Tesla presented self-published and inflated safety statistics for its “Full Self-Driving” system directly to government regulators in Sweden and the Netherlands as it lobbied for European approval, according to correspondence obtained by Reuters through public records requests. The data includes a claim that FSD could have “saved 32,000 lives” — a figure that independent researchers say is based on the assumption that every vehicle in the U.S., including freight trucks and motorcycles, would be replaced by an FSD-enabled Tesla. This development marks a significant escalation in the controversy surrounding Tesla’s safety claims, moving from social media posts and marketing materials into formal regulatory proceedings.
How Tesla’s Inflated Safety Data Reached European Regulators
As reported last month, a Reuters investigation found that Tesla’s “Full Self-Driving” safety statistics are deeply misleading, relying on invalid data comparisons that exaggerate the system’s safety record. Ten of 11 independent traffic-safety researchers who reviewed Tesla’s methodology called it misleading marketing rather than a serious safety study. Now, documents show Tesla used those same inflated statistics when directly lobbying European regulators.
In a November 2024 letter to RDW, the Dutch road authority, Tesla provided a link to its safety report and claimed that “increased usage” of FSD “leads to safer roads.” After more than a year of testing and discussions, RDW approved FSD for use in the Netherlands in April and is now seeking EU-wide approval on behalf of Tesla. RDW told Reuters it “does not rely on marketing claims or external statistics” and performs its own “tests, analyses and verifications” on public roads and test tracks. However, the agency did not say whether it actually assessed the validity of Tesla’s U.S. safety statistics.
The 32,000 Lives Claim: A Flawed Calculation
Soon after the Dutch approval on April 10, Tesla policy manager Ivan Komusanac emailed Swedish regulators asking for similar FSD approval. He attached a slide presentation displaying the exaggerated claim that Teslas using FSD can travel more than seven times farther between crashes than the average U.S. human driver. The presentation also claimed FSD could have potentially saved 32,000 lives and prevented 1.9 million injuries.
The problem with these figures is well-documented. Tesla compares a rate of crashes in FSD-equipped Teslas that triggered airbag deployments to a U.S. crash rate for all vehicles that includes far less severe accidents — an apples-to-oranges comparison that inflates the safety margin by a factor of three. Tesla also compares its cars to the average U.S. vehicle, which is about 12 years old. That distorts results because newer vehicles across all brands have better safety features that reduce crash rates. A new Toyota Camry is also safer than the average U.S. vehicle — that does not prove Toyota has cracked autonomous driving.
The “32,000 lives saved” claim takes this already-inflated methodology and applies it to an absurd scenario: replacing every vehicle in the U.S. — trucks, motorcycles, everything — with an FSD-enabled Tesla. Independent researchers describe this as a fundamentally unserious calculation that has no basis in realistic traffic safety analysis.
What Is the Core Methodological Flaw in Tesla’s FSD Safety Data?
Tesla’s central methodological flaw is comparing airbag-deployment crashes in its FSD-equipped vehicles against all reported crashes in the general U.S. vehicle population. Airbag deployments only occur in moderate to severe collisions, while the general crash rate includes everything from minor fender benders to fatal accidents. This mismatch inflates Tesla’s apparent safety advantage by roughly a factor of three, as independent researchers have consistently pointed out. The comparison also ignores the fact that newer vehicles — regardless of brand — have better safety technology than the 12-year-old average vehicle on U.S. roads.
European Regulators Respond With Caution and Skepticism
The responses from European regulators reveal a mixed picture. Anders Eriksson, an investigator at the Swedish Transport Agency, said regulators “look beyond headline figures” and that any assessment would not be based “solely on aggregated safety claims.” However, the regulator did not answer Reuters’ questions about what other evidence Tesla actually provided.
Norway’s response was more direct. Stein-Helge Mundal of the Norwegian Public Roads Administration responded to several Tesla enthusiasts who had written urging FSD approval, saying Tesla’s figures “are self-produced,” making it “difficult to find correlation with the authorities’ accident statistics.” Meanwhile, a Greek regulator cited data “from the other side of the Atlantic” showing FSD “leads to a very significant drop in accidents” — though the transport ministry declined to say whether that data came from Tesla’s own report.
The European Transport Safety Council expressed concern. Dudley Curtis, a spokesperson for the watchdog group, said that if Tesla wants to make safety claims, the company should “give the data to a university, have it independently verified by a qualified researcher, and then let’s talk.” This call for independent peer review underscores the gap between Tesla’s self-published assertions and the standards expected by traffic safety professionals.
What Is at Stake for Tesla in the European Market
Tesla has said FSD approval in Europe is key to regaining market share in a region where sales plummeted last year amid backlash over Elon Musk’s political activities, including his embrace of far-right European political parties. While Tesla has seen some recovery in recent months, BYD has outsold Tesla in Europe for multiple consecutive months, with Chinese EV makers steadily making inroads.
For EU-wide approval, representatives of 55 percent of member states making up 65 percent of the bloc’s population must vote “yes.” Individual countries can approve FSD nationally in the meantime — the Netherlands, Lithuania, Belgium, and Denmark have already done so. Each national approval represents a regulatory decision that, based on the documents obtained by Reuters, was preceded by Tesla’s submission of inflated safety data.
The Implications of Tesla’s Regulatory Strategy
This is a significant development. It is one thing for Elon Musk to post inflated safety statistics on social media — that has become a regular occurrence. It is quite another for Tesla to formally present those same misleading numbers to government regulators as part of an official approval process. The company has been using self-published safety data that is deeply problematic. The airbag-deployment-versus-all-crashes comparison is a fundamental methodological flaw that anyone with basic statistical knowledge should catch. The fact that Tesla continues to use this data in official regulatory correspondence, after researchers have publicly debunked it, suggests the company either does not understand the problem or does not care.
The European Transport Safety Council’s recommendation is exactly right: if Tesla’s data is legitimate, the company should submit it for independent peer review. The fact that Tesla has not done so speaks volumes. European regulators should be evaluating FSD based on their own rigorous testing, not on Tesla’s self-serving marketing materials. To RDW’s credit, the agency says it performed its own testing — but the fact that Tesla even attempted this approach with multiple regulators is concerning. As FSD approval spreads across Europe country by country, regulators need to hold a much higher evidentiary bar than whatever slide deck Tesla’s lobbyists email over.
The broader lesson here extends beyond Tesla. As autonomous driving technology becomes a subject of regulatory action across the globe, the quality and integrity of safety data presented to regulators will be critical. Self-produced statistics that cannot withstand independent scrutiny undermine not only the credibility of the company presenting them but also public trust in the regulatory process itself. Regulators in Europe and elsewhere would be wise to treat any safety claims that have not been independently verified with the skepticism they deserve.
