the AIS-230 standard development. 

5GAA therefore encourages a multi-phased deployment approach that considers the time required for finalisation of technical specification, product development, testing, certification, validation, security credential management system readiness, supply chain preparation, broad availability of hardware and software and vehicle production planning.

As an initial basis for discussion, 5GAA suggests:

1. Maintaining the proposed voluntary deployment milestone of 1 October 2027 for vehicle categories L, M and N that are voluntarily equipped with V2V technologies. This first phase provides an opportunity to gather real-world deployment experience under Indian traffic conditions and learn from coordinated initial large-scale deployment, with particular attention to category L vehicles.

• Maintaining an initial milestone of 1 October 2028 to introduce the mandate for V2V. Consideration should be given on a stepwise approach, potentially suggesting multiple milestones with a split between new type-approved vehicles and new manufactured vehicles, as well as, differentiating the timelines between vehicle categories. The timelines should take into account the finalisation of AIS-230, the outcomes of the initial large-scale deployment (especially for L-vehicle category) and the readiness of the broader V2X ecosystem, including interoperability, certification and security credential management.

• Clarifying the fitment of aftermarket devices, which has a clear potential role to accelerate the penetration rate of V2V-equipped vehicles, especially on legacy fleet, during a transition period.

This multi-phase approach would preserve the momentum created by the proposed voluntary deployment milestone while providing manufacturers with the regulatory certainty and lead time needed to develop, validate, certify and industrialise compliant solutions at scale. In particular, given that AIS-230 is under active development, industry would need some time following its finalisation to transpose the specifications into future vehicle programmes.

From 5GAA’s global experience, connected vehicle deployment typically include both direct and network V2X solutions and is accompanied by complementary digital road and data platform policy initiatives. 5GAA encourages India to consider complementary policies to support the broader ITS and road safety data-sharing adoption and maximise the benefits of connected mobility.

5GAA remains committed to supporting the Government of India and relevant stakeholders in developing a practical, interoperable and scalable deployment roadmap for V2X services.

[1] Subject to be “amended from time to time” as mentioned in the proposed G.S.R. 665(E).