Few topics are currently causing as much discussion in driver groups and social networks as the new driver monitoring systems, which will become mandatory in many newly registered vehicles starting in July 2026. Terms like „in-car camera“, „face recognition“ or even „driver monitoring“ are circulating and causing concern among many professional drivers.
But what exactly is behind the so-called ADDW system? Will drivers be permanently monitored in the future? Can employers access the data? Or is it ultimately another assistance system aimed primarily at improving road safety?
A look at the underlying EU regulations shows that the reality is much more differentiated than some headlines suggest.
Legal Basis: The EU General Safety Regulation
The basis for ADDW is the EU Regulation 2.019/2144, better known as General Safety Regulation II (GSR II).
With this regulation, the European Union aims to sustainably reduce the number of serious traffic accidents. To this end, various driver assistance systems are gradually being made mandatory for new vehicles.
Already since July 7, 2024, the requirements for newly developed vehicle types are in effect. From July 7, 2026, the requirements must be fulfilled by all newly registered vehicles of the affected classes.
ADDW is just one component of an extensive safety package, which also includes intelligent speed assistants, emergency braking assistants, lane-keeping systems, and event data recorders.
The goal of the regulation is clear: accidents should be prevented as much as possible before they even occur.
What is ADDW Exactly?
ADDW stands for „Advanced Driver Distraction Warning“, which is an advanced warning system for detecting driver distraction.
Unlike classical assistance systems, ADDW does not monitor the environment of the vehicle, but analyzes the driver’s behavior. This is usually done using a camera or special sensors inside the vehicle.
For example, the system evaluates eye direction, head position, or eye movements. If the system detects signs that the driver is not focused on the traffic situation for an extended period, a warning is triggered.
Typical triggers can be:
- prolonged looking away from the road,
- intensive use of a smartphone,
- distractions from displays or other activities in the driver’s cabin.
The reaction occurs immediately within the vehicle. The system is intended to remind the driver to refocus their attention on the traffic situation.
ADDW and Drowsiness Detection Are Not the Same
In many discussions, ADDW and drowsiness warning systems are confused with each other. In reality, they are, however, different functions.
While systems for drowsiness and attention warning are primarily intended to detect signs of fatigue, ADDW focuses on specific distractions during driving.
Both systems pursue the same goal – the prevention of accidents –, but they work with different approaches and evaluate different behavioral patterns.
Is the Driver Now Being Permanently Monitored?
Exactly at this point, most discussions begin.
Many drivers automatically associate a camera in the driver’s cabin with permanent monitoring of their person. However, the EU regulation does not require permanent video recording of the driver.
ADDW was designed as a warning system. Its primary task is to detect distractions and immediately alert the driver.
The actual question is therefore not whether a camera is present, but rather what data is generated, how it is processed, and who can access it.
Because there is a significant difference between a short-term evaluation in the vehicle and long-term storage or further processing.
Between Road Safety and Employee Monitoring
From my perspective, the actual discussion begins here.
The EU regulation does not prescribe a system for remote monitoring of drivers. The goal of ADDW is to detect distractions and warn the driver within the vehicle.
This question is therefore not yet fully answered.
Modern commercial vehicles are today part of highly interconnected fleet management and telematics systems. Already now, numerous vehicle data are captured, transmitted, and evaluated. These include, among other things, driving times, fuel consumption, driving style, braking actions, or location data.
The legitimate question is therefore whether information from driver monitoring systems could also flow into such evaluations in the future.
Technically, this appears to be possible. Whether and to what extent such data are actually allowed to be processed is, however, a different question.
At the latest, data protection regulations under the GDPR, the Federal Data Protection Act, and – if applicable – the co-determination rights of the works council come into play.
From my perspective, the discussion should not end with the camera in the driver’s cabin. The decisive question is rather which data will be stored, evaluated, or linked with other systems in the future and whether a safety system will ultimately become an instrument for performance or behavior control.
Professional drivers should closely follow this development. Because not every technical possibility is automatically also legally permissible.
Safety System or Control Instrument?
From the perspective of data protection and labor law, it becomes particularly interesting when information from different sources is linked together.
Modern commercial vehicles already have a wide range of digital systems today:
- digital tachographs,
- telematics systems,
- GPS tracking,
- fleet management software,
- dashcams,
- driver assistance systems.
Each of these systems generates specific information on its own. However, when these data are combined, they can create a very detailed picture of a worker’s driving behavior.
At this point, the actual discussion begins.
It is not the camera itself that is the problem, but the question of whether long-term behavior or performance profiles can be created from individual events.
Data protection and employee rights
In Germany, such systems are subject to the provisions of the General Data Protection Regulation (GDPR) as well as the Federal Data Protection Act.
Personal data may not be collected, stored, or processed arbitrarily. Every processing requires a legal basis and must be proportionate.
For employers, this means that a system aimed at improving road safety may not automatically be used for permanent performance or behavior monitoring.
Particularly relevant in this context is also the Works Constitution Act. According to § 87 Abs. 1 Nr. 6 of the Works Constitution Act (BetrVG), the works council has co-determination rights regarding technical installations that are suitable for monitoring the behavior or performance of employees.
Companies that wish to implement such systems must therefore often jointly with the works council establish clear rules regarding purpose, use, storage duration, and access rights.
Why these systems are introduced in the first place
Despite all criticism, the cause should also be considered.
The European Commission has pointed out for years that distraction is a significant risk factor in road traffic. This includes not only smartphones but also navigation systems, onboard computers, or other activities that divert attention from the road.
ADDW is therefore not intended as a tool for punishing drivers, but as another building block for preventing serious accidents.
Whether these systems actually bring the desired safety benefit in practice will only become clear in the coming years.
The real question is: What happens to the data?
Those who discuss ADDW should therefore not focus exclusively on the camera.
The crucial questions are:
- What data are actually generated?
- Are these data stored?
- For how long are they stored?
- Who can access them?
- Are they linked to other systems?
- Are they used exclusively for safety or also for performance evaluation?
Only the answers to these questions will determine whether an assistance system serves exclusively the purpose of road safety or whether it can become an instrument of employee control.
Conclusion
ADDW is not a monitoring system prescribed by the EU, but an assistance system for detecting driver distractions. The goal is to increase road safety and prevent accidents.
At the same time, it would be naive to completely ignore the data protection and labor law issues. Modern vehicles generate an increasing amount of data, and the technical possibilities for analysis are growing continuously.
The actual discussion should therefore not end with the existence of a camera. What is decisive is rather what happens to the information gained, who has access to it, and for what purpose it is used.
Because it is not the camera alone that decides on monitoring – but the handling of the data it generates.
Sources and legal bases
EU Regulation 2019/2144 (General Safety Regulation II)
Legal basis for the mandatory introduction of various driver assistance and safety systems in vehicles within the European Union.
https://eur-lex.europa.eu/eli/reg/2019/2144/oj
Delegated Regulation (EU) 2023/2590 on ADDW systems
Sets out the technical requirements and testing procedures for Advanced Driver Distraction Warning Systems (ADDW).
https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX:32023R2590
General Data Protection Regulation (GDPR)
Particularly relevant:
- Art. 5 GDPR (Principles of data processing)
- Art. 6 GDPR (Legal bases for processing)
- Art. 13 GDPR (Information obligations)
- Art. 25 GDPR (Data protection through technical design)
- Art. 88 GDPR (Data processing in the context of employment)
https://eur-lex.europa.eu/eli/reg/2016/679/oj
Federal Data Protection Act (BDSG)
Particularly relevant:
- § 26 BDSG (Data processing for the purposes of the employment relationship)
https://www.gesetze-im-internet.de/bdsg_2018/
Works Constitution Act (BetrVG)
Particularly relevant:
- § 87 Abs. 1 Nr. 6 BetrVG (Co-determination regarding technical installations for behavior or performance monitoring)
https://www.gesetze-im-internet.de/betrvg/__87.html
German Road Safety Council (DVR)
Information on driver assistance systems and their safety-relevant effects.
