Edited on Jun 24, 2026.
In September 2015, the United States Environmental Protection Agency issued a Notice of Violation of the Clean Air Act to Volkswagen Group. The company had installed defeat-device software in approximately 11 million diesel vehicles worldwide to cheat emissions testing. The scandal — already being called Dieselgate — has become the largest corporate crisis in the modern automotive industry. Three months on, the early reputation rebuild is taking shape.
This is the working read on what Volkswagen is actually doing, what the broader crisis communications dynamics look like, and what other consumer brands should learn from the case so far.
What Volkswagen has actually done so far
Three operating tracks are running in parallel.
Executive accountability. CEO Martin Winterkorn resigned within a week of the EPA notice. Matthias Müller, previously the head of Porsche, was appointed CEO. Multiple senior engineering and compliance executives have been suspended pending internal investigation. Michael Horn, the CEO of Volkswagen Group of America, testified before Congress in October and apologized publicly. The internal accountability work has been faster and more visible than the typical corporate crisis response, but the depth of the eventual prosecutions and personnel consequences will not be known for years.
The vehicle remediation question. Volkswagen has not yet announced a comprehensive remediation plan for the approximately 500,000 affected U.S. vehicles. The technical fix — whether it involves software-only changes, hardware modifications, or vehicle buybacks — is being negotiated with the EPA, the California Air Resources Board, and the U.S. Department of Justice. The eventual structure will likely cost Volkswagen tens of billions of dollars across the U.S. and European markets combined.
The structural reform commitment. Volkswagen has announced a comprehensive review of its compliance and engineering practices. The company has hired Jones Day to conduct an internal investigation. The Group's supervisory board has committed to structural reforms once the investigation is complete. Whether the structural reform produces real cultural change or whether it produces communications-only adjustments is one of the most consequential questions for the broader VW recovery.
The crisis communications challenge
Volkswagen faces one of the more difficult crisis communications situations any major consumer brand has had to manage in recent memory. The challenge has several structural components.
The scandal is not an accident. Most major corporate crises involve negligence, oversight failures, or operational mistakes. Dieselgate involves deliberate engineering of software intended to defraud regulators and consumers. The intent makes the standard crisis response playbook — express regret, commit to remediation, invest in prevention — substantially harder. The audience is more skeptical of the apology when the underlying conduct was systematic deception.
The scale is unprecedented. Eleven million vehicles worldwide. Approximately 500,000 in the United States. The financial liability across settlements, vehicle remediation, and regulatory penalties will likely cross $30 billion before the dust settles. The scale exceeds prior automotive crisis cases including Toyota's 2009-2010 recall and the GM ignition switch recall that emerged in 2014.
The regulatory environment is hostile. The EPA, the Department of Justice, and the California Air Resources Board are operating coordinated investigations. The Federal Trade Commission has filed a separate enforcement action. European regulators are pursuing parallel investigations. The multi-jurisdiction regulatory exposure will produce sustained settlement negotiations across years.
The brand is structurally exposed. Volkswagen's marketing has emphasized clean diesel technology as the differentiating brand attribute in the U.S. market. The advertising history — including the "Clean Diesel" campaigns that ran for years — is now part of the evidentiary record in the consumer fraud litigation. The brand cannot easily distance itself from the marketing claims that turned out to be false.
The Toyota recall comparison
The cleanest comparable crisis is Toyota's 2009-2010 unintended-acceleration recall. Toyota lost approximately $30 billion in market capitalization in the first 90 days of the crisis. Akio Toyoda's congressional testimony in February 2010 became one of the most-studied corporate apologies in modern business. The eventual financial cost to Toyota included a $1.2 billion settlement with the U.S. Department of Justice in 2014.
The Volkswagen case shares some structural features with the Toyota case but differs in important ways. Toyota's underlying defects were the result of engineering and supply chain failures. Volkswagen's defeat devices were the result of deliberate fraud. The two crises will resolve differently because the underlying conduct is different.
The Toyota recovery took roughly 18 months from peak crisis to functional brand stabilization. The Volkswagen recovery will likely take longer.
What other consumer brands should learn
Three early lessons from the case.
Compliance is operational infrastructure, not a communications surface. The Volkswagen case demonstrates that compliance failures eventually surface regardless of communications strategy. The brands that invest in real compliance infrastructure produce fewer crisis events. The brands that treat compliance as a public-relations function produce more.
Marketing claims become evidence in the eventual litigation. Volkswagen's clean diesel advertising is now part of the consumer fraud cases against the company. Brands making technical or environmental marketing claims should be auditing those claims continuously against the underlying product reality. The cost of being caught making false claims has grown substantially.
Executive accountability matters in the early response. Winterkorn's resignation within a week of the EPA notice is the right communications move. The brands that try to protect executive positions during crisis events typically end up doing more damage than the brands that accept the executive consequences early.
The road ahead
Volkswagen's recovery will unfold across the next several years. The vehicle remediation, the regulatory settlements, and the broader brand rebuild will all take time. Whether the company can recover its U.S. market position, whether the European business absorbs the broader financial cost, and whether the structural reforms produce real cultural change are all open questions.
The brand and PR teams across the broader corporate communications category will be studying the case continuously. Dieselgate is the largest corporate crisis communications case of recent years. The lessons will continue to develop.
Adjacent Practice Coverage
The Volkswagen Dieselgate case sits inside EPR's manufacturing and crisis communications practice graphs:
