The fix is software now, and so is the driver

A recall used to be a part. A bracket that cracks, a seat belt buckle that does not latch, an airbag inflator that ages badly. The manufacturer sends a letter, the owner books a visit, a technician replaces the part, and the vehicle is fixed in a way anyone can see.

That is no longer the typical case. In Canada the share of recalls fixed by changing software has more than doubled in six years, and the over-the-air share of those is rising faster still. The numbers are public. What they imply is less discussed: once the remedy is software, the question "does this recall apply to this vehicle?" and the question "what is this vehicle?" become the same question. Driving automation takes that to its end point, because there the software is the driver.

One recall in four is now a software change

Transport Canada publishes its Motor Vehicle Safety Recalls Database as a monthly file: one row per campaign, make, model and model year, with the notice text Canadians read, including a section headed "Corrective Actions".¹ We downloaded the file dated 24 September 2026, grouped it by recall number, and counted, for each year since 2019 (the first year every entry carries that section), the recalls whose corrective actions name a software change (software, firmware, reprogramming or reflashing), and within those, the ones whose corrective actions describe the update being delivered over the air or wirelessly.

Canadian recalls remedied with software, by year

2019: 62 of 594 recalls (10.4%) · 0 over the air; Transport Canada
2020: 60 of 536 (11.2%) · 3 over the air; Transport Canada
2021: 86 of 658 (13.1%) · 5 over the air; Transport Canada
2022: 83 of 635 (13.1%) · 11 over the air; Transport Canada
2023: 101 of 593 (17.0%) · 9 over the air; Transport Canada
2024: 142 of 670 (21.2%) · 16 over the air; Transport Canada
2025: 170 of 654 (26.0%) · 26 over the air; Transport Canada
2026 to 17 Sept: 94 of 426 (22.1%) · 19 over the air; Transport Canada

Every campaign in the database for the year, by recall date, including tires, child seats, trailers, buses and motorcycles. A software remedy is a campaign whose corrective actions name a software change; over the air is the subset whose corrective actions describe wireless delivery. Text matching reads what the notice says, so both counts are floors.

Figure 1 The share doubled from 2019 to 2025. Over-the-air remedies went from none in 2019 to 26 in 2025, and make up one in five software remedies in 2026 so far.

Two refinements sharpen it. The denominator above counts everything Transport Canada lists, including tires, child seats and trailers, which have no software to update. Among campaigns that name a passenger car, SUV, minivan, pickup or van, software remedies were 143 of 371 in 2025, or 38.5 percent. And the over-the-air share is a floor in a second sense: several manufacturers deliver the same change over the air to some vehicles and at the dealer to others, and a notice counts here as over the air only if it says so.

The United States shows the same curve. Applying the same test to the corrective-action summaries in NHTSA's recall file, software remedies were 8.2 percent of campaigns in 2019 and 20.0 percent in 2025, 199 of 995, with 36 describing over-the-air delivery.² The file has no field that marks a remedy as over the air; the notice text is the only public place it is written down, on either side of the border.

What the notices say

A Canadian recall starts with the manufacturer. A company that applies the national safety mark, sells or imports a vehicle must give notice of a safety defect to the Minister on becoming aware of it, and to the current owner.³ The public notice describes the remedy, and more and more of those descriptions are version numbers.

Take one configuration. Transport Canada lists eight campaigns naming the 2023 Model Y. Six are software remedies, and all six were delivered over the air.⁴

2023 Tesla Model Y

SUV

6recall campaigns on file

6 remedy available

Rearview camera delayTCRemedy available · May 5, 20262026-221
Power steering assistTCRemedy available · Jan 28, 20252025-034
Unlatched hood warningTCRemedy available · Jul 25, 20242024-427
Seat belt reminderTCRemedy available · May 28, 20242024-298
Brake telltalesTCRemedy available · May 21, 20242024-283
Autosteer driver monitoringTCRemedy available · Dec 12, 20232023-657

Figure 2 Six Transport Canada campaigns naming the 2023 Model Y, all remedied with a software update sent over the air. Each also names other models; the Autosteer campaign alone counts 192,769 Canadian units.

Four of the six notices end the same way. "There is no further action required if your vehicle has software release 2024.20.3 or a later release," reads the hood-warning campaign; the steering campaign names 2023.38.4, the camera campaign 2026.8.6.1, the brake-telltale campaign 2024.3.25 and 2024.14.5.⁴ The remedy is stated as a version. And campaign 2024-283 exists because of a version: "A previous over-the-air (OTA) software update could cause the vehicle not to display the correct visual warning indicators" for the brake system, which Canadian rules require to be symbols rather than words.⁴ An update created the defect, and another update fixed it.

The pattern is not one manufacturer's. The 2025 Tucson carries four campaigns, three of them software, two sent wirelessly with a dealer visit as the alternative, and one, a front camera that "could cause the forward collision avoidance (FCA) system to apply the vehicle's brakes suddenly", fixed only at the dealer.⁵

2025 Hyundai Tucson

Limited · SUV

4recall campaigns on file

4 remedy available

Cluster with HUD · over the airTCRemedy available · Jun 24, 20262026-308
Front camera software · dealerTCRemedy available · May 19, 20262026-238
Cluster software · over the airTCRemedy available · Jan 27, 20262026-033
Side curtain airbags · dealerTCRemedy available · Nov 20, 20252025-646

Figure 3 Four campaigns naming the 2025 Tucson; three are software. One names only hybrids and plug-in hybrids with a head-up display, which is why the word is applicable: a campaign that names a model year does not name every vehicle of it.

The safety state lives in the software

A part-based recall has a physical answer. The new bracket is on the car or it is not, and the VIN, which fixes the build at the plant, is enough to say whether a campaign could apply.

A software recall breaks that. Two vehicles with the same seventeen characters on the door frame, one updated last Tuesday and one not, are the same build in different safety states. The VIN says which campaigns name the vehicle. Only the installed version says where it stands against them. And the version moves: an update can close one campaign and, as 2024-283 shows, cause the next.

So the question a registrar, a lender, a fleet or a buyer is really asking, "which recalls are applicable to this vehicle, and has it been remedied?", resolves into three facts that have to be held together:

What the vehicle is. The configuration, read from the VIN against the manufacturer's evidence. We argued in the post on empty decodes that a field is published with its source or not at all, and the vehicles nobody could name showed how much of the fleet arriving now needs that.
What the campaigns say a fixed vehicle runs. Increasingly, a software release or later.
What the vehicle is running, and when that was true. A dated fact about one VIN.

The rulebook is moving toward the second and third. The car will tell you covered the amendment the UN adopted in November 2025: under the 01 series of UN Regulation No. 156, a manufacturer must assign a software identifier for every type approval its updates touch, and "shall not execute software updates to vehicles approved to the 01 series of amendments of this Regulation already registered in the market" unless one has been assigned.⁶ That rule identifies software by vehicle type. Nothing in it names the vehicle, and nothing in Canadian law records which version a given VIN carried on a given day.

When the software is the driver

Driver assistance supports a driver who remains responsible. Driving automation replaces the driver for some stretch of the journey. Either way, the thing doing the driving is code, and the code is updated after the sale like everything else in the car.

The first binding rule for it said so directly. UN Regulation No. 157, in force since 22 January 2021, governs Automated Lane Keeping Systems: a system that "keeps the vehicle within its lane for travelling speed of 60 km/h or less by controlling the lateral and longitudinal movements of the vehicle for extended periods without the need for further driver input".⁷ Every such vehicle must carry a Data Storage System for Automated Driving that records activation, deactivation, each transition demand, emergency manoeuvres and any detected collision. For each of those events, "the R15XSWIN for ALKS, or the software versions relevant to ALKS, indicating the software that was present at the time when the event occurred, shall be clearly identifiable".⁷ The data must be readable "at least through the standard interface (OBD port)", and where a manufacturer does not implement the identifier, "an alternative software identification system (i.e. software version) shall be implemented".⁷

Read that again as a recall question. The regulation does not only ask what the system can do. It asks which version of it was present at each moment it mattered.

On 24 June 2026 the World Forum for Harmonization of Vehicle Regulations adopted what the UN described as the first global regulations for fully autonomous driving systems, with support from Canada, China, the European Union, Japan, the United Kingdom and the United States.⁸ Two texts were before that session:⁹ a new UN Regulation under the 1958 Agreement and a draft Global Technical Regulation under the 1998 Agreement, to which Canada has been a party since 2000.¹⁰ Both carry the same thread.

Updates are regulated. The Regulation requires that an ADS whose software can be updated be shown to comply with UN Regulation No. 156 "according to its 01 or later series of amendments", the series that makes the identifier compulsory.¹¹ The GTR asks the manufacturer to document "software identification and version control" and "target vehicle identification and compatibility checks" for every update.¹²
Every vehicle records. The Regulation requires a data storage system for automated driving "capable of monitoring the safety performance of the ADS",¹¹ and the GTR uses the same words.¹²
Every occurrence is reported against a VIN and a version. The short-term report template, issued within 30 days of the manufacturer learning of a significant or critical occurrence, lists "Vehicle Identification Number" and "ADS identifier" as required fields. The annual periodic report lists "ADS software version/identifier(s)" as required.¹²

The design is a safety case that is re-proved in service, and the unit of proof is a vehicle, a version and a time.

Every regime asks which software was driving

The same question appears wherever automation is regulated, in different words.

Which software was driving, as each regime asks it

UN R157 (lane keeping): software identifier present at each recorded event; R157, 8.3.2
UN ADS Regulation and GTR: VIN and ADS identifier on each short-term occurrence report; WP.29, 2026
NHTSA crash reporting: automation feature version in use at the time; SGO, field 19
California DMV: collisions within 10 days; updates certified at deployment; 13 CCR 228.06
Transport Canada: version in operation, past and pending updates; TC, element 11

Primary sources only, read at source. Each regime asks the manufacturer for the version at the time of the event; none publishes it against the full VIN for the next reader.

Figure 4 Five regimes, one question. The answer is always a fact about one vehicle at one moment.

The United States.

NHTSA's Standing General Order 2021-01 collects crash reports involving automated driving systems and Level 2 driver-assistance systems. Field 19 of each report is "the system or automation feature version of the ADAS or ADS in use on the subject vehicle at the time of the incident".¹³ The public file shows how that answer travels. In the driver-assistance reports submitted from June 2025 to August 2026, 2,186 in their latest version, the reporting entity claimed the version as confidential business information in 1,978, or 90.5 percent. In the automated-driving file, 1,437 reports, the claim was made in 36.¹⁴ The published VIN is cut to its first 11 characters, because NHTSA concluded the last six "may lead to the identification of individuals involved in a crash".¹³ That is a sound privacy rule, and it means the public record of which software was driving cannot be joined back to one vehicle from the public file.

The agency is also shaping the global text. In January 2026 NHTSA asked for public comment on the draft ADS regulation, noting that the draft includes "post-deployment monitoring capabilities" and that each 1998 Agreement party "is expected to initiate processes to incorporate parts or all of the GTR" into its own rules.¹⁵

California.

A manufacturer testing under a California permit must report any collision that damages property or injures anyone within 10 days on form OL 316,¹⁶ and must file an annual report summarizing disengagements of the autonomous mode, with the circumstances and "the party that initiated the disengagement".¹⁷ To deploy, it must certify that "it will make available updates pertaining to the autonomous technology at least annually", keep mapping current "on a continual basis", and tell registered owners how to get the updates.¹⁸ A safety-related defect in the autonomous technology goes to the department as a copy of the federal Part 573 report, the same filing a recall starts from.¹⁹ Collision reports are published;²⁰ the updates, by design, never stop.

Canada.

Transport Canada's published tools for automation are non-regulatory guidance, and they ask the question in plain words. The Safety Assessment for Automated Driving Systems, a voluntary tool for developers of SAE level 3 to 5 systems, asks: "Is the vehicle equipped with an auditable version control system that shows the system version in operation, past and/or pending updates? How is the information presented or accessed?"²¹ It asks developers to update their assessments "as the ADS features are refined through software updates".²¹ Its testing guidelines say trial personnel "should be informed of any over-the-air updates performed to the vehicle's software".²²

Five regimes, five vocabularies, one requirement: when something happens, say which software was in control. Each regime asks the manufacturer, at the time, for its own purpose. None of them leaves behind a record of that vehicle's software history that the next reader can use: the buyer, the lender, the province that registers it, the assessor after a claim.

What the record has to hold

The recall count and the autonomy rules are one story told twice. In both, the state that matters for safety is a software version, the version changes after the sale, often without a visit, and the authority that needs the answer asks the manufacturer for it after the fact.

A record that answers both has a small, strict shape. It is keyed on the VIN, because that is the key every one of these regimes uses, from the Canadian notice to the UN occurrence template. It carries the configuration, read from evidence. It carries the campaigns that name that configuration, from Transport Canada, with what each says a remedied vehicle should run. And it carries software identity as dated observations: this module, this version, read on this day, kept so that it can be read back later. The port under the dash can report what is installed; it cannot say whether a recall is complete, and the record does not pretend it can. It says what was observed, when, and next to which campaigns.

Held that way, the questions stop being separate. "Is this recall applicable?" is a join between the configuration and the campaign. "Where does this vehicle stand against it?" is a comparison between the campaign's version and the last observed one, with its date. "Which software was driving on the fourteenth?" is the same observation, asked about a different day.

What Cardog does

Cardog keeps the record of the Canadian vehicle, keyed on the VIN. The configuration is decoded from evidence, with its source on every field. The recalls are Transport Canada's, joined to the configuration they name and called applicable, because that is what the public record can support. Software identity, where a vehicle reports it, is held beside them as a dated fact.

In 2019 one Canadian recall in ten was a software change. In 2025 it was one in four, and the vehicles that drive themselves for part of a trip are subject to rules that ask for the version at every event. The build is still where a vehicle's identity begins. More and more, its safety state is the software it is running now.

Talk to us about the record.

Sources

Vehicle Recalls Database, Transport Canada, Open Government Portal (Open Government Licence, Canada), dataset page and full monthly CSV (file last modified 24 September 2026, retrieved 25 September 2026; 17,966 recall numbers; latest recall date 17 September 2026), open.canada.ca and opendatatc.tc.canada.ca ↑
NHTSA recalls flat file FLAT_RCL_POST_2010 (file last modified 24 September 2026, retrieved 25 September 2026), field 22 CORRECTIVE_ACTION, by field 16 report received date, and file description RCL.txt, National Highway Traffic Safety Administration, static.nhtsa.gov and static.nhtsa.gov ↑
Motor Vehicle Safety Act, S.C. 1993, c. 16, section 10(1), Justice Laws Website, laws-lois.justice.gc.ca ↑
Transport Canada Recall Details 2023-657, 2024-283, 2024-298, 2024-427, 2025-034 and 2026-221, Motor Vehicle Safety Recalls Database, wwwapps.tc.gc.ca, wwwapps.tc.gc.ca, wwwapps.tc.gc.ca, wwwapps.tc.gc.ca, wwwapps.tc.gc.ca, wwwapps.tc.gc.ca ↑ ↑ ↑
Transport Canada Recall Details 2025-646, 2026-033, 2026-238 and 2026-308, Motor Vehicle Safety Recalls Database, wwwapps.tc.gc.ca, wwwapps.tc.gc.ca, wwwapps.tc.gc.ca, wwwapps.tc.gc.ca ↑
Proposal for a new 01 series of amendments to UN Regulation No. 156, ECE/TRANS/WP.29/2025/142, new paragraphs 7.1.1.3 and 7.1.4, UNECE, documents.un.org ↑
UN Regulation No. 157, Uniform provisions concerning the approval of vehicles with regard to Automated Lane Keeping Systems, E/ECE/TRANS/505/Rev.3/Add.156, in force 22 January 2021, paragraphs 2.1, 8.2.1, 8.3.2, 8.4.4 and 9.3.1, United Nations, documents.un.org ↑ ↑ ↑
New global rules clear the road for driverless vehicles, UN News, 24 June 2026, news.un.org ↑
Annotated provisional agenda for the 199th session of the World Forum, Geneva, 23 to 26 June 2026, ECE/TRANS/WP.29/1191, 31 March 2026, items 4.14.2 and 14.1.1, UNECE, documents.un.org ↑
Status of the 1998 Agreement, of the Global Registry and of the Compendium of Candidates, ECE/TRANS/WP.29/1073/Rev.40, list of Contracting Parties (Canada, 25 August 2000), UNECE, documents.un.org ↑
Proposal for a new UN Regulation on uniform provisions concerning the approval of motor vehicles with regard to their Automated Driving Systems, ECE/TRANS/WP.29/2026/137, 14 April 2026, paragraphs 6.3.1.1, 6.3.2.1 and 6.3.3.1, UNECE, documents.un.org ↑ ↑
Proposal for a new United Nations Global Technical Regulation on Automated Driving Systems (ADS), ECE/TRANS/WP.29/2026/139, 14 April 2026, paragraphs 4.3.1.1, 4.3.3.1, 5.4.8 and 5.4.9, Annex 2 (short-term reporting template) and Annex 3 (periodic reporting template), UNECE, documents.un.org ↑ ↑ ↑
Standing General Order 2021-01 Data Dictionary, 15 September 2026, section 1 and Table 3, fields 8, 19 and 20, National Highway Traffic Safety Administration, static.nhtsa.gov ↑ ↑
Standing General Order 2021-01 incident report files for ADS and Level 2 ADAS (retrieved 25 September 2026; reports submitted June 2025 to August 2026, latest version of each report), fields "Automation Feature Version" and "Automation Feature Version CBI", National Highway Traffic Safety Administration, static.nhtsa.gov and static.nhtsa.gov ↑
Notice and Request for Comment; Proposal for a New United Nations Global Technical Regulation on Automated Driving Systems (ADS), Docket NHTSA-2026-0034, FR Doc. 2026-01274, 23 January 2026, National Highway Traffic Safety Administration, public-inspection.federalregister.gov ↑
California Code of Regulations, Title 13, § 227.48, Reporting Collisions, Legal Information Institute, law.cornell.edu ↑
California Code of Regulations, Title 13, § 227.50, Reporting Disengagement of Autonomous Mode, subsections (a) and (b)(3), Legal Information Institute, law.cornell.edu ↑
California Code of Regulations, Title 13, § 228.06, Application for a Permit for Post-Testing Deployment of Autonomous Vehicles on Public Roads, subsection (a)(9)(A) to (C), Legal Information Institute, law.cornell.edu ↑
California Code of Regulations, Title 13, § 228.12, Reporting Safety Defects, Legal Information Institute, law.cornell.edu ↑
Autonomous Vehicles, California Department of Motor Vehicles (permit types, collision reports, disengagement reports), dmv.ca.gov ↑
A Safety Assessment for Automated Driving Systems in Canada, Transport Canada, January 2019, executive summary, element 11 (System Updates and After-Market Repairs/Modifications) and question 11(a), tc.canada.ca ↑ ↑
Guidelines for Testing Automated Driving Systems in Canada, Version 2.0, TP 15482E, Transport Canada, 2021, tc.canada.ca ↑