The Connected Vehicle Rule (CVR) has set the automotive and IoT supply chain on notice. Products containing software or hardware tied to foreign adversaries must be identified, evaluated, and addressed or removed from the U.S. market.
As we’ve explored in the previous blogs, this isn’t a theoretical policy. The CVR introduces a real and urgent operational requirement for every OEM, supplier, and technology provider working on connected vehicle systems.
So the question now becomes: What should your organization actually do next?
In this final post in our series, we shift from analysis to action, highlighting the concrete, achievable steps companies should begin taking now to prepare for CVR compliance before enforcement begins.
Start by taking stock of your connected vehicle platforms, both current and planned. Focus on systems that include:
If the system communicates outside the vehicle or receives updates remotely, it may fall under CVR scrutiny.
Map your product lines and determine where these technologies are used and, critically, where they’re sourced, developed, and maintained.
This step is foundational. Without visibility into what’s in scope, every other compliance effort will be blind.
Once your platforms are mapped, shift your focus to the components inside them. The most efficient way to evaluate risk is through a software bill of materials (SBOM) and a hardware bill of materials (HBOM).
But this can’t be a one-time, manual exercise. You’ll need:
If you’re relying solely on supplier-provided SBOMs, you’ll also need to verify that those documents are accurate and complete. In our experience, too many SBOMs omit critical firmware or embedded third-party packages, leaving hidden exposure.
Automated tooling, especially those that can analyze firmware binaries, can accelerate this step dramatically.
Once BOMs are in hand, begin the deeper work of evaluating risk based on control and influence.
This is where CVR compliance gets tricky. It’s not just about where code was written or who manufactured the hardware. It’s about who owns, controls, or can influence those vendors and whether they are linked, directly or indirectly, to foreign adversaries like China or Russia.
Ask questions like:
This kind of analysis can’t be fully automated. It often requires procurement, legal, security, and product teams to collaborate on supplier research and decision-making. But it’s central to making defensible compliance calls under the CVR.
If you uncover gaps in your visibility, such as incomplete SBOMs or unclear supplier lineage, begin outreach now. Supplier transparency can take time, especially when legal departments or overseas offices are involved.
Send formal requests for:
And as you conduct this work, track and document every step. Create a compliance log that captures:
This documentation will be the first line of defense if the Department of Commerce or a customer ever questions your due diligence.
Not every component will fall under CVR restrictions. For those that don’t, begin preparing your Declarations of Conformity (DoCs) now. Each year, manufacturers and importers must certify that they’ve performed due diligence to confirm that covered hardware and software are free from ownership, control, or influence by foreign adversaries.
Your DoCs should be backed by evidence — SBOMs, HBOMs, supplier attestations, and ownership analyses — and retained for ten years.
This step isn’t just a formality. It’s how you prove that your diligence and documentation meet the Rule’s expectations, even for components that comply. Preparing DoCs early will also streamline future filings and help you establish a repeatable, defensible compliance process.
If you identify technologies that fall under CVR restrictions, either due to foreign ownership, origin, or functionality, you’ll need to develop a mitigation plan.
Options may include:
Whatever the path, don’t delay in implementation. Lead times for validated suppliers, regulatory review, and engineering changes can extend well into 2026. Delaying now could mean missing compliance windows later.
Compliance with the CVR isn’t a one-time project. It’s an ongoing program that must be repeatable, auditable, and scalable across your portfolio. To make that happen:
Companies that treat CVR as a governance challenge, not just a technical one, will be best positioned to scale their response and demonstrate maturity to regulators.
Finite State partners with OEMs and suppliers to accelerate CVR readiness through:
Whether you’re starting your first BOM inventory or already working on mitigation strategies, our platform and advisory services help you reduce manual lift, uncover hidden exposure, and build a compliance program that scales.
The CVR sets a clear expectation: know what’s in your connected products, and prove that those components don’t introduce adversarial risk. For most organizations, the work to meet that bar is already underway or should be. Deadlines are fast approaching; what matters now is moving forward - quickly and decisively.
The companies that begin building transparency, process, and documentation today will be the ones that cross the compliance finish line with confidence and turn CVR readiness into a long-term advantage.
Start that journey now: talk to our experts or book a demo to see how Finite State can accelerate your path to compliance.