Spain’s Dirección General de Tráfico (DGT) requires participants in automated-vehicle road tests under Programa ES-AV to carry civil-liability insurance, alongside prior authorization, data-recording systems and qualified operators. That test requirement is separate from commercial robotaxi coverage: in comments reported on October 25, 2026, Mutua Madrileña’s Jesús del Río Anyat said there was no single insurance model for autonomous vehicles.
What Spain requires for automated-vehicle tests
The DGT published Programa ES-AV on June 18, 2025, as a framework for authorizing and supervising tests of automated and remotely driven vehicles on roads open to general traffic. Participating manufacturers, developers, importers and fleet operators need prior authorization, systems to record data, civil-liability insurance and qualified operators, either on board or remote. The DGT’s framework also requires periodic, final and incident reports to support safety assessments and publication of basic information.
The program has three test phases: controlled, extensive and pre-deployment. Pre-deployment testing covers the stage immediately before commercialization or the start of a service, subject to the program’s conditions. These requirements set the insurance and operating prerequisites for tests; they do not prescribe a commercial robotaxi policy.
What has been reported about Madrid’s pilots
ABC reported on October 25, 2026, that supervised pilot tests by Uber, Waymo and Bolt in Madrid were underway or about to begin. The report described driverless operation as expected in 2027. NeoTeo has also covered Madrid’s Level 4 robotaxi permit, a separate step in preparing and testing the service.
How insurers view fleet and technology risks
Del Río Anyat described a possible division of insurance roles: the fleet owner or operator as the natural insured, with manufacturers, autonomous-driving-system suppliers and platforms carrying other risks. That is his assessment of how coverage could be structured, not a set of established policy terms.
Ramón González Aznar, an automobile business-development director at Mapfre España, said responsibility could shift toward a manufacturer or service operator when no human driver is present. He also pointed to potential exposure involving product or service safety, software, cybersecurity and personal data, alongside claims for damage or injury in a collision.
José María Cancer, director of Cesvimap, said insurers have little historical claims data for underwriting autonomous fleets. He said supervised testing can generate information about safety-driver interventions and recurring risk scenarios, giving insurers more to assess as they evaluate these operations.
Why fewer crashes may not mean cheaper insurance
Mutua Madrileña cautioned that fewer accidents would not automatically make coverage cheaper: sensors and electronic components can raise repair costs. The frequency of claims is only one part of the insurance calculation when a vehicle’s technology can make repairs more expensive.
