Regulatory Compliance


The transportation industry is highly regulated and our client was faced with a short timeline to comply with a change that impacted a fundamental tenet of their OEM business model: service delivery through their dealers. In contrast to past requirements, regulatory compliance in this case did not involve only product changes to improve emission reduction goal attainment. Rather, it required manufacturers to make available emission-related service information about their vehicles (including service manuals, technical service bulletins, on board diagnostics descriptions, and diagnostic tools) to all service providers in the repair industry at a fair and reasonable price – so-called “right to repair” legislation. At the same time, the requirement to share information with 3rd-parties created a new type of commercial opportunity. This situation was different from previous regulatory responses by our client and it would require close coordination of technical and commercial work streams and stakeholders over a global span.


Like many projects, understanding the current state is the first step. At the time of our engagement there were already many eyes on the issue. Technical development was well on its way but the situation was characterized by multiple participants lacking a focal point for cross-functional activity. In other words, “who’s got the ball?” was a big question. To address this, three key coordination mechanisms were put in place:

  • A Governance Model was established to ensure effective coordination and communication of activities and decisions;
  • A Project Charter brought together the objectives, methodology, and responsibilities for common understanding of all stakeholders; and,
  • A RACI matrix defined the specific roles and responsibilities of the ten disparate stakeholders.

Once these mechanisms were established, the approach turned to activity planning and execution. This effort employed “classic” project management tools for activity planning:

  • A holistic timeline with milestones and critical path identification;
  • A single Activity Plan with activity descriptions, responsibilities, due dates, status, and complicating factors; and,
  • Risk tracking including impact and likelihood analysis.

Execution, for some activities, simply included status monitoring and assistance or escalation of identified obstacles. Oftentimes, the obstacles were not so “simple” since they extended into other departments that required awareness and motivation in line with the project objectives. For other activities, we filled gaps in areas such as benchmarking, opportunity identification, organizational design, regulatory submittals, and 3rd-party web portal design.

The third and final step of our approach was a strong dose of effective communication. The importance of this cannot be underestimated. Who, when, and what information to share were critical determinations. We structured a communication plan around a regular cadence of internal and external information sharing sessions, each with agendas specific to the task and audience.


There were several important outcomes to this work. First and foremost, failure was not an option – regulatory compliance was achieved on schedule. The various work streams were aligned and joined to deliver a solution accepted by state and federal regulators. This delivery included these four elements:

  • 3rd-party access to information: Service Bulletins, Product Manuals, Schematics, and Recalls;
  • 3rd-party access to diagnostic tools: Remote download of OE software, Developer specifications, and Re-publishing license agreement;
  • 3rd-party access to training: Model year-specific courses related to emissions equipment; and,
  • Service delivery descriptions: Process details using common scenarios and FAQs.

The second outcome was the realization of a new commercial opportunity. New revenue sources were enabled with daily, monthly and annual subscription price levels set relative to value received and horizontal market benchmarks. Care was taken to protect the preferred dealer channel and changes were implemented with their awareness and agreement. Future revenue stream opportunities were also identified including partnerships with independent service providers for expanded part sales, higher service contract support levels for existing customers, and new account conquest opportunities with multi-branded fleets.

The third outcome was the establishment of work flows and organizational changes to ensure long-term compliance. Aptus had filled a short term need but the compliance requirement extended beyond the project end. Before this project, compliance was viewed as a cyclical need with ownership scattered across functions. We secured acceptance for a recalibrated organizational design to enable proactive issue identification, coherent strategy development, and response synchronization around future regulatory requirements.

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