Reform of Intelligence Service Law

"The VDA supports the legislator's aim of strengthening public safety and placing cooperation between security agencies and the business sector on a modern, transparent, and legally sound footing. In light of increasing industrial espionage, cyberattacks, and sabotage, protecting Germany as an industrial location is of great importance. Against this backdrop, it is essential that Germany protects its companies and key technologies more effectively. To achieve this, our security agencies require up-to-date legal tools.

At the same time, the relevant powers must be defined in a manner that is proportionate and ensures legal certainty: there must be no preemptive collection of additional vehicle data. Trade and business secrets must be protected, and existing European data protection and cybersecurity requirements must be taken into account. We also support the approach whereby data is made available via manufacturers or, alternatively, via repair shops. Any form of direct access to the vehicle itself must be rejected on safety grounds.

Further clarification is required, particularly regarding the planned new obligations for the German automotive industry to cooperate. A prerequisite for legal certainty is a clear distinction of these new obligations from the existing European legal framework governing data, data protection, and cybersecurity requirements. In particular, the term 'telemetry data' and the scope of corresponding requests for information must be precisely defined. It is a positive aspect that, in principle, only information that is already available is required to be disclosed. This must not give rise to a general obligation to collect or store additional vehicle data in anticipation of potential future requests from authorities.

It is a fact that vehicle manufacturers and suppliers are already subject to extensive European regulations. A coherent legal framework is therefore essential—one that takes existing compliance structures into account, avoids duplicative regulation, and ensures legal, planning, and investment certainty for companies. The VDA will constructively engage with the ongoing legislative process and advocate for a balanced legal framework that reconciles safety interests with data protection, innovation capacity, and business planning certainty."