NHTSA Engineering Analysis: FSD Collisions in Reduced Roadway Visibility Conditions (EA26-002)

EA26-002 at a glance

What is NHTSA investigating in the Tesla Cybertruck?

From NHTSA’s investigation summary:

The Office of Defects Investigation (ODI) is opening this Engineering Analysis to evaluate Tesla's Full Self Driving Beta and Full Self Driving (Supervised) (collectively, FSD) degradation detection system.

The focus of this investigation will be to assess the system's ability, when encountering reduced roadway visibility conditions, to detect degradation and alert the driver with sufficient time to respond.

ODI will evaluate the performance of FSD in degraded roadway conditions and the updates or modifications by Tesla to the degradation detection system, including the timing, purpose, and capabilities of the updates, and Tesla's assessment of their safety impact.

Tesla's FSD is an advanced driver assistance system (ADAS) that relies exclusively on vision-based cameras and the related FSD software to detect and respond to the roadway ahead, projecting a path forward based on traffic control devices, vehicles, pedestrians, and the roadway itself.

When Tesla began transitioning away from using both cameras and radars to an exclusively camera-based approach, known as Tesla Vision, in mid-2021, it developed and implemented a degradation detection system that it deployed by a software update to existing and new Tesla vehicles.

On June 28, 2024, the day after Tesla submitted the SGO report of the November 28, 2023 fatal crash listed in this document, Tesla began developing an update to the degradation detection system.

At this time, ODI does not have information on when the update was deployed and which vehicles have the updated system.

ODI discussed individual incidents and its initial findings during the PE phase of its investigation with Tesla.

As part of those discussions, Tesla's post-incident analysis indicated that the update to the degradation detection system, had it been installed on the vehicles at the time, may have affected 3 of the 9 incidents identified by ODI.

Tesla also described internal data and labeling limitations that prevented a uniform identification and analysis of crash events with the subject system engaged.

ODI believes this limitation could have led to under-reporting of subject crashes over portions of the defined time-period.

Available incident data raise concerns that Tesla's degradation detection system, both as originally deployed and later updated, fails to detect and/or warn the driver appropriately under degraded visibility conditions such as glare and airborne obscurants.

In the crashes that ODI has reviewed, the system did not detect common roadway conditions that impaired camera visibility and/or provide alerts when camera performance had deteriorated until immediately before the crash occurred.

Review of Tesla's responses revealed additional crashes that occurred in similar environments and where the system either did not detect a degraded state, and/or it did not present the driver with an alert with adequate time for the driver to react.

In each of these crashes, FSD also lost track of or never detected a lead vehicle in its path.

In upgrading PE24031 to an Engineering Analysis (EA), ODI will gather further information on the updated degradation detection system, including the status of updating vehicles and scope of compatible vehicles, the system's visibility degradation detection capability, and alerts or warnings to the driver.

Lastly, ODI will conduct analysis on six recent potentially related incidents.

These incidents can be found at NHTSA.gov under the following SGO report identification numbers: 13781-11937, 13781-13211, 13781-13569, 13781-13633, 13781-13693, 13781-13788.

The crashes included in the failure report summary can be found at NHTSA.gov under the following SGO report identification numbers: 13781-8004, 13781-7181, 13781-7381, 13781-7767, 13781-7964, 13781-8977, 13781-9267.

What is an engineering analysis?

Engineering Analysis is the second, deeper stage of a federal defect investigation, opened when a preliminary evaluation finds enough evidence. NHTSA can test vehicles and demand detailed engineering data, and this stage often ends with a recall or a recall request.

Did this investigation lead to a recall?

Not yet. The investigation is still open, and NHTSA has not listed a recall from it. Investigations can take months. If your vehicle already has the problem, document every dealer visit now.

Which vehicles are part of this investigation?

What are Tesla Cybertruck owners reporting to NHTSA?

NHTSA’s public database lists 7,227 owner complaints filed since 2020 for the vehicles in this investigation (all components). Complaints are unverified owner reports.

What should owners do?

1. Check your VIN at nhtsa.gov/recalls for any open recall on your vehicle.
2. If you have the problem NHTSA is investigating, take the vehicle to a dealer now and get a repair order, even if the dealer cannot find anything.
3. Keep a log of every time the problem happens: date, mileage and what happened. Photos and videos help.
4. File your own complaint at nhtsa.gov/report-a-safety-problem. Owner complaints are what start and expand investigations.
5. If the problem keeps coming back, talk to a lemon law attorney.

Recalls on the same vehicles

• 2026 Tesla Model Y Front Suspension Recall (26V558)
• 2021-2023 Tesla Model 3 Headlight Recall (26V507)
• 2026 Tesla Model Y Knee Bolster Recall (26V445)
• 2025-2026 Tesla Model Y Label Recall (26V315)
• 2021-2023 Tesla Model 3 Backup Camera Software Recall (26V283)
• 2024-2026 Tesla Cybertruck Brake Rotor Recall (26V255)
• 2024 Tesla Cybertruck Lighting Recall (25V735)
• 2024-2026 Tesla Cybertruck Lighting Recall (25V699)
• 2025 Tesla Model 3 Fuses Recall (25V690)
• 2026 Tesla Model Y Wiring Recall (25V658)

Can a recall or defect investigation make my car a lemon in California?

Not by itself. What matters is whether a covered defect keeps coming back or keeps your vehicle at the dealer, and a federal investigation or recall is strong evidence that the problem is real.

Under California’s Song-Beverly Consumer Warranty Act, a manufacturer that cannot fix a warranty defect that substantially impairs a vehicle’s use, value or safety within a reasonable number of attempts may have to repurchase or replace it (Civ. Code 1793.2(d)). Within the first 18 months or 18,000 miles, the law presumes a reasonable number of attempts after two repairs of a defect likely to cause death or serious injury, four repairs of the same defect, or more than 30 days out of service (Civ. Code 1793.22(b)).

An owner who prevails can recover reasonable attorney fees and costs from the manufacturer (Civ. Code 1794(d)). You pay nothing, win or lose. We are paid only if you win, and the manufacturer pays our fees, including in settlements. If a case is lost, our firm covers the costs.

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