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Michigan Governor Signs SB 198 Limiting Third-Party Access to Auto Dealer Data

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20

Why it matters

Governor Gretchen Whitmer signed Senate Bill 198 on October 9, 2026, creating the Motor Vehicle Dealer Data Collection Act as Public Act 113 of 2026. The law took effect immediately. It governs who may reach data stored in dealership computer systems, including dealer management and customer relationship management platforms. Dealers had complained that manufacturers and third-party vendors often demanded broad, sometimes unilateral, access to that data, frequently as a condition of joining manufacturer programs or receiving incentive payments. The act's core rule is consent: a third party may not access, share, sell, copy, use, or transmit protected dealer data without the dealer's prior written consent. Manufacturers face a parallel limit, with exceptions for "required manufacturer data," including diagnostic information and what is needed for warranty claims and recall notices. Vendors and integrators must follow their written agreements with dealers. Those agreements must be terminable within 90 days of notice. Dealers may request a list of who receives their data and audit how it is used. Dealer data vendors must also offer open application programming interfaces (APIs) so authorized integrators can exchange data.

The law covers three categories of data inside a dealer's system: consumer personal and financial information, motor vehicle diagnostic data, and records of the dealer's business operations. It does not reach data that is publicly available or that a manufacturer or third party obtains from another source. Data generated by a vehicle or a consumer's connected device falls outside the act. The statute does not name collision repair shops or other independent service providers, a gap trade publications have already flagged. Michigan's bill was introduced in 2025 and sponsored by Democratic Senator Sam Singh. It joins Arizona, Delaware, Florida, Georgia, Montana, North Carolina, Oklahoma, Oregon, Utah, Washington, and West Virginia in regulating dealer data access, according to the National Law Review.

Several questions remain open. Trade and legal commentary from mid-October and early November 2026 is still working through how the new rules apply in practice, and the act's treatment of independent repair providers is unresolved in the text.

Vendors and any firm offering financing, service, or data products to Michigan dealers should review contracts and data-sharing practices now, since the law is already in force. Check whether consent is captured in writing before any access, confirm that termination rights run 90 days, and confirm that APIs and audit-list obligations can be met. Watch for guidance or enforcement signals on what counts as "required manufacturer data" and on whether independent repair shops gain access rights.

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