The Trump administration has proposed removing a federal safety requirement that all vehicles must include a manual brake pedal — and it's a move designed specifically to clear the runway for self-driving cars that will never have a human driver in the seat.
The National Highway Traffic Safety Administration (NHTSA) filed a notice of proposed rulemaking on June 25, 2026, targeting Federal Motor Vehicle Safety Standard No. 135 — the regulation that currently requires every car sold in the United States to have foot-operated brake controls. Under the proposal, vehicles "designed to be driven exclusively by automated driving systems" would be exempt from that requirement entirely. The public has 30 days to submit comments before the agency decides whether to make it permanent.
"We are at the cusp of the greatest technological revolution in vehicle technology since the innovation of the Model T."
— Jonathan Morrison, NHTSA Administrator
What FMVSS No. 135 Is — and Why It Matters for AVs
FMVSS No. 135 sets the braking performance standards for all passenger vehicles sold in the US. It mandates not just that brakes work, but that they're operated by foot-controlled pedals. That standard made perfect sense when every car was driven by a human. For a robotaxi with no steering wheel and no pedals, it's a regulatory wall.
Until now, any company building a purpose-built autonomous vehicle without standard controls had to petition the federal government for an individual exemption. The exemption process is slow, capped at small volumes, and creates a vehicle-by-vehicle approval gauntlet that prevents scaled commercial deployment. This rule change would remove that barrier outright for fully autonomous vehicles — replacing the pedal requirement with a performance-based alternative: the same stopping distance and braking criteria, just achievable by whatever hardware and software the AV developer chooses to use.
What changes under the proposed rule
- Removed: The requirement that brake controls be foot-operated pedals
- Kept: All stopping distance and braking performance standards — same safety bar, different method
- Who it covers: Vehicles designed exclusively for automated driving — no human controls at all
- Who it doesn't cover: AVs with manual backup controls (steering wheel, pedals) still follow existing rules
- Next step: 30-day public comment period before the rule is finalized
Who Benefits Most: Tesla Cybercab and Zoox
The Cybercab is the most obvious winner. Tesla has spent years developing its two-seat robotaxi with no steering wheel and no pedals — and has explicitly refused to apply for individual exemptions, betting instead that the regulatory framework would eventually catch up. Tesla CEO Elon Musk has said repeatedly that broad regulatory approval, not exemptions, is how the Cybercab will reach scale. This proposal, if finalized, gets Cybercab significantly closer to that outcome.
Zoox — the Amazon-owned AV startup — already holds an exemption from FMVSS requirements for its custom-built robotaxi. It's been using that exemption to run demonstrations in select cities and is now waiting on a second exemption to operate commercially. A rule change like this would simplify Zoox's path considerably, eliminating the need for the exemption process going forward.
Waymo, by contrast, is less directly affected. Its vehicles are retrofitted versions of production cars — the Jaguar I-Pace — which already have standard controls. Because those vehicles pass existing FMVSS requirements as-built, Waymo can deploy as many vehicles as it wants without the exemption process. Purpose-built designs without pedals are where the old rules created friction, and that's where this fix is targeted.
30
Days the public has to comment before NHTSA decides on the rule
135
The Federal Motor Vehicle Safety Standard number being updated
2
AV companies most directly impacted: Tesla Cybercab and Zoox
Part of a Bigger Push to Deregulate AV Rules
This isn't the first regulatory rollback aimed at clearing the path for autonomous vehicles. Late last year, NHTSA proposed removing FMVSS requirements around windshield wipers, defoggers, and tire placards for vehicles that will never be operated by humans. The Biden administration had already moved in this direction too — it finalized a rule allowing AVs to operate without steering wheels at all, a precursor to today's proposal on brake pedals.
The pattern is consistent: rules designed for human-operated vehicles are being reconsidered one by one for the subset of autonomous vehicles that will never have a human in control. NHTSA Administrator Jonathan Morrison framed the brake pedal proposal as part of this broader effort under DOT Secretary Sean Duffy's "AV Framework" — a push to clear outdated regulatory barriers while simultaneously developing new real-world performance requirements specifically for autonomous systems.
What this doesn't change
- Any AV that includes manual controls (pedals, steering wheel) still has to meet all existing FMVSS standards
- The braking performance bar — stopping distance, reliability — stays exactly the same
- NHTSA is separately developing new AV-specific real-world safety standards that haven't been released yet
- State-level AV laws still apply — federal rule changes don't override state deployment restrictions
What It Means for the AV Industry
The exemption system that existed before this proposal technically allowed companies to build pedal-free AVs — but only in small numbers, only after a lengthy approval process, and only for specific demonstration purposes. Scaling a commercial robotaxi fleet under that framework was essentially impossible. You'd need an exemption renewal for every significant change to the vehicle design.
A rule change that simply removes the pedal requirement for fully autonomous vehicles transforms that calculus. Companies can design, build, and deploy at commercial scale without working through a federal approval gauntlet for each step. Tesla in particular has been publicly waiting for this kind of structural clearance — not a one-off exemption, but a regulatory environment where the Cybercab design is inherently legal without special permission.
The 30-day comment period is a formality in the sense that the direction of travel is clear, but it matters: critics who argue that removing the pedal requirement weakens safety — or that the AV industry isn't ready for this level of trust — have a formal window to make their case. If opposition is strong enough, NHTSA could modify the proposal before finalizing it.
The bottom line: NHTSA's proposal to remove the brake pedal mandate for fully autonomous vehicles is the clearest federal signal yet that purpose-built robotaxis — with no steering wheel, no pedals, no human controls — are on a path to legal commercial deployment in the US. The safety bar doesn't change. The barrier to designing around it does. For Tesla's Cybercab and Zoox, the regulatory logjam just got significantly smaller.