From ConOps to Approval: Regulatory and Commercial Pathways for Demonstrating Autonomous Inland Shipping between Terneuzen and Ghent

Abstract

The transition to autonomous inland shipping in Europe requires not only technical maturity but also collaborative, transparent, and reproducible approval processes. This paper presents a structured approach to securing permits for an autonomous vessel demonstration on the cross-border waterway between Terneuzen (NL) and Ghent (BE), a milestone within the AUTOFLEX project. Rather than focusing solely on regulatory frameworks, we analyze both the legal requirements and the commercial acceptability of risk, recognizing the interplay between hard governance (laws, decrees, administrative procedures) and soft governance (stakeholder trust, market readiness, and operational risk tolerance). The Flemish framework, based on Article 70 of the Scheepvaartdecreet, provides a model for testing autonomous systems under temporarily adapted legal conditions, while Dutch authorities emphasize risk acceptability in practice. To ensure balance and transparency, the paper integrates perspectives from authorities and stakeholders, capturing their views on challenges in the approval process. Approval is structured around a Concept of Operations (ConOps), complemented by a maritime adaptation of the Specific Operations Risk Assessment (SORA) method. Together with validation data, these elements form a Comprehensive Safety Portfolio (CSP) that supports both regulatory and commercial decision-making. The result is a blueprint for future pilot projects that bridges innovation, governance, and market viability, laying the foundation for sustainable deployment of autonomous inland vessels across Europe.