Autonomous Vehicles (AVs) have the potential to provide numerous societal benefits, such as decreased road accidents and increased overall transportation efficiency. However, quantifying the risk associated with AVs is challenging due to the lack of historical data and the rapidly evolving technology. This paper presents a data-driven framework for comparing the risk of different AVs' behaviors in various operational design domains (ODDs), based on counterfactual simulations of "misbehaving" road users. We introduce the concept of counterfactual safety margin, which represents the minimum deviation from normal behavior that could lead to a collision. This concept helps to find the most critical scenarios but also to assess the frequency and severity of risk of AVs. We show that the proposed methodology is applicable even when the AV's behavioral policy is unknown -- through worst- and best-case analyses -- making the method useful also to external third-party risk assessors. Our experimental results demonstrate the correlation between the safety margin, the driving policy quality, and the ODD shedding light on the relative risk associated with different AV providers. This work contributes to AV safety assessment and aids in addressing legislative and insurance concerns surrounding this emerging technology.
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