Are cyan robotaxi lights required?
No. NHTSA's Oct 26, 2026 proposal would make ADS marker lamps optional. It would set standards only for lamps a manufacturer chooses to install.
Home · Cyan marker lamps
Why do some robotaxis have cyan lights?
As of Nov 2, 2026, NHTSA has proposed, not finalized, an optional cyan lamp. The lamp would tell other road users that the vehicle is operating without the expectation that anyone inside is watching the road. A vehicle that uses them would have four to eight. The Federal Register notice says comments on docket NHTSA-2026-1519 should be submitted no later than November 25, 2026. Utah has no public robotaxi service.
D.R. Autonomy is an independent Utah company and is not affiliated with or endorsed by Tesla. This page is educational, not legal advice.
What NHTSA published
On Oct 26, 2026, NHTSA published a proposed rule in the Federal Register. These details are from that notice, read Nov 2, 2026:
- Title: Federal Motor Vehicle Safety Standards; Modernization of FMVSS No. 108 To Accommodate ADS-Equipped Vehicles
- Document: 2026-21794, 91 FR 67243
- Docket: NHTSA-2026-1519
- Comments: "Comments should be submitted no later than November 25, 2026."
This is a proposal. It is not a standard in force, a ban, or a recall, and it does not approve any specific company. The Federal Register notes that its web text is not the official legal edition. If you need the legal text, use the official PDF linked from the Register page.
What the cyan lamp is
The proposal calls it an ADS marker lamp. ADS stands for automated driving system. The proposed definition says it is a lamp used to indicate when a vehicle is operating without the expectation that an occupant is monitoring the roadway.
- Optional. NHTSA says it is not proposing to mandate the lamps on every ADS-equipped vehicle. Any lamp a manufacturer chooses to include would have to meet the proposed requirements.
- Color. Cyan, the blue-green color defined in SAE J578.
- Number and placement. One or two lamps on each of the front, sides, and rear, so a minimum of four and a maximum of eight.
- Steady burning when on. NHTSA asks for comment on whether the lamps could flash to signal what the vehicle is about to do.
- ADS vehicles only. The notice says the proposal would also prohibit ADS marker lamp installation on vehicles without ADS functionality.
No car on the road today is breaking a rule by not having cyan lamps. The proposal would not require them.
Why NHTSA wants a standard
NHTSA says differing supplemental lighting could confuse or distract other drivers, or interfere with required lamps. A single standard would keep these lamps consistent.
The notice says Mercedes-Benz conducted a two-year on-road validation of ADS marker lamps in California from 2023 to 2025, using five vehicles, and stated that a 360-degree view of the cyan lamps would be beneficial to law enforcement and other road users. That is NHTSA's account of Mercedes-Benz's comments, not a finding that any company must install the lamps.
What else is in the proposal
The same notice also covers vehicles with no manual driving controls. It would limit some requirements, such as manually operated turn signal, hazard warning signal, and beam switching controls, and certain telltales, to vehicles that have manual driving controls. The cyan lamp is the part most people are searching for.
Who would turn one on
Under the proposed definition, the lamp is for when no one inside is expected to watch the road. Whether a given company would install them is up to that company. We have not seen a Tesla page saying whether Tesla will or won't use them. A direct request to tesla.com on Nov 2, 2026 returned 403, so this page does not claim a full search of Tesla's site.
Not the Cybercab certification case
This proposal is a separate docket from the Cybercab FMVSS certification matter. See NHTSA, the Cybercab, and Utah operators.
What this means for Utah
Nothing changes in Utah yet. As of Nov 2, 2026, there is no public robotaxi service in Utah. A test car with a cyan light would not mean service has started. See robotaxi status in Salt Lake City / Utah.
How to comment
The Federal Register notice says comments should be submitted no later than November 25, 2026. The comment link printed with the notice is regulations.gov/commenton/NHTSA-2026-1519-0001. We could not open that regulations.gov page on Nov 2, 2026 (HTTP 403). The November 25 date is the date in the Federal Register notice.
Sources
- Federal Register, NHTSA proposed rule, document 2026-21794, 91 FR 67243, published Oct 26, 2026. DATES line: comments no later than November 25, 2026. Full text read Nov 2, 2026.
federalregister.gov document 2026-21794 - Comment link printed in the Federal Register API for that document. The regulations.gov page itself returned HTTP 403 on Nov 2, 2026.
regulations.gov comment form
FAQ
What color is the proposed lamp?
Cyan, the blue-green color defined in SAE J578, per the Federal Register notice.
When do comments close?
The Federal Register notice says comments should be submitted no later than November 25, 2026, on docket NHTSA-2026-1519.
Is this rule already law?
No. As of Nov 2, 2026, it is a proposed rule, not a final standard.
Does this mean robotaxis are legal in Utah?
No. This is a federal lighting proposal. It says nothing about Utah robotaxi service. As of Nov 2, 2026, no public robotaxi service is live in Utah.
Is this the same case as the Cybercab certification review?
No. They are separate NHTSA matters with different dockets.