Since Henry Ford first proposed his Model T, Americans have fallen in love with the automobile. From the moment the car first appeared, it represented freedom and allowed ordinary people to explore places far beyond their immediate location. But as exciting as these machines were, they were also very complicated and potentially dangerous. And this led regulators to create stringent rules to ensure that the operator of any vehicle was always in control. That assumption shaped not only the overall design of the car and its steering wheel, pedals, dashboard, warning lights, and seat, but even the legal language that defined the vehicle’s purpose. Now, in 2026, one of the clearest examples of that human-centered rulebook is in focus. The NHTSA may be about to target a specific regulation that covers the light vehicle braking rule, proposing that the human foot no longer has to be a crucial part of this picture.
The Brake Pedal Was Never Just A Brake Pedal
2012 Dodge Charger SRT8 – brake pedal, acceleratorStellantis
2026 Tesla Cybercab Specifications
Motor
Single AC three-phase permanent-magnet motor
Transmission
Single-speed automatic
Drivetrain
Front-wheel drive
Power
219 hp
Torque
Not disclosed
For generations, people have implicitly understood that if they’re sitting behind the car’s brake pedal when the vehicle is in motion, they’re fully responsible for safety and control. That assumption has been in place since the early days of Henry Ford and his fellow trailblazers.
Various regulations existed over time until, in 1995, the NHTSA finalized Federal Motor Vehicle Safety Standard Number 135 and codified more formal language. This was a time when anti-lock brakes, hydraulic systems, and other technologies were becoming increasingly important, and the new rules (with some additions in 1997) covered not only cars but also light trucks, multipurpose passenger vehicles, and buses up to 7,716 lbs. of gross vehicle weight.
Rule 135 went into detail about different hydraulic components, warning sets, ABS, and other matters like regenerative braking. The entire rule set pivoted around the fact that a human occupant had to manually operate each vehicle. In this case, the pedal was basically the bridge between the vehicle and the operator’s judgment and safety on the road.
However, in 2026, the NHTSA suggests that that bridge may not always be necessary. Its proposals suggest that manufacturers can remove manual brake pedals and hand or foot-operated parking brake controllers, so long as the vehicle in question is designed exclusively to be driven by an automated driving system. Stopping distance rules would still apply, and the brakes still have to work, but humans wouldn’t always have to control the outcome.
What The NHTSA Is Actually Changing
Brembo Greentell Brake DiscBrembo
Under the current FMVSS number 135, the vehicle service brake is activated by a foot control while the parking brake must be independent of that and can be controlled by either hand or foot. Under the NHTSA’s proposed new amendment, these manual control requirements now only apply to vehicles that actually have manually operated driving controllers. Otherwise, autonomous vehicles must still brake effectively, efficiently, and safely, but the braking performance requirements can now be met through different test procedures and control architecture.
The proposal does not permit a braking architecture in which the required braking signal can only originate outside the vehicle. Instead, it relates to vehicles where braking depends on onboard systems, and the automated driving system (ADS) translates an electronic command into a physical deceleration. This could be something like a linear actuator replacing muscular force on a brake pedal.
Stopping distance can now be assessed based on the initial transmission of an electronic braking command up to the point where the vehicle comes to a complete stop. All the overall safety targets remain the same, but the old pedal force measurements no longer make any sense. Now the trigger point moves from a human foot to an electronic action.
This Matters To Tesla, Zoox, Waymo, And Others
The Tesla Cybercab has only two doors.Tesla
Up until this point, purpose-built robotaxis operated in a gray area and effectively had to pretend to be conventional cars to fit legacy rulebooks. But this change could therefore make a significant difference for companies like Zoox or Tesla and its Cybercab, where these vehicles are meant for passengers rather than drivers.
Up until now, fully autonomous vehicles that have traditional human controls could attract certification like a normal vehicle, so long as they met applicable standards. Those without any human controls would need exemptions, and this placed a cap of approximately 2,500 vehicles per manufacturer per year, according to the NHTSA. Robotaxi organizations therefore faced a significant challenge in developing their business models, given the strict cap on how many identical robotaxis they would be able to deploy.
The new NHTSA proposal could represent the start of a shift for these manufacturers. The government could be starting to rewrite the rules to deal with the issue of driverless configuration. Certainly, there’s still a long way to go and manufacturers must comply with a variety of other applicable safety standards, while ADS performance also remains a separate issue. But the fact that a purpose-built vehicle without pedals or a steering wheel is no longer such a regulatory oddity does represent an interesting moment.
The New Interior Starts Where The Driver Used To Sit
Zoox driverless taxiZoox
People who want to see a glimpse of the future might take a closer look at the Zoox robotaxi. This is a compact, bidirectional, all-electric vehicle that has no front end or back end in the conventional sense. It has subway-style doors, four-wheel steering, and four seats that face each other rather than all looking forward. It also has a 75-mph top speed in either direction and can run for up to 16 hours on a single charge, but its design makes it more of a “room that moves” than a conventional vehicle.
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There’s no need for a steering wheel, carefully positioned driver’s seat, pedal box, instrument cluster, mirror layout, or other features that define a driver’s cockpit. Zoox is also leaning further into its robotaxi design with its latest update, adding larger cupholders, a more visible touchscreen, wireless charging tweaks, and better seat padding.
The Big Unanswered Question Is Still Who Brakes
2008 Mitsubishi Lancer – Hand brakeMitsubishi
In this proposal, the NHTSA says that it expects passengers to have some way to bring one of these vehicles to a stop, but it’s not going into detail about how they would do so, or how the vehicle should respond. In a conventional car today, even a nervous passenger can still see the brake pedal, even if it may be difficult for them to reach it. But in this room on wheels, there’s no such pedal and each passenger has to trust a software-defined system, even if there is a support channel or emergency interface somewhere along the line.
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The NHTSA will surely address ADS performance at some stage, but until then, it doesn’t really answer the question of liability. In the event of an incident, did a human being actually have an opportunity to stop the car? In the meantime, the NHTSA is seeking comments on its FMVSS No. 135 proposal, and the closing date for submission is July 27, 2026.
If the proposal goes through, this could certainly signify a regulatory turning point, and it’ll be far more than just a business win for a robotaxi company. Instead, it will do something historically significant by removing a physical brake pedal and thereby declaring that a human driver doesn’t always have to exist. And this could split the automotive world into two halves, with machines that people still actually drive, and others that are basically places that people occupy while the software does the work.
Sources: NHTSA, Tesla, Zoox, Federal Register.
Sources: Zoox, NHTSA, Tesla
