Uber spent its second-quarter call telling investors it wants to be the app layer for everyone else’s self-driving cars. The number attached to that ambition: more than $10 billion of capital across equity stakes, infrastructure and vehicle purchase commitments over the coming years, per the company’s own prepared remarks from August 5.
The more interesting figure in that document is 120,000. That’s how many vehicles Uber says its partners have now committed to the network over the coming years. Autonomous rides are live on the app in seven cities, with as many as 15 targeted by the end of this year.
Hold that number. We’re going to come back to it, because in Europe it collides with a piece of type-approval arithmetic that nobody in this story seems eager to discuss out loud.
The Chinese partner doing the heavy lifting
Uber’s European autonomy plan runs substantially through Momenta, the Beijing-founded developer it first partnered with in May 2025 for markets outside the U.S. and China. That agreement named Europe as the first deployment, with safety operators aboard. In September 2025 the two named Munich as the launch city.
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Then on July 29, Momenta announced it had received Germany-wide approval from the Kraftfahrt-Bundesamt to test Level 4 autonomous driving across urban environments nationwide. Uber, meanwhile, has been converting the partnership into ownership, adding to its position through subsidiary SMB Holding during Momenta’s Hong Kong listing.
So: an American ride-hailing platform, a Chinese autonomy stack, a German regulator, and a Bavarian launch city. Which is a genuinely novel arrangement, and also the part where most coverage stops. Let’s keep going, because the permit does considerably less than the headline suggests.
What a KBA testing permit actually buys you
Germany’s Autonomous Driving Act inserted §§1d through 1l into the Straßenverkehrsgesetz in July 2021. The provision Momenta just cleared is § 1i, which governs Erprobung — testing and development of automated and autonomous driving functions on public roads. It requires an Erprobungsgenehmigung issued by the KBA on application from the vehicle keeper, and the KBA can attach conditions to it at any time to ensure safe operation.
Here’s the clause worth reading twice. Under §1i, a vehicle running an autonomous function during testing must be supervised by a Technische Aufsicht who is physically present on site. Not a remote operator watching a video feed from a control room three time zones away. Present. Germany wrote its testing regime around the assumption that a qualified human is right there.
Paid passenger service is a different statute entirely. That runs through § 1e, which requires an operating permit for the autonomous driving function plus a separately approved, defined operating area — the festgelegter Betriebsbereich. A nationwide testing permit removes the need to file paperwork in every city. It does not put a paying passenger in the back seat.
What it does buy is time and mileage, and in a business where validation data is the product, that’s not nothing. It’s just not a launch.
Now the arithmetic
The EU’s type-approval framework for fully automated vehicles is Commission Implementing Regulation 2022/1426, which set the world’s first harmonised technical rules for approving an automated driving system that replaces the human driver. It was built on the small-series scheme. During the drafting, the European Parliament recorded the constraint plainly: the act limits approval of fully automated vehicles to 1,500 units per vehicle type sold annually across the entire European Union — and only 250 units of one type per Member State.
Two hundred and fifty. Per country. Per year. Per type.
Set that against Uber’s 120,000 committed vehicles. Even if only a modest slice of that fleet is bound for Europe, the ceiling as originally written doesn’t accommodate a robotaxi network — it accommodates a demonstration. A single German metro area running a real service needs more than 250 cars of one configuration to hit the wait times that make people delete the taxi app. Waymo’s American operations have long since blown past that count in individual cities.
There are only three ways out of that box: the approval regime changes, operators homologate multiple distinct vehicle types to stack the allowances, or Europe’s robotaxi fleets stay small enough to be press events rather than transport.
Brussels has picked door number one, slowly. The Commission’s Automotive Action Plan, COM(2025) 95, commits to developing rules for unlimited series of vehicles with automated driving systems, to proposing harmonised admission approval procedures for on-road ADS and ADAS testing in early 2026, and to establishing at least three large-scale cross-border testbeds with regulatory sandboxes and European Automated Driving Corridors. On June 8 this year, 18 Member States signed a Joint Declaration of Intent on those testbeds, backed by €20 million from the Connecting Europe Facility’s 2026 work programme for supporting digital infrastructure.
A joint declaration of intent is not a regulation. But it does tell you which direction the ceiling is moving, and it explains why an operator would spend money now on permits that don’t yet generate revenue.
The liability wrinkle that favors Europe
Here’s something the American commentary consistently misses. Germany’s strict-liability regime under the Straßenverkehrsgesetz attaches responsibility to the vehicle keeper — the Halter — largely irrespective of fault. The 2021 autonomous driving law was passed as a combined amendment to the Straßenverkehrsgesetz and the compulsory insurance act, deliberately.
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For a robotaxi operator, that structure is arguably an advantage rather than a burden. When a crash happens, the compensation question routes through a mandatory insurer with a defined statutory hook, rather than into a multi-year American product-liability fight over whether a neural network’s decision constituted a design defect. Predictable exposure is cheaper to underwrite than unlimited exposure, and insurance cost is one of the largest line items in any rideshare P&L — Uber told investors its California insurance reform work is expected to generate significant recurring savings from 2027.
What this means on the ground
For riders in Munich, nothing changes this year. Testing with an on-site supervisor is what the permit allows, and commercial operation requires a separate approval tied to a specific geofenced area.
For drivers, Uber’s own numbers complicate the replacement narrative: the company reported a record 10.2 million drivers and couriers earning over $25 billion on the platform in the quarter, and says its category share in mature AV markets like Los Angeles, San Francisco and Phoenix is higher now than a year ago. Autonomy is currently additive to the network, not subtractive from it. That will not be permanently true, but it’s true today.
And for anyone tracking the industrial politics: the first company to hold a nationwide German Level 4 testing permit is Chinese, operating a stack developed largely in China, validated against European standards, distributed by an American app. Whatever else Europe’s regulatory caution accomplished, it did not keep the technology domestic.
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