Tesla's Dutch FSD page April 2026: what's stated and what's missing

What Tesla's Dutch page says right now

On 11 April 2026, one day after the RDW decision, Tesla published on its Dutch-language FSD page the announcement that Full Self-Driving (Supervised) was 'now legally approved' and available for the Netherlands. The page contained the following claims (translated from Dutch):

Hero banner: 'Full Self-Driving (Supervised), Now legally approved'

Availability:

"Full Self-Driving (Supervised) is currently available in the United States, Canada, China, Mexico, Puerto Rico, Australia, New Zealand, the Netherlands and South Korea and will become available for other regions in future updates."

Product promise:

"Under your active supervision, Full Self-Driving (Supervised) can intelligently and accurately drive your car. [...] Your Tesla will then bring you safely from your location to your destination by making real-time decisions along the way."

The critical claims:

"Wireless software updates ensure that every Tesla benefits from the latest safety improvements."

"7x Safer than a human driver when Full Self-Driving (Supervised) is enabled" (with only a footnote: "Compared to the estimated US average")

What's missing is the whole point

Tesla's Dutch FSD page mentions nowhere:

That Hardware 3 vehicles receive a different, stripped-down version of Full Self-Driving
That Tesla's own CEO publicly acknowledged in January 2025 that HW3 computers must be replaced
That Tesla's own VP of Autopilot confirmed in August 2024 that HW3 runs a 'smaller model'
That Tesla's own patent application acknowledges that the workaround for HW3 can render the system 'inoperable'
That independent reporting documents the HW3 performance gap versus AI4 at approximately 3.75 times worse on critical safety metrics
That the '7x safer' claim doesn't apply to HW3, which, based on fleet data, likely comes out below the original 2019 promise of 'twice as safe'

The footnotes don't save it

The page itself carries four footer notes:

'Availability of all features is subject to legal approval and other factors, which may take longer in some jurisdictions.'
'The features currently available require active supervision by the driver and do not make the car autonomous.'
(About the miles counter)
'Compared to the estimated US average.' (for the 7x claim)

None of these footnotes mention hardware versions, product differentiation, or the position of Hardware 3 vehicles. An average consumer reading this page would reasonably assume that the promise applies universally to every Tesla.

The configurator's new fine print

On the configurator (tesla.com/nl_nl/model3/design), Tesla has added a new disclaimer during the same period that wasn't present in 2019:

"Technical limitations may apply. Consult the user manual and support page for more information."

This addition is telling. Tesla has explicitly extended the original 2019 disclaimer with 'technical limitations', but without specifying which limitations, for which vehicles, and how a buyer would know whether their specific car falls within them. The clause asks the buyer to consult the user manual and support page, with no indication where to start.

That's the opposite of transparency. The vague 'technical limitations' is precisely where Tesla's knowledge of the HW3 problem should've been shared. Instead there's a vague phrase that effectively fails to inform the consumer.

This is a textbook misleading omission

Article 6:193d of the Dutch Civil Code defines a misleading omission as 'a commercial practice in which material information is omitted that the average consumer needs to make an informed transactional decision'.

Tesla's NL FSD page on 11 April 2026 fits this definition literally:

Material information exists: that HW3 vehicles receive a different, inferior version of the product
That information is omitted: no mention, even in the footnotes
The average consumer needs it: to decide whether to buy a Tesla with HW3 (used or new), or to understand what to expect on their current Tesla
A consumer aware of the omission would make a different transactional decision

This is legally powerful because it's an ongoing violation. Unlike the historical 2019 promises (which could potentially be the subject of a limitation period discussion) this omission is happening now. It's happening when this page is read, when this summation letter is sent, and at every moment thereafter until Tesla updates its page.

Every HW3 owner, every used-car buyer, every new customer

The misleading omission on Tesla's NL FSD page affects three groups:

Existing HW3 owners: who believe they're entitled to the approved version, and aren't warned that they'll receive a 'Lite'
Potential second-hand buyers: who, without this information, would purchase a 2019-2023 Tesla on the assumption that FSD is now available
New Tesla buyers: who may read the page without realising that the product they're buying only works fully on vehicles with AI4 or later

That's exactly what article 6:193d of the Dutch Civil Code was designed for: collective protection of consumers in the market, not merely individual protection after the fact.