On October 28, 2021, a vehicle equipped with an automated driving system (ADS) manufactured and operated by Pony.ai crashed in Fremont, California (subject crash). After learning of the crash, NHTSA engaged with Pony.ai regarding the company’s recall and reporting responsibilities under the Motor Vehicle Safety Act (Safety Act). This engagement led Pony.ai to submit three reports under NHTSA’s Standing General Order 2021-01 (SGO), which requires reporting of certain crashes involving ADS or Level 2 Advanced Driver Assistance Systems equipped vehicles. Pony.ai filed the first such report for the subject crash on November 17, 2021, and it filed updates to this report on November 29, 2021, and December 15, 2021. After further engagement with NHTSA regarding the company’s software changes following the crash, Pony.ai filed a Part 573 Safety Recall Report on March 3, 2022 (Recall No. 22E-016). NHTSA subsequently opened two investigations to assess Pony.ai’s response to the crash, including the timeliness of the company’s crash reporting and the sufficiency of the recall. Specifically, Audit Query AQ22001 was opened on March 24, 2022, to consider whether Pony.ai complied with the crash reporting requirements of the SGO when reporting the subject crash. Recall Query RQ22001 was opened on April 10, 2022, to evaluate the scope of the population affected by Recall No. 22E-016 and the remedy described in the recall. NHTSA issued a detailed Special Order to Pony.ai under RQ22001, requesting more information about the subject crash and Pony.ai’s response to it. Pony.ai’s response to the Special Order was voluminous, spanning a series of rolling productions. After assessing this material, NHTSA closed RQ22001 on October 30, 2023, explaining that ODI believes that the company’s recall properly identified both the ADS software error that precipitated the crash and the vehicles affected by the defect. Based on the available information, Pony.ai has implemented process and procedural changes t