The Fédération Internationale de l’Automobile – European Bureau (FIA EB) invites proposals for a comprehensive study on interoperability and consumer rights in digital services linked to connected products and mobility. The study forms part of FIA Region I’s broader policy work on consumer protection, digitalisation, and interoperability in mobility ecosystems. As vehicles and other connected products increasingly rely on software-based services, ensuring that consumers retain meaningful control, transparency, and the ability to switch providers is becoming a central policy priority.
This research aims to assess the consumer and market implications of over-the-air (OTA) software updates, digital subscriptions, and the transfer of ownership of software-based services, with a particular focus on lock-in risks, data portability, consumer awareness and transparency of service conditions.
Context of the Study
The increasing digitalisation of products and services, including vehicles and other connected devices, is reshaping traditional notions of ownership, use, and consumer rights. Software-based functionalities, over-the-air updates, and subscription-based models are becoming central features of digital ecosystems.
In the mobility and automotive sectors in particular, consumers are increasingly purchasing products that rely on embedded software and digital services, which may be updated, modified, restricted, or monetised throughout the product lifecycle. Functionalities can be activated or deactivated remotely, features may depend on subscription payments, and certain services may not automatically transfer when a product is resold.
While these developments create opportunities for innovation and enhanced services, they also raise significant questions regarding:
At EU level, the Digital Services Act, the Digital Markets Act, the Data Act, the Consumer Rights Directive, and the Sale of Goods Directive form part of a rapidly evolving regulatory framework. However, important uncertainties remain regarding how these rules apply in practice to software-based services embedded in connected products.
This study will assess the practical implications of these developments from a consumer and mobility perspective, identify risks and best practices, and provide actionable recommendations to ensure that digitalisation strengthens – rather than undermines – consumer protection, competition, and interoperability.
Scope of Work
The contractor is expected to prioritise analytical depth over exhaustive market coverage. Rather than attempting a comprehensive mapping of all digital services, the study should focus on the most relevant and illustrative examples affecting consumers in connected product ecosystems, particularly in the mobility sector.
Where appropriate, the research should include a limited number of focused case studies that illustrate practical consumer impacts and regulatory challenges.
The selected contractor will be responsible for conducting research in the following key areas:
1. Over-the-Air Updates and Consumer Rights
• Analyse the legal and practical implications of OTA updates, including mandatory vs. optional updates, security updates, feature modifications, and performance changes.
• Assess how OTA updates may affect product conformity, durability, and long-term usability.
• Examine whether consumers are adequately informed and able to give meaningful consent to significant software changes.
• Evaluate potential risks where updates restrict interoperability or limit third-party services.
2. Digital Subscriptions and Software-Based Functionalities
• Map current subscription-based models for digital services linked to connected products, including feature activation, bundled services, and pay-per-use models.
• Assess risks of consumer lock-in resulting from proprietary ecosystems, technical barriers, or contractual restrictions.
• Examine switching barriers and the extent to which consumers can effectively change providers without disproportionate costs or loss of functionality.
• Analyse transparency of pricing structures, renewal conditions, termination clauses, and changes to subscription terms.
3. Ownership Transfer and Secondary Markets
• Assess how digital subscriptions and software-based functionalities are treated when a product is resold (e.g. vehicle resale or transfer of connected devices).
• Identify legal and technical barriers to transferring digital services or licences to a new owner.
• Evaluate implications for product value, consumer expectations, and secondary markets.
• Examine compatibility with EU consumer and data protection rules.
4. Lock-in Risks and Data Portability
• Analyse lock-in risks linked to closed ecosystems, restricted interoperability, and limited access to user data.
• Assess how data portability rights under EU law function in practice in the context of embedded digital services.
• Identify technical and contractual barriers to effective portability and interoperability.
• Evaluate potential remedies or regulatory clarifications needed to strengthen consumer choice and competition.
5. Consumer Awareness, Consent and Transparency
• Assess the clarity, accessibility, and fairness of service conditions governing OTA updates and digital subscriptions.
• Analyse how consent is obtained for software changes, data processing, and service modifications.
• Identify best practices for transparent communication, including layered information models and standardised disclosures.
• Evaluate whether current practices allow consumers to make informed decisions throughout the product lifecycle.
6. Best Practices and Policy Recommendations
• Identify examples of good practice that promote interoperability, transparency, and consumer empowerment.
• Develop clear, actionable recommendations for policymakers at EU and national level.
• Provide guidance for Mobility Clubs and consumer organisations on how to support members navigating digital service ecosystems.
Proposal Submission
Interested parties are invited to submit detailed proposals outlining their approach, methodology, timeline, and budget for the research project. Proposals should include:
Proposals should be sent to Ellen Magg, Policy Officer, at emagg@fia.com by 7 April 2026
Selection Criteria
Proposals will be evaluated based on the following criteria:
1. Proven expertise in EU digital regulation, consumer protection, and data governance.
2. Demonstrated experience in conducting policy impact assessments and market analyses.
3. Experience analysing interoperability challenges, digital ecosystems, or platform-based service models.
4. Ability to translate legal and technical analysis into clear, actionable policy recommendations.
5. A clear, detailed, and feasible research methodology.
6. Budget competitiveness.
7. Ability to deliver within the proposed timeline.
Timeline
Budget and Payment
A maximum budget of €60.000 (including VAT, if applicable) is available. 40% of the agreed costs will be paid once the contractor is appointed, and 60% will be paid once the
research is concluded and the final report is approved. The budget must include all expenses, including potential travel costs.
About the FIA European Bureau
The FIA European Bureau (EB) brings together 105 Mobility Clubs and their 40 million members from across Europe, the Middle East and Africa. Our members provide roadside assistance, legal advice, insurance, and many other services to their members.
The FIA EB aims:
1) to provide strong representation of European Member Clubs’ interests towards the European Union institutions – for example on road safety, consumer protection, environmental protection, and the promotion of sustainable motoring.
2) to build up links and support the exchange of best practices between our Member Clubs across Europe, Africa, and the Middle East.
3) to engage in new campaign activities together with Automobile Clubs throughout the region, such as the FIA Action for Road Safety campaign.
