Automated motor vehicles have transformed the transportation industry, offering new opportunities for safety, efficiency, cost-savings, and clean transportation. In a continued effort to foster innovation in autonomous vehicle technology, particularly within the trucking industry, the Ontario government introduced the Automated Commercial Motor Vehicle (“ACMV”) Pilot Program in August 2025. Building on the province’s existing statutory framework for autonomous vehicle testing, the ACMV Pilot Program extends the testing of autonomous vehicles to include heavy-duty commercial vehicles.

In this article, we provide an overview of Ontario’s original Automated Vehicle Pilot Program, introduce the new ACMV Pilot Program, and outline the program conditions and eligibility requirements for participation.

What are autonomous vehicles?

Autonomous vehicles are driverless or self-driving vehicles. By using a range of technologies including sensors, cameras, artificial intelligence, and global positioning systems, automated vehicles can perform part, or all, of the dynamic driving tasks (“DDTs”) and critical safety functions required for driving without direct driver input. DDTs include the real time operational functions required to operate a vehicle, such as steering, braking, accelerating, changing lanes, and using turn signals.

The Society of Automotive Engineers (“SAE”) has defined 5 levels of driving automation:

  • Level 0: No driving automation – the driver performs all DDTs.
  • Level 1: Driver assistance – the vehicle has some driver assistance systems like sustained steering or sustained acceleration/ deceleration. Example features include blind spot warnings and emergency braking systems.
  • Level 2: Partial driving assistance – steering and acceleration/deceleration can be performed by the vehicle. The driver is responsible for supervising and taking control of the vehicle when necessary.
  • Level 3: Conditional driving automation – the vehicle performs all driving functions in certain conditions, such as at certain speeds, weather conditions, or road conditions.
  • Level 4: High driving automation – the vehicle performs all driving functions within a limited domain, and the driver is not permitted to intervene. If conditions occur that prevent the vehicle from performing the DDTs safely, such as a malfunction or if the vehicle leaves its domain of operability, the automated technology moves the vehicle to a safe location.  
  • Level 5: Full driving automation – all DDTs are performed by the vehicle without the need for any human intervention.

Vehicles with Level 1 and 2 automation are currently available for purchase in Canada. While Level 3 vehicles are permitted for use in Ontario, they are not yet sold within the country. Testing of Level 4 and Level 5 automated vehicles is allowed in Ontario, subject to specific conditions outlined below.

Ontario’s first autonomous vehicles pilot program

In 2016, the Ontario government introduced a ten-year Automated Vehicle Pilot Program to allow for the testing of autonomous vehicles under certain conditions, including the requirement that a driver be present in the vehicle. The program was updated in 2019 to allow for the testing of driverless automated vehicles and cooperative truck platoons under specific conditions. Under the pilot program, motor vehicles, commercial motor vehicles, and streetcars with an automated driving system are permitted. Eligible pilot program participants include autonomous vehicle owners who are either manufacturers or converters of autonomous vehicles. This includes auto manufacturers as defined by the Motor Vehicle Safety Act, technology companies, and academic and research institutions.

The new ACMV Pilot Program

In August 2025, the provincial government announced the introduction of the ACMV Pilot Program. This 10-year pilot runs from August 1, 2025 to August 1, 2035, and aims to evaluate automation in the trucking sector. The program expands on the existing Automated Vehicle Pilot Program to allow for the testing of autonomous commercial motor vehicles that weigh over 4,500 kilograms and meet the SAE International Standards for Level 3, 4, or 5 autonomy. Some vehicle types, including long combination vehicles, tractor double-trailers (A-, B-, or C-trains), truck-trailer configurations, and buses, are not permitted. Automated vehicles are also limited to operating in approved weather conditions and are subject to existing provincial speed restrictions.

Testing streams

Testing may be conducted through either the driver-supervised stream or the driverless stream. In the driver-supervised stream, a driver of vehicles at Level 3 autonomy must be present in the driver’s seat and be prepared to take control of the vehicle when necessary. Under the driverless stream, vehicles may operate at Level 4 or 5 with an assistant located in the driver’s seat, or elsewhere in Ontario, and must be ready to provide oversight of the vehicle.

Eligibility requirements

In addition to the weight and automation level criteria described above, applicants must meet one of 3 requirements to be eligible:

  • have at least 2 years of experience with a “Satisfactory-unaudited” carrier safety rating, and be partnered with another carrier that has at least 5 years of experience and a similar carrier safety rating;
  • have at least 3 years of experience with an “Excellent-audited” carrier safety rating; or
  • have at least 5 years of experience with a “Satisfactory-unaudited” carrier safety rating.

Additionally, program participants must maintain a minimum of $10 million in public liability coverage.

Areas of operation

Program applicants must obtain approvals for testing in particular areas. For example, the Ministry of Transportation (“MTO”) must approve testing on provincially controlled infrastructure such as highways. Applicants must also notify and provide details to each local municipality where they intend to test ACMVs and obtain feedback from municipalities regarding their proposed testing plan. Lastly, applicants must also notify the local road authority for testing on municipally controlled infrastructure and keep them informed as to any changes to the testing plan.

Other program requirements

The government also requires program participants to collect daily data on speed, vehicle warnings or notifications to the vehicle’s driver or assistant, weather conditions, shared road space, video footage, and other sensor data. This data must be retained for three years and be made accessible to the MTO upon request. Participants must also maintain a monthly record of each ACMV trip and submit their data to the MTO. The data provided to the MTO will be used for evaluation purposes and inform the further rollout of ACMVs in Ontario.

ACMVs must also clearly display signs with the text “TEST VEHICLE – STAY BACK” on both the front and rear of all vehicles. When testing under the driverless stream, vehicles must display signage or a sticker on the driver’s side door to inform first responders how to contact the remote assistant overseeing the vehicle, with information including a phone number.

How to apply

Interested and eligible program participants must submit an application package to [email protected]. The MTO will review and contact the applicant regarding the development of a custom graduated testing framework. The framework must demonstrate safe operation in lower-risk environments before progressing to testing in higher-risk environments. The testing framework is then submitted for approval to the Registrar of Motor Vehicles. Before approval is granted, the applicant may need to provide proof of the equipment to be used by carriers and their partners and compliance with the federal Motor Vehicle Safety Act. For driverless testing, applicants will be required to demonstrate how they intend to satisfy commercial motor vehicle rules and regulations under the Highway Traffic Act.

For more information or assistance with applying to the ACMV Pilot Program, please contact a member of Miller Thomson’s Transportation & Logistics Team.