New Michigan Law Puts Brakes On Access To Dealer Data
Michigan has sharply limited access to dealer data systems with the adoption of the Motor Vehicle Dealer Data Collection Act (the “Act”), enacted through S.B. 198 on October 9, 2026 with immediate effect. In so doing, Michigan joins other states—including Arizona, Delaware, Florida, Georgia, Montana, North Carolina, Oklahoma, Oregon, Utah, Washington, and West Virginia—in regulating access to dealer data and dealer data systems, although the approach each state takes to the issue varies in many ways. The Act, codified at Mich. Comp. Laws §§ 445.2601-445.2621, prohibits manufacturers and third parties from requiring direct or indirect access to a dealer’s data system; requires dealer consent for specified uses of protected dealer data; provides dealers with statutory indemnification rights; and imposes new obligations on dealer data vendors and authorized integrators. Manufacturers and vendors cannot compel access to those systems, and a manufacturer cannot tie program or incentive eligibility to a dealer’s consent to share data. Michigan Limits Access and Defines “Protected Dealer Data” In general, the Act prevents a manufacturer or third party from requiring a dealer to grant direct or indirect access to its “dealer data system.” Mich. Comp. Laws § 445.2605(1). The Act defines the term “dealer data system” to
