Traficom assesses the approval of Tesla’s FSD (Supervised) system in Finland

Tesla’s driver assistance system FSD (Supervised) received national provisional type-approval from the Dutch type-approval authority RDW on 10 April 2026.

The Dutch national approval has launched a procedure that allows new technologies or technical solutions to be placed on the market even if they are incompatible with established requirements. Under the procedure, the applicant must demonstrate that the new technology or solution offers at least an equivalent level of safety and environmental protection to the current requirements.

As a rule, this kind of approval may be granted with the authorisation of the European Commission. The decision on authorisation is made in the Technical Committee – Motor Vehicles (TCMV), which operates under the Commission and votes on the matter. The application is either approved or rejected by a weighted qualified majority. Finland is represented in the committee by the Finnish Transport and Communications Agency Traficom, coordinated by the Ministry of Transport and Communications. The vote is expected to take place in October 2026.

Member States, such as Finland, may recognise the national approval before the committee vote if they so wish. By mid-June 2026, a few Member States had used this option. In Finland, Traficom may decide on whether to recognise the approval.

“Traficom has been actively assessing the national approval granted by the Netherlands and has discussed the matter with both the manufacturer and the Dutch approval authority. However, our examination is still ongoing and Traficom has not yet been able to decide whether to recognise the approval in Finland,” says Senior Specialist Jukka Juhola.

Key features of FSD (Supervised) and the driver’s role

The key difference between Tesla’s system and the driver assistance systems already on the market is that, when active, it does not require the driver’s continuous physical participation in driving.

Similar systems can already be placed on the market under current legislation. They can also support driving by performing steering movements, but they require the driver to keep their hands on the steering wheel. In addition, it is already possible to approve a driver assistance system for motorway conditions that allows the driver to take their hands off the steering wheel.

Tesla’s system also deviates from current legislation in that its speed control may use a contextual speed setting. This means that the vehicle’s speed adapts to other traffic if the speed limit detected by the system is uncertain or inaccurate.

In addition, the approval includes individual exemptions that are due to the fact that current legislation does not fully apply to an end-to-end system that operates as a single entity instead of separate parallel systems or functions.

This is not an automated driving system, and a car equipped with such a system is therefore not self-driving, as the driver must remain alert and ready to take control of the car immediately and at the right time.

“Active monitoring and intervention by the driver are the system’s primary means of risk management. The system monitors the driver’s attentiveness and ensures that they are able to take control of the car if necessary,” Juhola says. 

The system approval currently under consideration applies to Tesla models equipped with the latest-generation hardware. There are around 6,500 such vehicles in Finland.  These cars are approximately two years old. You can check your car’s hardware generation on its information display and obtain further information from the manufacturer. 

For older cars, the manufacturer has not initiated a corresponding procedure.

Safety benefits and assessment in Finnish conditions

The system is marketed on the basis of the safety benefits it provides, which Traficom does not dispute. The system is considered to have significant potential to reduce accidents caused by human factors and to make traffic flow more smoothly, as the driver’s role in driving can be reduced for extended periods. 

The system forms an integrated set of safety functions for the driver, enabling smooth and calm driving behaviour when used correctly. Based on tests and experiences from other markets, vehicles equipped with the system have also been able to manage challenging weather conditions, and the system does not even need to identify lane markings in order to operate. 

The system has been observed to often make safer decisions than a human driver, and its response capability in many situations is faster than that of a human. The overall view of the system is positive.

“However, Traficom wants to ensure that the driver is also able to monitor and intervene in the system’s operation in Finnish road conditions, and to bear the responsibility that belongs to the driver. Traficom has granted the manufacturer several test permits, so trial use of the system in Finland by the manufacturer’s own drivers has been possible for several years,” Juhola says.

Support for the driver in sudden situations

The basic idea of the system is that the car can be driven without physical contact with the controls at different speeds and in almost all weather conditions. However, the manufacturer stresses in its owner’s manual Ulkoinen verkkopalvelu. that the vehicle may quickly and suddenly make unexpected manoeuvres or mistakes. The manufacturer also states Ulkoinen verkkopalvelu. that the system is an early access feature that must be used with particular caution. 

For this reason, the driver must be ready to take control of the car at all times and understand that they may need to take control even before the system requests this. Because the system’s response capability is faster than that of a human in some situations, the driver must be able to anticipate situations in which the system functions incorrectly. 

“We are reviewing the documentation related to the approval process together with the manufacturer and the Dutch approval authority. The aim is to ensure that the system does not impair the driver’s actual ability to control the vehicle compared with the systems currently on the market,” Juhola says.

The assessment has examined, among other things, situations where the system makes a sudden mistake or where the stability of the vehicle changes rapidly due to an external factor, for example in slippery conditions and at higher speeds.

“When using the system, taking back steering control involves an additional step in which the driver must first move their hands to the steering wheel. This can be challenging because the steering wheel may be moving under the control of the system at the same time, while the driver must continue to monitor traffic. In addition, some Tesla models have an unusually shaped steering wheel, which may make it more difficult to grip and thereby add to the difficulty of the situation,” Juhola continues.

Overtaking on two-way roads with bends and differences in elevation

The manufacturer states in its owner's manual that the system does not operate optimally on high curvature roads. The functionality of the camera-based system requires that it has a sufficient view of its surroundings. The system is programmed to perform overtaking manoeuvres also in these conditions, which are known to require particular care.

Discussions have been held with the manufacturer and the approval authority on the system’s expected performance and the related risks, particularly when overtaking slower traffic. The assessment has focused on conditions typical of Finnish highways, where speed limits generally range from 60 to 100 km/h and where bends and differences in elevation can obstruct visibility. 

Speed offset and assessment of its impacts

Any car can be driven above the speed limit in traffic, both without driver assistance systems and, for example, when using cruise control. Tesla’s system also includes a similar option. A speed offset of up to +50 per cent above the detected speed limit can be set for the system.

The offset does not mean that the system will continuously drive at the speed permitted by the set offset, as cruise control does, for example. Instead, the speed continues to adapt to the situation at hand. However, this adaptation does not rule out the possibility that the car may exceed the speed limit. 

The need to retain this feature and its impacts have been assessed in cooperation with the authority that granted the approval, other European authorities and the manufacturer. At present, the need for the feature is justified on the grounds that the driver must be given sufficient flexibility for situations where the system does not correctly identify the speed limit and the vehicle could otherwise travel too slowly for the situation.

According to the manufacturer, the solution is also necessary because a vehicle travelling strictly at the speed limit could disrupt traffic in situations where other traffic does not comply with speed limits.

The tolerance enables flexible speed adjustment in such situations, but at the same time it also enables intentional speeding. The exception is motorway conditions, where it is not possible to exceed the maximum permitted speed of 120 km/h.

Traficom has reviewed whether the approval assessment has sufficiently taken into account situations where, as a result of the driver’s choices, the vehicle may travel at an exceptionally high speed in relation to its surroundings, the conditions or other road users. A system based on deep learning may find it challenging to manage situations for which it has not been trained.

“Speeding is very common in Finland. We must therefore take into account that this may also happen very commonly when this system is used, and the resulting impacts have been assessed,” Juhola says.

Vehicle ageing in the approval assessment

Traficom has examined how vehicle wear and tear has been taken into account in the approval assessment.

Tesla differs from other car manufacturers in that its vehicle maintenance programme does not include regular condition inspections.

No modification inspection usually needed when introducing the system

Traficom has examined the suitability of the system for vehicles already in use and assessed whether introducing the system could require a modification inspection.

Traficom has considered that vehicles already put into service do not need to undergo a modification inspection when the system is introduced, provided that no other modifications requiring a modification inspection have been made to the vehicles.

Retrofitting the system to a car is carried out in accordance with international legislation on software updates, and the type-approval authority has therefore already assessed the conformity of the car equipped with the system.

For cars that have undergone a modification requiring a modification inspection, the assessment is still ongoing. Traficom estimates that the number of such cars is very low. The types of modifications already made that are most likely to have required a modification inspection include unusual tyre sizes or, for example, suspension lowering kits.

Applicability of Finnish legislation 

Finnish legislation does not contain any inconsistencies concerning the installation or use of the system.

The ongoing legislative project LVM039:00/2025 takes into account the technological development of highly advanced driver assistance systems. The purpose of the legislative amendments included in the project is to clarify the responsibilities and obligations related to the use of these systems.

The decision concerning Tesla’s system does not depend on this legislative project.

Next steps and progress of the assessment

The Technical Committee – Motor Vehicles (TCMV) will next discuss the system’s approval process on 30 June 2026. Traficom will participate in the meeting, where the observations made by Member States on the approval will be reviewed.

“It cannot be ruled out that, following this discussion, the approval will be supplemented or that some further changes will be made to it, which may also be reflected in the system’s features,” Juhola says.

In the assessment of the approval, it must be taken into account that when the Commission authorises the granting of EU type-approval containing an exemption for new technology, it must adapt established legislation to recognise this new technology. After this adaptation, which will take around two years, the technology covered by the exemption will be available to all manufacturers.

At the same time, Tesla’s driver assistance system is being assessed in relation to the parallel and advanced legislative framework for genuinely self-driving vehicles. Self-driving vehicles may probably be seen on Finnish roads as early as 2028. 

“The matter therefore has long-term significance, which is why the assessment must be carried out with particular care,” Juhola says.

When assessing the urgency of the decision from Finland’s perspective, it should be noted that there are around 6,500 registered cars with FSD (Supervised) capability in Finland. This represents around 0.24 per cent of the 2.7 million passenger cars in traffic use in the country.

An EU-wide solution can be expected in October 2026. However, Traficom is prepared to proceed on a faster schedule after the summer if the necessary additional information has been obtained on the key areas of assessment mentioned above.

“We have identified that, before the system is approved, users and others interested in the matter need to be provided with further information on its use. The safety benefits of the system will only be achieved if its operating principles are understood correctly and it is used appropriately,” Juhola says.