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From September 12, 2025, Regulation (EU) 2023/2854 (the 'Data Act') enables users of connected products and related services (i.e. services that influence the way a connected product behaves), to request access to the data they generate by using the connected products and/or related services.
User is defined as a natural or legal person that owns a connected product or to whom temporary rights to use that connected product have been contractually transferred (e.g. through a rent or lease contract), or that receives a related service.
Users can request to share this data with another company or individual, identified as a third-party data recipient.
The Data Act applies within the EU, meaning that the user shall be established in the EU, the connected product(s) shall have been placed on the market in the EU and any third-party data recipient shall also be EU-based.
The data in scope for sharing under the Data Act is data retrieved by Volvo that is raw (ie unprocessed, automatically generated data points) or pre-processed (i.e. modified to be understandable and usable for further analysis). These data shall be provided together with the relevant metadata necessary to interpret and use those data.
To find out how to access the eligible data from your Volvo connected products, check out the section “Data Access request” below.
For each new connected product financed by VFS starting 12 September 2025, the mandatory pre-contractual information can be shared to you by your VFS contact before signing any financing agreement.
It is also available here in English:
Data notice (“Pre-contractual information”) regarding all assets financed by Volvo Financial Services
1. Introduction
In accordance with the transparency requirements under Article 3.2 of the EU Data Act, this document describes how the Connected Product as defined below collects data, how you as a user can access it, and how it is used by Volvo (meaning the Volvo group entity which finances the Connected Product, also referred to as “VFS”). Note that depending on the specific customizations, add-ons selected, technical progress, and additional services acquired, the types, frequencies and amounts of data gathered and processed may vary. This Pre-contractual information is located at https://www.volvofinancialservices.com/en/data-act.
Where information changes during the lifetime of the Connected Product, including any changes to the purpose for which the data are to be used from the originally specified purpose, this information will updated at the above mentioned web address.
2. Connected Product
“Connected Product”: means any asset manufactured by a Volvo Group OEM (original equipment manufacturer), financed by Volvo Financial Services and equipped with a communication system connected to Volvo Group IT systems. The connected product is capable of generating data continuously and in real-time and data accessibility is described below. The connected product is capable of storing data on-device or on a remote server and data accessibility is described below.
3. Signature or incorporation of the Data Management Agreement (or “DMA”):
If VFS and a buyer, lessee, or renter of the Connected Product have not entered into a Data Management Agreement with the Volvo Group OEM (eg. Volvo Trucks, Renault Trucks, Volvo Construction Equipment, Volvo Bus, Volvo Penta, Volvo Energy) or signed an information systems clause as part of a financing agreement, the earlier of (i) the use of the Connected Product or (ii) conclusion of a sales, leasing, financial lease, rental or other relevant agreement for the Connected Product shall constitute your acceptance of and agreement to be bound by the terms and conditions of the Data Management Agreement (DMA), which is hereby incorporated by reference in its entirety and can be accessed at the following websites and web addresses :
If the Connected Product is being (re)sold, leased, or rented, each seller, lessor, or rental provider must comply with the ‘transparency obligation’ outlined in article 3 of the EU Data Act. This requires the seller, lessor, or rental provider to provide this pre-contractual information for the future user to exercise their data access rights under the Data Act and to be provided with Volvo Group OEM´s standard Data Management Agreement.
4. Data in scope:
In scope for the mandatory sharing under the Data Act is data that is “raw” or “pre-processed” (raw data is unprocessed, automatically generated data points, while pre-processed data is modified to be understandable and usable for further analysis). The manufacturer of the Connected Product and/or VFS as data holder might also have opted to voluntarily share inferred or derived data (refined data due to being the outcome of processing beyond pre-processing). Such voluntary sharing does not alter the manufacturer’s or data holder’s classification of the data as inferred or derived, and the sharing status is at the discretion of the manufacturer and data holder, respectively. Data classified as trade secrets or security-related data might be subject to additional non-disclosure and safeguard measures required to be fulfilled.
5. Indirectly accessible data (readily available data under EU Data Act articles 4.1 and 5.1)
The Connected Product may be capable of generating the following product data which might be indirectly accessible as readily available data. Not all data elements are generated and collected for all individual products.
Connected Product data generated in connection to digital services made available by the applicable Volvo Group OEM will be available through the relevant service API, if applicable (in this case please contact the relevant Volvo Group OEM at the following web addresses:
In the other cases (where customers have no subscription for digital services with the Volvo Group OEM), requests for VFS data access can be initiated by contacting VFS according to the process described under the following URL https://www.volvofinancialservices.com/en/data-act.
Product data can become readily available data in the following situation:
· Data Collection by VFS for VFS Purposes (see table below). This collection is specifically designed for VFS's purposes[2]. The scope of the Data Collection for VFS Purposes is determined by VFS and the scope of data collection (which Connected Product and what data), volume, frequency and collection will vary over time and differ between specific Connected Products.
Data Collection by VFS for VFS Purposes - Note that the data below are examples of data collected by VFS and might not be collected from your specific product. What data is available for a specific vehicle can be provided in conjunction with a data access request.
Format and estimated volume:
Access & retention Data is made accessible over API in 2 weeks rolling window after a first data sharing request has been completed for a specific vehicle. As unpacking of collected data is done every 24 hours, the API will contain updated data with the same interval. Vehicle/Product/Driver generated connected to a certain Vehicle/Product may be processed for the entire expected life of the Vehicle/Product type, which could be up to 25 years (e.g. for research and development projects or to ensure that the Volvo Group OEM can manage product liability claims) |
| Type of data, valid for the following Volvo Group OEMs: Volvo Trucks, Renault Trucks, Volvo Bus, Volvo Construction Equipment | Purposes |
For Retail portfolio:
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For Retail portfolio:
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For Wholesale portfolio:
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For information about the types of data collected by the applicable Volvo Group OEM for its own purposes and related frequency, volume and format, please visit the Volvo Group OEM websites:
[1] Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonised rules on fair access to and use of data (“Data Act”)
[2] VFS Purposes: (i) Verify contract compliance or be able to deliver services contracted for, (ii) Confirming that required maintenance and servicing is being done throughout the lifetime of a lease, (iii) perform research and development to verify, validate, enhance and maintain products, solutions and services and to develop new products, solutions and services, e.g. through innovation and data analytics, (iv) verify current market values on return or repossession of a unit, (v) credit underwriting, (vi) perform recoveries on default/ repossession, (vii) verify mileage for usage based contracts, (viii) risk prevention, (ix) fraud prevention, (x) support VFS customers in their vehicle usage and fleet optimization, (xi) enable VFS to manage its own fleet of vehicles, (xii) develop and provide insurance related products and services, including but not limited to connected insurance, (xiii) compliance with ESG regulations and guidelines from authorities and with VFS self-defined goals, (xiv) tax optimization purposes – using benefits from OECD’s Anti-Base Erosion Model Rules
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For the connected products financed by any VFS legal entity based in the EU before 12 September 2025, please see below the EU Data Act Notice in relation to Pre-Existing Agreements:
1. Enabling the effective access to and use of relevant data generated by our products and services in compliance with applicable legal requirements is an essential part of (VFS applicable legal entity financing your connected product( (hereinafter “VFS”) offering to our customers. To that end, VFS is committed to ensuring that such data can be retrieved and processed in a transparent, lawful, and secure way. This will allow us to enhance the value we provide to our customers, while at the same time confidently leveraging the data to develop, deliver and continually improve our products and services.
2. Under Regulation (EU) 2023/2854 (hereinafter the “EU Data Act”), applicable 12 September 2025 (“Applicability Date”), VFS – acting as the so-called “data holder” – is required to:
(i) before concluding a contract for the purchase, rent or lease of a connected product after the Applicability Date, provide pre-contractual information about the data generated, its processing, user access and sharing rights (accessible here above under this URL https://www.volvofinancialservices.com/en/data-act);
(ii) enter into a contract with its customers – qualifying as “users” – in relation to the collection, use and sharing of any Vehicle Data within the scope of the EU Data Act; and
(iii) enable users to exercise their rights to access, use and make relevant data available (please refer to https://www.volvofinancialservices.com/en/data-act for more information about how to exercise these rights).
Where such data includes personal data, please also refer to the relevant section of your Pre-Existing Agreement (as defined below) and our applicable privacy policy for vehicle data, available here: https://www.volvogroup.com/en/tools/privacy.html in English and many languages.
3. The agreements entered into by and between VFS and customers prior to 12 September 2025 or any agreement entered into at a later date which is based on an earlier version of Volvo’s standard financing agreement for the collection, use and sharing of product data (as set out in section 5), as applicable (hereinafter the “Pre-Existing Agreements”) may (depending on the version of the agreement and its date of signature) stipulate concerning VFS’s collection, use and sharing of such Vehicle Data that VFS “may: (…) use the Vehicle Data for the specific needs of VFS (…); share the Vehicle Data within the Volvo Group and with selected third parties.”
4. From 12 September 2025, VFS hereby declares that it shall interpret the above wording of the Pre-Existing Agreements as meaning, and for agreements with no such clause, shall consider the following wording as being incorporated therein:
a. Customer acknowledges and agrees that VFS (i) accesses the System at any time, including remotely, and use its processing capabilities; (ii) collects Vehicle Data; (iii) stores Vehicle Data in the vehicle's storage capacities and in the IT systems of the Volvo group; (iv) uses Vehicle Data for the specific needs of VFS which are described below
b. Further information about the purposes regarding the connected product data for which VFS processes Vehicle Data, can be found in the applicable Privacy Notices https://www.volvogroup.com/en/tools/privacy/operators-drivers.html.
c. VFS’s own internal and other reasonable business purposes shall be understood to comprise the following purposes: (i) verify contract compliance or be able to deliver services contracted for, (ii) Confirming that required maintenance and servicing is being done throughout the lifetime of a lease, (iii) perform research and development to verify, validate, enhance and maintain products, solutions and services and to develop new products, solutions and services, e.g. through innovation and data analytics, (iv) verify current market values on return or repossession of a unit, (v) credit underwriting, (vi) perform recoveries on default/ repossession, (vii) verify mileage for usage based contracts, (viii) risk prevention, (ix) fraud prevention, (x) support VFS customers in their vehicle usage and fleet optimization, (xi) enable VFS to manage its own fleet of vehicles, (xii) develop and provide insurance related products and services, including but not limited to connected insurance, (xiii) compliance with ESG regulations and guidelines from authorities and with VFS self-defined goals, (xiv) tax optimization purposes – using benefits from OECD’s Anti-Base Erosion Model Rules, and any additional purposes further described in the applicable Privacy Notices (hereinafter the “VFS Purposes”). The above-mentioned purposes include the development, training, and monitoring of artificial intelligence systems and machine learning models for the VFS Purposes, including, without limitation, large language models, predictive analytics.
d. VFS’s sharing of Vehicle Data with third parties under the Pre-Existing Agreement entails that, to the extent necessary for the purposes of the Pre-Existing Agreement or as otherwise required by applicable law or regulation, VFS may share Vehicle Data (including, personal data) within the Volvo Group and with third parties, including but not limited to software service providers, subcontractors, Volvo dealerships, public authorities and any other recipients described in the applicable Privacy Notice.
e. The data processed for the VFS Purposes shall never be used in a manner that can undermine the commercial position of the customers on the market in which the customer is active, or otherwise prejudice the legitimate interests of the customers. Where external suppliers are engaged, VFS will use reasonable commercial efforts to obtain an equivalent binding commitment from such supplier, which shall however remain responsible for its own compliance with the EU Data Act, if applicable.
5. The interpretations set out in items 4.a-4.e above are in line with the 2025 Data Management Agreement templates available here, which the VFS customers should be bound with, with the relevant Volvo Group OEM (see below section about the Data Management Agreement):
6. Terms capitalised but not defined in this notice shall have the meaning given thereto in the Pre-Existing Agreement.
7. Except as expressly interpreted herein, the terms of your Pre-Existing Agreement remain unchanged.
1/For cases where the user has acsess to digital services from a Volvo Group OEM:
Connected Product data generated in connection to digital services purchased from the applicable Volvo Group OEM will be available through the relevant service API, if applicable (in this case please contact the relevant Volvo Group OEM at the following web addresses:
In the other cases (where customers have a subscription for digital services with the Volvo Group OEM), requests for VFS data access can be initiated by contacting VFS at the following email address: vfs_data_act_request@volvo.com
3/ in all cases:
You must accept the terms of VFS Data Sharing Agreement, Agreement which will be provided to you in due time.
Access to data must be requested by sending a request to vfs_data_act_request@volvo.com
To access data, you must accept the terms of VFS Data Sharing Agreement which will be provided to you in due time.
If VFS and a buyer, lessee, or renter of the Connected Product have not entered into a Data Management Agreement with the Volvo Group OEM (Volvo Trucks, Renault Trucks, Volvo Construction Equipment, Volvo Bus, Volvo Penta, Volvo Energy), or signed an information systems clause as part of a financing agreement, the earlier of (i) the use of the Connected Product or (ii) conclusion of a sales, leasing, financial lease, rental or other relevant agreement for the Connected Product shall constitute your acceptance of and agreement to be bound by the terms and conditions of the Data Management Agreement (DMA), which is hereby incorporated by reference in its entirety and can be accessed at the following websites and web addresses :