2021-2022 Volvo XC40 Electrical Management System Software Recall (21V109)
Volvo Car USA, LLC · 2,278 vehicles · Reported February 24, 2021
Volvo Car USA, LLC is recalling 2,278 2021-2022 Volvo XC40 vehicles. The Battery Energy Control Module (BECM) microprocessor may reset and cause the high voltage system to disconnect. A disconnected high voltage system can cause a loss of drive power, increasing the risk of a crash. Dealers will make the repair free of charge.
Recall 21V109 at a glance
| NHTSA campaign number | 21V109000 |
|---|---|
| Manufacturer recall number | R10078 |
| Date reported to NHTSA | February 24, 2021 |
| Manufacturer | Volvo Car USA, LLC |
| Vehicles | 2021-2022 Volvo XC40 |
| Units affected | 2,278 |
| Component | Electrical System > Propulsion System > Traction Battery > Management System / Energy Control Module (Bms / Becm) > Software |
| Safety risk | A disconnected high voltage system can cause a loss of drive power, increasing the risk of a crash. |
| Fix | Available at dealers |
What is wrong with the 2021-2022 Volvo XC40 in recall 21V109?
The Battery Energy Control Module (BECM) microprocessor may reset and cause the high voltage system to disconnect.
Volvo Car USA, LLC (Volvo Car) is recalling certain 2021-2022 XC40 Recharge vehicles. The Battery Energy Control Module (BECM) microprocessor may reset and cause the high voltage system to disconnect.
Owners may also contact the National Highway Traffic Safety Administration Vehicle Safety Hotline at 1-888-327-4236 (TTY 1-800-424-9153), or go to www.safercar.gov.
Is it safe to drive a 2021-2022 XC40 with recall 21V109?
NHTSA has not told owners to stop driving, but the risk is real: A disconnected high voltage system can cause a loss of drive power, increasing the risk of a crash.
NHTSA describes the risk this way: A disconnected high voltage system can cause a loss of drive power, increasing the risk of a crash.
NHTSA has not issued a do-not-drive or park-outside warning for this recall. Still, get the repair done as soon as it is available, and stop driving if you notice symptoms related to the software.
Which vehicles are included in recall 21V109?
Recall 21V109 covers 2,278 vehicles: 2021-2022 Volvo XC40.
NHTSA lists 2,278 vehicles in this campaign. Not every vehicle of these models and years is included, so check your VIN.
| Model years | Make | Model |
|---|---|---|
| 2021-2022 | Volvo | XC40 |
What is the fix for the XC40 electrical management system software recall?
Yes. Volvo Car will notify owners, and dealers will install a software update, free of charge.
Volvo Car will notify owners, and dealers will install a software update, free of charge. The recall began March 30, 2021. Owners may contact Volvo Car customer service at 1-888-458-1552. Volvo Car's number for this recall is R10078.
When was recall 21V109 announced?
Volvo Car USA, LLC reported recall 21V109 to NHTSA on February 24, 2021.
| Date | What happened |
|---|---|
| February 24, 2021 | Volvo Car USA, LLC filed the defect report with NHTSA; NHTSA assigned campaign 21V109000. |
This recall was filed 68 months ago. If your XC40 was built in that window, the VIN check below is the way to confirm it is included.
How do I check if my XC40 is part of recall 21V109?
Enter your 17-character VIN at nhtsa.gov/recalls. If recall 21V109 is open on your XC40, it will be listed there.
The fastest check is NHTSA’s VIN lookup. Type in the 17 characters from your registration or insurance card. Because only some 2021-2022 XC40 vehicles are included, the VIN check is the only reliable way to know. A brand-new recall may take several days to show up.
What should XC40 owners do about recall 21V109?
Check your VIN, schedule the free recall repair, and keep a repair order for every dealer visit.
- Check your VIN at nhtsa.gov/recalls to confirm recall 21V109000 applies to your XC40.
- Book the recall appointment with any authorized Volvo dealer. Ask up front whether parts are available and how long the vehicle will be there.
- Get a repair order for every visit, even if the dealer only inspects the vehicle. Read it before you leave and make sure your complaint is written the way you described it.
- Keep a simple log of any software symptoms with dates and mileage. Video of a warning light or the problem happening is strong evidence.
- Count the days the vehicle is at the dealer. Days out of service add up toward California's 30-day presumption.
- If the problem comes back after the repair, return to the dealer and contact a lemon law attorney.
What are XC40 owners reporting to NHTSA?
Owners have filed 89 complaints with NHTSA about these vehicles since 2020, 18 of them about the ev and hybrid battery.
Since recall 21V109 was reported on February 24, 2021, owners have filed 18 complaints with NHTSA about the ev and hybrid battery on these vehicles. 3 of them (17%) describe the same problem happening more than once or coming back after a repair attempt.
How we counted: we matched NHTSA owner complaints for the model years in this recall that list the ev and hybrid battery and were received on or after February 24, 2021, then flagged narratives that describe a repeat failure or a problem returning after a dealer repair, recall service or software update. Data from NHTSA, accessed October 1, 2026. Complaints are unverified owner reports and may involve a related ev and hybrid battery issue rather than this exact defect; automated text matching can miss or misread some reports.
NHTSA’s public complaint database lists 89 owner complaints filed since 2020 for the vehicles in this recall, and 18 of them involve the ev and hybrid battery. Complaints are reports from owners and have not been verified by NHTSA, but a high count for the same component is a sign the problem is widespread.
- 2021 Volvo XC40: 52 complaints in total, 14 about the ev and hybrid battery
- 2022 Volvo XC40: 37 complaints in total, 4 about the ev and hybrid battery
Examples of what owners have reported to NHTSA (unverified excerpts):
The 12-volt battery has failed on 5 occasions. Each time, I tried to unlock the vehicle after being away from it for a short period (e.g., 5-40 minutes). I had to use the manual key to unlock the vehicle, but the vehicle wouldn't start. I had the vehicle towed 4 times.
2021 Volvo XC40 owner, WA, NHTSA complaint 11634084, filed January 4, 2025
Turning out of parking lot , car started pulsing, and stopped. Propulsion failure box popped up. Thankfully no cars behind us (young daughter in car seat)or was not attempting to merge on highway. Tow truck manually pulled car as no electric (cannot unlock or open trunk), completely shut down.
2021 Volvo XC40 owner, PA, NHTSA complaint 11662285, filed May 21, 2025
1. OBC failure. Stranded unable to charge. Situational could be dangerous. 2. Rt side mirror defaults to extreme angle after locking car evert time. Dealership could not troubleshoot solution.
2021 Volvo XC40 owner, MD, NHTSA complaint 11677385, filed July 30, 2025
Can recall 21V109 make my XC40 a lemon in California?
Not by itself. A recall repair that fails, or repeat dealer visits for the same defect, can support a California lemon law claim.
Recall 21V109000 does not automatically make your XC40 a lemon. California's Song-Beverly Act asks two questions: does a warranty defect substantially impair the vehicle's use, value or safety, and did the manufacturer fail to fix it in a reasonable number of tries (Civ. Code 1793.2(d))?
Battery and electric drive repairs are among the slowest repairs in the industry. A 2021-2022 Volvo XC40 waiting on a battery module or drive unit can sit at the dealer for weeks, and every day counts toward the 30-day figure in California's lemon law presumption.
The recall repair is available at dealers. If it works, great. If the same symptom comes back, the recall visit is one repair attempt and the next visit is another.
California law presumes a reasonable number of attempts has been made if, within 18 months or 18,000 miles of delivery, the same problem was repaired two or more times for a defect likely to cause death or serious injury, four or more times for any covered defect, or the vehicle was out of service for repairs more than 30 days in total (Civ. Code 1793.22(b)). Some of these require written notice to the manufacturer. A claim can still succeed outside that window.
An owner who prevails in a lemon law case 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.
In our cases, a recall repair visit counts as a repair attempt, and it's strongest when the owner complained about the problem before the recall came out. A recall shows the defect is real and that enough owners reported it for the manufacturer to issue a fix.
A software update can count as a repair attempt, especially if you complained about the problem or the update keeps being repeated. I've seen dealers do the same software update five or six times with no fix.
Recall repairs depend on parts. Owners can wait days, weeks or months, usually about one to three months in our cases, and those days count toward California's 30-day out-of-service rule.
The biggest mistake I see is waiting too long. The mileage offset starts at your first repair visit for the problem, so the sooner you take it in, the better. If the problem comes and goes, take it in when it happens. You can't go back to that date later.
If you get a recall notice, call a lemon law attorney right away. You may have taken the car in for the same problem before and forgotten, or there may be other recalls related to it.
Jacob Shayesteh, Esq. (SBN 362320), Founder and Managing Attorney. Quotes lightly edited for clarity. Prior results do not guarantee a similar outcome.
Has your XC40 been back to the dealer for this problem?
Call 877-536-6620Other Volvo XC40 recalls
Frequently asked questions about recall 21V109
Did the recall 21V109 fix work?
Since recall 21V109 was reported on February 24, 2021, owners have filed 18 complaints with NHTSA about the ev and hybrid battery on these vehicles. 3 of them (17%) describe the same problem happening more than once or coming back after a repair attempt. If your vehicle still has the problem after the recall repair, go back to the dealer, get a repair order, and talk to a lemon law attorney.
Is the 21V109000 recall repair free?
Yes. Safety recall repairs are done free of charge at authorized dealers.
How do I know if my XC40 is part of recall 21V109000?
Enter your 17-character VIN in NHTSA's recall lookup at nhtsa.gov/recalls, or call a dealer. The VIN is on your registration, insurance card and the lower corner of the windshield.
Can a battery recall reduce my EV's range?
Some battery recalls limit the state of charge or range until a module or pack is replaced. Check your owner letter for any interim limits, and keep notes if range or charging changes after the repair.
Does a recall mean my car is a lemon?
Not on its own. A lemon law claim depends on whether a covered defect keeps coming back or keeps the vehicle out of service. A recall repair that fails, or repeat visits for the same problem, can support a claim.
Does the recall fixing my car mean I have no case?
Not necessarily. Even if the recall repair fixed it, you may still have a case, and a car that's a year or more old can still qualify.
Do used cars qualify for California lemon law?
We take certified pre-owned, demo and dealer vehicles. Since the California Supreme Court's Rodriguez decision in 2024, ordinary used cars generally do not qualify.
How long does a recall lemon law case take?
Recall-related cases typically resolve in one to three months from your first call. Prior results do not guarantee a similar outcome.
What does a lemon law attorney cost?
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.
Sources
- NHTSA recall record 21V109000 (recall report and owner letters are posted there)
- NHTSA complaints and recalls data, accessed October 1, 2026
- California Civil Code 1793.2 and 1793.22
Attorney advertising. America’s Lemon Lawyer is a trade name of Wynn Law Group, APC. Responsible attorney: Jacob Shayesteh, Esq. (SBN 362320). This page is general information, not legal advice. America’s Lemon Lawyer is not affiliated with NHTSA or Volvo. Prior results do not guarantee a similar outcome.