MoRTH's Draft V2V Rules: What Vehicle-to-Vehicle Communication Adds to a Commercial Fleet's Risk File

On 3 August 2026 the Ministry of Road Transport and Highways issued a draft notification proposing amendments to the Central Motor Vehicles Rules, 1989 to enable phased implementation of vehicle-to-vehicle communication systems in motor vehicles. The draft is an enabling instrument. It does not by itself mandate that a tipper leaving a quarry in Chhattisgarh must broadcast its position and braking state, and it does not fix a compliance date for any vehicle category. What it does is create the rule-making space in which those mandates can later sit, category by category, in phases.

Running alongside it is a spectrum decision that matters more than it looks. The 5.875 GHz to 5.925 GHz band has been earmarked for V2V and other Intelligent Transportation System applications, and the Department of Telecommunications has exempted that band from licensing requirements. A fleet operator does not need a telecom licence to have its trucks talk to each other. The practical effect is that the cost of deployment drops to the cost of the radio, the software stack and the integration work, which is exactly the sort of cost curve that produces fast, uneven, partly aftermarket adoption.

A draft notification is the right moment for a fleet to read its policy wordings rather than to buy new cover. The exposure arrives when the first V2V-equipped vehicles enter the fleet, and for aftermarket retrofits that can precede any compliance deadline by years.

The insurance consequence of V2V is not that vehicles become safer, though the safety case is the reason the rules exist. It is that the vehicle acquires a new class of component whose failure mode is informational rather than mechanical.

A V2V stack on a commercial vehicle typically involves four parties who are not the fleet:

• The OEM or the retrofit vendor that supplies the on-board unit and the radio.
• The chipset and stack supplier whose firmware encodes and decodes the safety messages.
• The software integrator that connects the unit to the vehicle bus so it can read speed, braking and steering state.
• The certificate or security credential provider that signs messages so a receiving vehicle can decide whether to trust them.

Every one of those parties can push an update. A fleet that operates 400 trucks across five states can find that all 400 changed behaviour on a Tuesday night because a stack vendor shipped a firmware revision. Motor own damage wordings were not written with that population-wide, simultaneous change in mind, and neither were the fleet's contracts with its vendors.

This is the same structural problem that shows up in ADAS and autonomous vehicle liability, with one difference. ADAS acts on the vehicle it is fitted to. V2V acts on other people's vehicles, because the whole point is that a message from truck A changes what truck B does.

Third-party liability under the Motor Vehicles Act, 1988 is unaffected in form. The owner remains liable, the insurer remains on risk, and a claimant injured by a truck still proceeds against the owner and the insurer rather than against a chipset vendor. Nothing in an enabling amendment to the Central Motor Vehicles Rules changes the compensation architecture for a road accident victim. See the glossary entry on third-party liability for how the statutory obligation is framed.

What moves is what happens after the insurer pays. If the event data shows that a V2V message was received, was acted on by the receiving vehicle, and was wrong, the insurer's subrogation target is no longer the other driver. It is the entity that generated or corrupted the message. Indian motor insurers have very little practice at recovering against a software supplier, and the recovery route runs through product liability rather than motor.

On own damage, three questions decide whether a claim is paid cleanly:

1. Is the on-board unit declared in the vehicle schedule, and is its value inside the sum insured? Aftermarket electronics that are not declared are a familiar source of partial repudiation.
2. Does the wording carry an electrical or electronic breakdown exclusion that a V2V unit failure would fall into?
3. If the unit's failure caused the collision rather than merely accompanying it, does the insurer treat the software fault as the proximate cause and look to the manufacturer?

A fleet buying or renewing commercial motor cover in the next two renewal cycles should ask for these three points to be answered in writing rather than assumed.

For a logistics operator the uncomfortable position is being neither the manufacturer of the V2V unit nor the party that wrote its firmware, while being the registered owner of the vehicle that broadcast the message.

Consider a fleet that retrofits on-board units across its trailer population. A unit misreports braking state because of an integration fault between the unit and the vehicle bus. A following vehicle from a different operator receives the message, its driver assistance system relaxes, and a rear-end collision follows. The claimant sues the owner of the following vehicle and its insurer. The following insurer, reading the event log, looks upstream at the broadcasting fleet. The broadcasting fleet looks at its integrator. The integrator looks at the stack vendor.

Where the cover has to sit

A fleet that installs and configures units is closer to a supplier of a component than it may realise, particularly where the installation was done by its own workshop. Product liability cover on a fleet's own liability programme is uncommon in India because a fleet does not usually make anything. Once it retrofits and configures safety-relevant radios, the argument for a liability insurance extension covering faulty workmanship and faulty installation becomes concrete.

The alternative, and the cheaper one, is contractual. Before commissioning, the fleet should hold:

• An indemnity from the integrator and the unit supplier covering third-party bodily injury arising from message error.
• Evidence of the supplier's own product liability limits, with the fleet named as an additional insured where the supplier's insurer permits it.
• A commitment that firmware releases affecting message generation are staged rather than pushed fleet-wide in one window.
• A defined route for the fleet to obtain signed event logs when an insurer asks for them.

A vehicle that receives messages from strangers and changes its behaviour in response has an attack surface that a vehicle without a radio does not. The security model for V2V rests on signed credentials, which means the credential system itself becomes a single point of failure with a fleet-wide blast radius.

Three scenarios matter for an underwriter:

1. Spoofing. A fabricated message causes vehicles to brake or swerve. Bodily injury follows, and the loss sits in motor and liability rather than cyber, even though the cause is a security failure.
2. Credential compromise. The fleet's own signing material leaks, and its vehicles are impersonated. The remediation cost, the re-provisioning of the fleet and the downtime are first-party cyber losses.
3. Denial of the radio channel. Vehicles fall back to unassisted operation. The exposure is business interruption in shape but is rarely covered by a motor policy at all.

Most Indian cyber insurance wordings sold to logistics operators are written around IT systems, customer data and ransomware. Bodily injury is a standard exclusion in cyber, and cyber causation is often absent from motor and liability wordings. That gap between the two is where a V2V loss will land. A broker should test the placement by putting a spoofing scenario in writing to both the motor and cyber underwriters and asking each to confirm, on the wording, which one responds.

The data flowing off these units also engages the Digital Personal Data Protection Act, 2023 once it is joined to driver identity, which is what happens the moment a fleet uses the same platform for telematics-based driver scoring.

V2V produces a timestamped record of what a vehicle knew and when it knew it. For a fleet with disciplined operations this is the best claims evidence it has ever had. A truck that received a hard-braking warning and responded within the expected window has a defence that no driver statement could previously establish.

The same record is available to the other side. A fleet whose vehicle received a warning and did nothing has produced the plaintiff's exhibit itself. Where a fleet has suppressed or ignored alerts at scale, for instance by disabling audible warnings after driver complaints, the pattern is discoverable across the whole fleet rather than one vehicle.

Practical consequences for claims handling

• Retention policy should be set deliberately. Logs that are gone when the surveyor asks are unhelpful, and logs kept forever are a standing liability.
• The chain of custody has to survive challenge. A log exported from a vendor dashboard by a fleet employee is weaker evidence than a signed record retrieved through a documented process.
• The fleet's duty of utmost good faith at proposal now extends to disclosing that vehicles are V2V-equipped and how alerts are handled operationally. A fleet that disables warnings and does not say so has a non-disclosure problem, not just a safety problem.

On 5 August 2026, two days after the draft notification, the Supreme Court observed that nearly 16.54 crore vehicles, around 56 per cent of registered vehicles in India, do not carry valid insurance, despite third-party cover being mandatory under the Motor Vehicles Act, 1988.

That figure sets the realistic ceiling on what V2V does for a commercial fleet's loss experience in the near term. A safety technology that works by exchanging messages between equipped vehicles delivers most of its benefit at high penetration. In a vehicle population where the majority are not even insured, the fleet's trucks will spend most of their kilometres surrounded by vehicles that broadcast nothing, and the fleet will still be the deep pocket in a collision with an uninsured party.

The underwriting implication is unglamorous. A fleet should not expect a V2V-equipped tractor-trailer to earn a rating discount in the 2026 or 2027 renewal, because there is no Indian loss data to price it on and no penetration to make the benefit real. What the fleet should expect is questions from underwriters about the software stack, the update policy and the alert-handling protocol. Those questions are the leading edge of pricing, and a fleet that answers them well early sets the terms of its own risk file. The related question of what statutory changes do to a fleet's obligations is covered in the note on the Motor Vehicles Amendment Act and commercial fleets.

The draft stage is the cheap stage. Once the amendment is notified and a phase-in date is set for a vehicle category, the fleet is negotiating with vendors under time pressure and with insurers at renewal.

1. Inventory the exposure now. Identify which vehicles already carry V2X-capable hardware, including units fitted by an OEM and dormant, and which retrofit programmes are in procurement.
2. Read the three wordings side by side. Motor own damage, liability and cyber. Mark where each responds and where each excludes for a message-error scenario, and take the gaps to the underwriters rather than to the broker's file.
3. Fix the vendor contracts before commissioning. Indemnity, limits behind the indemnity, staged firmware releases, log access. These are far harder to obtain after a fleet-wide rollout than before it.
4. Set the alert-handling protocol in writing. Drivers will ask for warnings to be muted. Whatever the fleet decides, it should be a documented decision with a safety rationale, not an undocumented workshop habit.
5. Respond to the draft. A draft notification carries a comment window. A fleet with 400 vehicles has a legitimate view on phase-in sequencing and retrofit obligations, and industry associations are the practical channel.