General Background: Artificial intelligence advancements have facilitated the development of autopilot-driven autonomous vehicles operating without human intervention. Specific Background: Although autonomous vehicles have entered Indonesia since 2014, Law Number 22 of 2009 on Road Traffic and Transportation still positions human operators as the sole legal subjects, creating a legal vacuum regarding technological failures. Knowledge Gap: Prior Indonesian legal studies identified regulatory challenges for autopilot vehicles but lacked a comparative analysis of the United States and China to formulate comprehensive national legal reform. Aims: This study analyzes and compares the legal frameworks governing autonomous vehicles in the United States and China as a reference for developing Indonesian regulations. Results: Using normative legal research with comparative and conceptual approaches, findings reveal that the United States applies a decentralized state-level model emphasizing Society of Automotive Engineers (SAE J3016) automation levels, technical safety testing, and disengagement reporting, whereas China implements centralized pre-operation supervision, redefines the driver as a dynamic system controller, and enforces strict liability on manufacturers and operators under its Civil Code. Novelty: This research synthesizes China's centralized civil law strict liability model with the United States' technical safety and reporting standards into a regulatory framework tailored for Indonesia, including pilot testing in Nusantara Capital City (IKN). Implications: Indonesia should revise Law Number 22 of 2009 by adopting SAE automation classifications, expanding the driver definition to dynamic system controllers, and applying manufacturer strict liability to ensure legal certainty and public safety. Highlights: United States jurisdictions decentralize automated driving governance across individual states through technical safety evaluations, mandatory five million dollar insurance, plus annual failure disclosures. China centralizes pre-operation approvals while imposing absolute legal responsibility upon software developers, fleet operators, data providers, or local governments during technological malfunctions. Updating Act Number 22 of 2009 requires adopting six international automation levels, establishing specialized certification bodies, plus designating Nusantara Capital City as a testing zone. Keywords: Autonomous Vehicles, Strict Liability, Comparative Law, Dynamic System Control, Road Traffic Regulation
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