The 3.2 Million Vehicle Investigation: NHTSA vs. Tesla FSD

In 2025, NHTSA opened investigation PE25012 into Tesla's Full Self-Driving (Supervised) system. By March 2026, it escalated to an "Engineering Analysis" — the final step before a potential mandatory recall. The scope: approximately 3.2 million Tesla vehicles equipped with FSD across Model S, Model 3, Model X, Model Y, and Cybertruck.

The Core Problem: Cameras Can't See

The investigation centers on a deceptively simple issue: Tesla's vision-only camera system fails in conditions where cameras struggle — glare, fog, low sun angles, and dust. Tesla removed radar and ultrasonic sensors from its vehicles starting in 2021, betting everything on cameras and neural networks. NHTSA's investigation suggests that bet isn't paying off.

The agency documented crashes where FSD failed to react to stationary objects, emergency vehicles with flashing lights, and vehicles in adjacent lanes — all in conditions with reduced visibility.

What's at Stake

If NHTSA determines a defect exists, Tesla could be forced to issue a mandatory recall — not just an over-the-air software update (which Tesla has used for previous "recalls"), but potentially a hardware fix. That would be unprecedented in scale for an automated driving system.

Tesla's total NHTSA incident count stands at 3,092 reported crashes with 56 fatalities. The PE25012 investigation could be the regulatory action that finally forces systemic changes to FSD's architecture.

Timeline of the Investigation

• 2021–2024: NHTSA receives increasing complaints about FSD crashes in low-visibility conditions
• 2025: Preliminary Evaluation (PE25012) opened
• March 2026: Escalated to Engineering Analysis (EA26-001) — the last step before recall
• 2026 and beyond: NHTSA expected to issue findings

The Broader Context

Tesla has already issued multiple FSD-related recalls via OTA updates, but critics argue software patches can't fix a fundamental sensor limitation. Meanwhile, competitors like Waymo use lidar, radar, and cameras together — a multi-sensor approach that provides redundancy in degraded conditions. Tesla's 56 fatalities vs. Waymo's 2 fatalities loom large in this debate.