Automated Vehicles (AVs) are expected to have a plethora of benefits to road safety, traffic and society. With the rise of automation liability allocation is becoming a critical and unresolved legal challenge that will affect AVs adoption, price, road safety and traffic. This paper presents an analysis of AV liability frameworks comparing three major jurisdictions: the European Union, the United States and China. Each region has unique regulatory frameworks, legal structures, and implementation timelines, leading to different approaches in liability allocation and managing insurance claims in AV-involved incidents. This study used a structured legal analysis framework to evaluate the clarity, coherence, and adaptability of liability rules in each jurisdiction, focusing on key dimensions such as manufacturer liability, driver responsibility and treatment of automation (SAE Levels 3–5). The findings highlight significant legal fragmentation between the studied jurisdictions, which could pose risks for cross-border AV deployment and potentially hinder manufacturer compliance efforts and innovation development, creating uncertainty for insurers and users. A comparative matrix was developed to illustrate how liability standards vary across regions and identify best practices that could promote both innovation and accountability. The paper concludes with policy recommendations aimed at improving AV liability allocation regulations in the EU.
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