Reference
Over-the-air recalls
Some safety recalls are fixed by a software update sent to the car over a wireless connection. Here is how those recalls work under federal rules, how owners are told, how to check that the update reached your car, and what happens when it doesn't.
The short answer
An over-the-air (OTA) recall is a safety recall whose remedy is a software update sent to the vehicle over a wireless connection, instead of work done in a service bay. The way the fix is delivered changes nothing about the legal process. The manufacturer still files a defect or noncompliance report with NHTSA, still mails owner notification letters, still has to provide the remedy free of charge, and still reports to NHTSA how many vehicles have been fixed.
For an owner, the practical question is whether the update actually reached your car. NHTSA's VIN search and the manufacturer's own lookup answer that. RunThatVIN lists recall campaigns by year, make and model; it does not check whether a recall, OTA or otherwise, has been completed on your car.
Why a software fix is still a recall
Under 49 U.S.C. 30118, a recall is triggered by a finding, not by the kind of repair. A manufacturer has to notify NHTSA, owners, purchasers and dealers when it decides in good faith that a defect is related to motor vehicle safety, or that a vehicle does not comply with a Federal Motor Vehicle Safety Standard. NHTSA can also decide this itself and order a recall. A problem in software carries the same duty as one in a brake line. Our guide to how vehicle recalls work covers the process in full.
What follows from that finding is the same for software:
- A Part 573 report. Under 49 CFR 573.6, the manufacturer reports to NHTSA not more than 5 working days after it determines that a safety defect or noncompliance exists, describing the affected vehicles, the defect, its safety risk and the remedy program.
- A free remedy. Under 49 U.S.C. 30120, the manufacturer must remedy the defect without charge. The statute does not carve out software fixes. The free remedy does not apply if the first purchaser bought the vehicle more than 15 calendar years before the recall notice.
- Progress reports. Under 49 CFR 573.7, the manufacturer files quarterly reports for six consecutive quarters, unless NHTSA directs otherwise, counting the vehicles that have been inspected and repaired and those that could not be reached.
- Limits on selling new vehicles. Under 49 U.S.C. 30120(i), a dealer may not sell or lease a new vehicle covered by a recall notice until the remedy has been done.
NHTSA also treats OTA recalls as worth watching. Its January 2025 report on recall completion rates lists remedies involving over-the-air updates as one of seven criteria it uses to flag a recall as high risk. Its 2025 annual recalls report charts, by manufacturer, the recalls and recalled vehicles that were partially or fully remedied using OTA updates from 2021 to 2025.
Two examples from NHTSA's records
Both of these recalls involve the rearview camera, and in both the manufacturer reported that the vehicles did not comply with FMVSS No. 111, the federal rear visibility standard.
Recall 24V-246
Hyundai recalled certain 2024 Santa Fe vehicles, 18,206 potentially affected, because a trailer parking assist message could block the rearview camera image. NHTSA's recall record says the remedy is an over-the-air software update and that owner letters were mailed beginning 31 May 2024. The owner letter says the OTA update is available only on vehicles that are enabled and opted in to receive updates through the manufacturer's connected service, and takes about 5 to 10 minutes to install. If the owner does not want the OTA update, or it fails, the letter says a dealer will update the software at no charge, in under an hour.
Recall 25V-002
Tesla recalled certain Model 3, Model S, Model X and Model Y vehicles from model years 2023 to 2025, 239,382 potentially affected, because a car computer circuit board could short and cause loss of the rearview camera image. Its Part 573 report says affected vehicles began receiving the OTA update on or shortly after 18 December 2024, before the report was filed in January 2025, and it names the software versions that contain the fix. NHTSA's record says the manufacturer will also identify vehicles whose circuit board already failed, or was under stress that may lead to failure, and replace those computers free of charge. Owner letters were mailed on 7 March 2025.
So a fix already installed is still a recall, with a report and owner letters, and software is not always the whole remedy.
How owners are notified
The formal notice is a letter. Under 49 CFR 577.7, owner notification must go out no later than 60 days after the manufacturer files its Part 573 report, by first-class mail to each person registered under state law as the vehicle's owner. Under 49 CFR 577.5, the letter opens with “IMPORTANT SAFETY RECALL”, describes the defect and the risk, and says whether the remedy is free and whether it is a repair, a replacement or a refund.
Section 24104 of the FAST Act (Pub. L. 114-94) directed NHTSA to add notification by electronic means to first-class mail, and a May 2020 NHTSA report found that in-vehicle systems may be functionally capable of showing owners an open recall. Even so, the owner notice that Part 577 prescribes today is the first-class letter, whether the fix is a part or a download. The letter goes to the owner on state registration records, so if those are out of date it may not reach you. That is one reason to check the VIN yourself.
NHTSA also offers recall alerts through its SaferCar app and by email for a vehicle you enter.
How to tell whether the update has been applied
- Search the VIN with NHTSA. NHTSA's recall lookup shows whether a specific vehicle has an unrepaired recall. It does not list recalls already repaired, so an OTA recall that was installed and recorded drops off the result. See recall history by VIN for what that search covers.
- Check the manufacturer's lookup. Under 49 CFR 573.15, larger manufacturers must run a free VIN lookup that shows each safety recall not yet completed on the vehicle, updated at least once every seven calendar days, so a just-installed update may not show as complete straight away.
- Look at the software version. A recall document may name the software version that contains the fix, as the Part 573 report for 25V-002 does. Compare it with the version the car displays.
- Keep the confirmation. Save any message or record the manufacturer sends when the update installs. If a dealer does the work, keep the repair order.
For a very new recall, NHTSA says not every VIN may have been added yet.
If the update fails or the car is offline
An OTA remedy depends on the car being connected and able to finish the install. In recall 24V-246, the update reached only vehicles enabled for the manufacturer's connected service, and the owner letter gave a dealer visit as the route when the OTA update was not wanted or failed. Read your own letter for the fallback it names.
The manufacturer's duty does not end because a download did not arrive. Under 49 U.S.C. 30120(c), failing to repair a vehicle adequately within 60 days of its being presented for remedy is prima facie evidence of failing to repair within a reasonable time, and the manufacturer must then replace the vehicle without charge or refund its price less depreciation. Under 49 CFR 577.5, the recall letter must tell you that you can complain to NHTSA if the remedy is not provided free of charge or within a reasonable time. Our guide to getting a recall repaired walks through booking the work and what to do when it stalls.
An ordinary software release that adds features or fixes a problem that is not a safety defect is not a recall, and carries none of these duties. Our guide to recalls vs service bulletins explains that line.
What RunThatVIN can and can't show
Our recall lookup lists NHTSA recall campaigns by year, make and model, with the campaign number, the consequence and the remedy text from NHTSA's records, so you can see when a remedy is an over-the-air update. It does not check whether any of them has been completed on your car. For that, run the VIN through NHTSA's recall search or ask the manufacturer. You can decode a VIN here first to confirm the year, make and model.
Quick answers
Is an over-the-air software update a real recall?
Yes, when it fixes a safety defect or a failure to meet a federal safety standard. The manufacturer still files a Part 573 report with NHTSA, mails owner notification letters, provides the remedy free of charge and reports how many vehicles have been fixed.
How do I know if an over-the-air recall update was installed on my car?
Run your VIN through NHTSA's recall search or the manufacturer's VIN lookup, which list recalls not yet completed on that vehicle. You can also compare the software version shown in the car with the version named in the recall documents.
What if the over-the-air update fails or my car can't receive it?
The manufacturer still owes the free remedy. Check your owner letter for what to do; in recall 24V-246, for example, a dealer installs the update at no charge if the OTA update fails. If the remedy is not provided free of charge or within a reasonable time, you can complain to NHTSA.
Does RunThatVIN show whether my car's OTA recall is done?
No. RunThatVIN lists recall campaigns by year, make and model. It does not check whether a recall has been completed on a specific vehicle. Use NHTSA's VIN search or ask the manufacturer.
Sources
- 49 U.S.C. 30118, Notification of defects and noncompliance
- 49 U.S.C. 30119, Notification procedures
- 49 U.S.C. 30120, Remedies for defects and noncompliance
- 49 CFR Part 573, Defect and noncompliance responsibility and reports (eCFR), including 573.6 and 573.15
- 49 CFR 577.5, Notification pursuant to a manufacturer's decision (eCFR)
- 49 CFR 577.7, Time and manner of notification (eCFR)
- NHTSA, Recalls
- NHTSA, Report on Vehicle Safety Recall Completion Rates (January 2025)
- NHTSA, 2025 Annual Report: Safety Recalls (March 2026)
- NHTSA, Feasibility of In-Vehicle Recall Notifications (May 2020)
- NHTSA recall record 24V-246 and owner notification letter
- NHTSA recall record 25V-002 and Part 573 Safety Recall Report