Under the grand narrative of leapfrog progress in intelligent driving, L2 has finally made a substantial transition to L3. On December 15, Changan SC7000AAARBEV pure electric sedan (Changan Deep Blue SL03) and Jihu brand BJ7001A61NBEV pure electric car (BAIC Jihu Alpha S6) became the first batch of products selected for L3 conditional autonomous driving access license.

Header image source| Network
author| Sun Yanan
edit| Su Peng
(To ensure reading fluency, this article will refer to "L2-level assisted driving" as "L2", "L3-level conditional autonomous driving" as "L3", and "L4-level highly automated driving" as "L4")

Image source: Announcement screenshot
Among them, Changan Deep Blue SL03’s smart driving system is self-developed by Changan, and BAIC Jihu Alpha S6 is equipped with Huawei Qiankun smart driving.
This is also regarded as a key signal that the L3 level is imminent.
"L3 is coming!" Jin Yuzhi, CEO of Huawei Smart Car Solutions BU, shouted.
Although Yu Chengdong, another key figure in Huawei's intelligent driving, Huawei's managing director and chairman of Terminal BG, has not spoken out, he seems to be no less excited than Jin Yuzhi.
"I cheer, embrace, and look forward to the arrival of L3. Then everyone can really sleep on the road." In September this year, when talking about the follow-up development of intelligent driving, Yu Chengdong said bluntly.
But he also added, "Of course, we really have L3 capabilities."
When L3 smart driving has made substantial progress, the smart driving industry will soon usher in a carnival. The day after the news was announced, the intelligent driving concept sector opened broadly higher in early trading, with BAIC Blue Valley and Zhejiang Shibao bidding at their daily limit.
But the question that should be more concerned about at this time is: Why were Changan and BAIC Blue Valley the first to reach this point, instead of "Wei Xiaoli", which has a greater presence in the field of intelligent assisted driving, or Sailis, the leader of Hongmeng's four realms?
In other words, can the level of the first batch of Changan and BAIC Blue Valley that obtained pilot licenses "represent" L3 regulatory standards?
Let’s find out more about the selection process of the two.

Image source: Deep Blue Auto

Why Changan and BAIC?
According to the 2023 "Notice on Carrying out Pilot Work on the Access and On-Road Access of Intelligent Connected Vehicles" (hereinafter referred to as the "Notice") and subsequent interpretations of documents, the pilot work must go through five stages: pilot application, product access pilot, on-road access pilot, pilot suspension and withdrawal, and evaluation and adjustment.
The focus of the pilot application stage isFrom a research and development perspectiveExplain the satisfaction of conditions such as automobile manufacturers and products, users, and cities where the vehicles operate.
Judging from the research and development data of intelligent driving, in terms of research and development time, Xiaopeng started autonomous driving research and development in 2014, and Changan only released the "Beidou Tianshu" plan in 2018. In terms of investment capital, annual investment amounts of tens of billions are common. In terms of team size, a thousand people is almost the threshold.

Image source: Future Car Daily Tabulation
But in the end, not all car companies entered the pilot list, which shows that R&D investment is not the only criterion for pilot application.
The real reasons may be gleaned from the questions and answers given by regulatory authorities.
According to the "Q&A on the Pilot Work of Intelligent Connected Vehicle Access and Road Access" released by the Ministry of Industry and Information Technology in 2024 (hereinafter referred to as the "Q&A"),The important basis for this pilot is "sufficient product development testing and verification."
The "Q&A" further explains that this "sufficient product development test verification" means that the product should be tested and verified through simulation, closed sites, actual roads, etc. "Among them, actual road testing is one of the important pillars of product autonomous driving system safety test verification."
This means that under the regulatory system,The safety level of autonomous driving must be repeatedly verified in the real world.
Looking directly at the actual road test: Changan Automobile has more than 5 million kilometers of road experience, extreme scenarios account for 36%, and scene elements exceed the national standard by 49%. BAIC Blue Valley stated in the "2024 Environmental, Social and Corporate Governance (ESG) Report" that the cumulative test mileage reached 2.784 million kilometers, and the test covered 18 provinces. BYD will add 72 million kilometers of new training miles every day in 2024.

Image source: BAIC Group
These car companies have proven their strength with their on-road performance.
It is worth noting that at least in the market impression, there are far more than these nine car companies that are leading in intelligence and insist on road testing, such as BMW and Mercedes-Benz, which were the first to obtain L3 test qualifications, as well as Xpeng and Cyrus, which advertise intelligence. But they didn't appear on the list.
Since the previous "Notice" stipulated that the pilot application requires a consortium between automobile manufacturers and users, some people have limited the "users" to travel platform resources, believing that some car companies do not have travel platform resources and cannot meet the requirements for application subject qualifications.
However, NIO, which also does not engage in commercial travel business, has its associated user entity "Shanghai NIO Automobile Co., Ltd." and still successfully passed the pilot application.
Therefore, a more reasonable explanation is that during the pilot application stage, not all car companies with technical capabilities chose to participate in the application, or were ready to participate in the application.
At the same time, the Ministry of Industry and Information Technology also clearly mentioned in the "Q&A" that there are indeed situations where "some automobile manufacturers with certain technical foundations did not participate in this centralized declaration."
Under the combined influence of the above factors,In the end, only nine car companies passed the pilot application, including seven passenger car companies including Changan, BYD, GAC, SAIC, BAIC Blue Valley, FAW, and NIO, as well as two commercial vehicle companies SAIC Hongyan and Yutong.

Image source: Announcement screenshot
The real watershed is still after the pilot application.
According to the process, the second stage is the product access pilot, and automobile manufacturers "should refine and improve the access testing and safety assessment plans for intelligent connected vehicle products."
The plan also needs to be reviewed at all levels: after confirmation by the Ministry of Industry and Information Technology and the Ministry of Public Security, supervision and testing by provincial authorities and the city government departments where the vehicles operate, and passing evaluation by technical service agencies, access permission can only be obtained after approval by the Ministry of Industry and Information Technology.
In other words, the key assessment in this link is the actual safety plan on the road.
Among the nine car companies that have passed the pilot application, only Changan and BAIC Blue Valley have obtained access permits.

Image source: Illustrated screenshot of the "Notice" from the Ministry of Industry and Information Technology
In other words, the key assessment in this link is the actual safety plan on the road.
Among the nine car companies that have passed the pilot application, only Changan and BAIC Blue Valley have obtained access permits.
Although it is difficult to know whether other car companies that have passed the pilot application have submitted detailed plans and what the details of the approved car companies' plans are, the passing standards can also be inferred from the safety design plans disclosed by the selected car companies.
According to Changan Automobile’s public information, its product safety design has introduced 45 regulatory standards and implemented 39 corporate standards. In terms of architecture, it adopts a seven-fold redundant architecture such as perception, control, power supply, and steering. In terms of functional safety and expected functional safety process assurance, a full-domain redundant architecture is built based on the ASIL D management and development process. In terms of network security and data security process assurance, a "9-layer defense in depth" system + a three-terminal integrated situation awareness platform have been constructed.
The model Polar Fox Alpha S (L3 version) declared by BAIC Blue Valley also pays attention to safety. The car is equipped with 34 high-performance sensors, including 3 lidars, to achieve 360-degree all-round environmental perception coverage around the vehicle. And this version draws on the safety design concept in the aviation field to achieve full-link safety redundancy backup in aspects such as perception, decision-making, steering, braking, communication, power supply, and positioning.
BAIC Group stated that the JiFox Alpha S (L3 version) has undergone "rigorous functional testing and traffic regulation compliance testing, achieving full and complete coverage of scenarios within the design and operation range."
It can be seen that the decisive factor in whether L3 can obtain access permission is not the radical algorithm or cutting-edge route, but whether it can consistently implement security standards in real-life scenarios and whether it has a stable security level that covers the designed operation scenarios.

After flying over L2, what you see must be L3?
According to relevant regulations, Changan and BAIC Blue Valley must complete the on-road access pilot, pilot suspension and withdrawal, evaluation and adjustment and other processes before completing the pilot work. According to the plan, BAIC Blue Valley will start operations in specific scenarios in the first quarter of 2026.
Even if the entire pilot process is completed, it does not mean that the car company is qualified for L3 mass production, but it will at least allow the industry to see the dawn of L3 mass production.
Other car companies have also made progress in L3. Following BYD, Changan, GAC, SAIC, BAIC Blue Valley, FAW, NIO, Jikrypton, Cyrus, etc., Xpeng and Ideal have also obtained L3 test licenses.
It should be noted that the L3 test licenses recently obtained by Xpeng and Lideal are not equivalent to the product access licenses obtained by Changan and BAIC Blue Valley.
The Ministry of Industry and Information Technology once made a clear distinction between the two in the "Q&A". The test license is mainly used in the product development process and carries out actual road tests. Adequate road testing is not only an important basis for mass production and application of subsequent products, but also "an important basis for this pilot."
In other words, car companies must obtain an L3 test license before they can conduct on-road testing. Only after sufficient road testing has been conducted will the basic requirements for pilot application be met.
It is reported that BYD and Hongmeng Zhixing are currently working with the Shenzhen Municipal Transportation Bureau to launch L3 internal testing to accumulate experience. In addition, car companies that have not participated in centralized declaration before can also conduct pilot applications. Next year, more car companies may promote pilot work.
Some car companies have also announced more specific goals. In March, GAC announced that it would launch mass production of L3 models in the fourth quarter of this year. Huawei expects to achieve large-scale commercial use of high-speed L3 in 2026.

Image source: Weibo@huaweiqiankunsmart car solutions
Some models have even adopted the slogan of "L3 reserve army": models equipped with Huawei's ADS 4 Ultra flagship version have high-speed L3 capabilities. The Qianlihaohan H9 solution adopted by JKr 9X Hyper is an L3 solution with mass production capabilities. The Haobo A800, which has not yet been launched, has obtained the country's first license plate that can conduct L3 road tests at 120km/h.
The industry collectively sprints towards L3. But in this process, some "minorities" gradually emerged - they hope to jump from L2 to L3 and jump directly to L4.
In November, Xpeng Motors CEO He Xiaopeng said in a group interview on Xpeng Technology Day that there will be no L3 in the future, only L2 and L4. After trying out Tesla FSD, He Xiaopeng said that it was in the "quasi-L4" stage, and he firmly believed that "everyone can skip L3".
In December, Horizon Su Qing said that Horizon will "open up L2 to L4" in the future, and L3 is just a "short transition."

Image source: Horizon official
Earlier, Ford and Volvo also announced that they would abandon L3 and move directly to L4.
Gu Jianmin, the then R&D director of Volvo Cars China, explained: "Although the driver can let go, he must be ready to take over at any time. That is to say, we hope that the driver can 'turn a blind eye or close an eye', but at the same time, we require the driver to pay full attention at all times throughout the process. This is contradictory in itself."
For a long time, the difficulties related to the implementation of L3 were often understood as "boundary" issues. Level 3 means that the vehicle can drive autonomously in certain scenarios, but will remind the driver to take over when encountering complex situations. However, the main body of responsibility for L3 level has changed from the driver to the car company.
Because it is difficult to define what a "complex situation" is and the driving process involves "human" factors, it is difficult to divide responsibilities at L3 level, and relevant regulations have not yet been perfected. So much so that L4 is already commercially available, but L3 still has boundary problems.
But this is not the source of the current disagreement between "incremental" and "leapfrog" players. On the one hand, the current pilot work can provide support for the establishment of regulations. There is reason to believe that relevant regulations can be implemented within a certain period of time, and the division of responsibilities will no longer be controversial. On the other hand, and more importantly, the "turn" of Xpeng and Horizon is mainly due to technological updates.
Under Xpeng Motors' current technical route, private Robo and commercial Robotaxi can be implemented using the same system and the same hardware system. Horizon adopts a brand-new methodology, which can connect L2 to L4 with a unified development paradigm, unified sensor configuration, and unified ODD area.

He Xiaopeng and his team test drive FSD V14.2 in Silicon Valley
Image source: Weibo @XP-He Xiaopeng
However, L4 players in the industry give completely different views. In the eyes of Pony.ai CEO Peng Jun, the transformation from L2 to L4 is equivalent to “starting from scratch.”
Peng Jun said that L2 and L4 have different requirements in terms of data collection, sensor layout, safety requirements, etc., and basically need to be redone. Taking driving data as an example, L2 and L4 fields have different requirements for data density. Data collected by L2 may be addition and subtraction, while switching to L4 requires multiplication.
Of course, even if you want to be a progressive player who transitions from L2 to L3 step by step, it is not easy. According to WeRide CEO Han Xu, L3 is a simplified L4, rather than a simple upgrade of L2++. The distance from L3 to L4 is closer, but it is far away from L2++. "The distance is far beyond your imagination."

Image source: Autohome
So in the future, whether what is seen after L2 is L3 or L4, just like the current dispute between lidar and pure vision, no one has yet reached a conclusion. A more likely scenario is co-existence. This is determined by the technical solutions of the car companies.
Moreover, intelligent driving is developing rapidly, and it is common for technology routes to fluctuate. Just in September this year, Horizon President Chen Liming also said that "the progressive route is a better path to achieve L4, and Horizon adopts the progressive L4 route." At the beginning of this year, He Xiaopeng also said that Xiaopeng would invest in L3.
In recent times, they have switched sides to the "leapfrog" approach.
However, what is certain is that with the penetration rate of new cars with L2-level assisted driving functions exceeding 60% in the first three quarters of this year, L3 on-road pilots are about to begin, L4 commercialization is gradually taking shape, and future travel methods must be closely related to autonomous driving.

end
As 2025 comes to an end, a car company has finally obtained a product access pilot license, which will undoubtedly give a shot in the arm to L3 development.
In contrast, as early as 2022, Mercedes-Benz has deployed the L3 autonomous driving system (Drive Pilot system) in Germany, California and Nevada in the United States, and promised that if the driver is involved in a car accident while using the system, Mercedes-Benz will bear the responsibility.

Image source: Mercedes-Benz Star News
On the surface, Mercedes-Benz is the first to bring L3 to the personal consumer market, which is a big step ahead of other car companies.
However, it should be noted that Mercedes-Benz's L3 usage conditions have many restrictions: it cannot be used at night and in bad weather; it cannot change lanes; it cannot be used when encountering road construction, tunnels or toll stations; it must work at a speed of no more than 40 miles per hour (about 64 kilometers); it can only work on highways with clearly identifiable markings; after reminding the driver to take over, if the driver does not respond within 10 seconds, the system will drive the vehicle to the side of the road to call emergency services. After that, the system will exit or downgrade, and the driver will become the responsible person.
If the driving conditions are consistent, the existing high-speed NOA of domestic car companies can also achieve the driving experience of Mercedes-Benz L3. At least at the technical level, domestic car companies have the L3 capabilities of the Mercedes-Benz version.
After excluding the technical gap, some people may simply and crudely attribute the lack of commercialization of domestic L3 to the lack of regulatory regulations.
But this problem does not go to the core and is being addressed. One of the expectations of this pilot is to accelerate the formation of a complete, pragmatic and efficient system of laws, regulations, management policies and standards.
The real core can be seen from the pilot work requirements. For the implementation of emerging technologies, our country’s regulatory authorities attach great importance to safety that can be repeatedly verified in the real world. This takes time to explain.
As for whether we can be the first to "eat crabs" and whether we can "take the lead" to implement it, this is at best a pursuit, not the focus.
In addition, according to the announcement, the consortium of Changan and BAIC Blue Valley is respectively Chongqing Changan AutoLink Technology Co., Ltd. and Beijing Travel Auto Service Co., Ltd. It can be speculated that even if L3 truly enters the commercialization process, it may gradually transition from travel services to the personal consumption field.
Various signs explain why Chinese car companies are in full swing in research and development in the wave of electrification and intelligence, but have always been so cautious in implementing them - in our country, safety is the unshakable first priority.
And taking your time is itself a safety strategy.