ATTENTION:
GENERAL MANAGER

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PARTS MANAGER

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CLAIMS PERSONNEL

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IMPORTANT - All
Service Personnel
Should Read and
Initial in the boxes
provided, right.

SERVICE MANAGER

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© 2021 Subaru of America, Inc. All rights reserved.

SERVICE INFORMATION BULLETIN
APPLICABILITY:

All 2022MY and Later Models Equipped with
STARLINK Telematics

NUMBER: 15-284-21
DATE:

07/12/21

SUBJECT:

STARLINK Telematics Service Availability
in Massachusetts

REVISED:

10/28/24

INTRODUCTION / BACKGROUND:
In November 2020, voters in Massachusetts (MA) passed an amendment to the existing MA motor
vehicle “Right to Repair” law. Among other things, this new amendment (the Data Law) requires
automotive manufacturers that utilize a Telematics system to equip their vehicles with an interoperable, standardized, and open access platform for communicating certain vehicle data to third
parties. These new requirements apply to all model year 2022 and newer vehicles.
As a direct result of the new Data Law, Subaru of America is no longer able to offer STARLINK
Safety & Security services to MA residents starting with MY2022 vehicles. Specifically, any
MY2022 and newer Subaru vehicle having a MA address associated with either the vehicle or
the STARLINK account will not be able to subscribe to STARLINK Safety & Security services.
This includes any of the following associations: Owner, Co-owner, Driver, Co-Driver, Subscriber,
Authorized User, Business, or Fleet Management Company. Subaru retailers will be unable to
enroll these vehicles during the delivery process, and customers will be unable to enroll themselves,
whether they use MySubaru or by calling STARLINK Customer Care.
IMPORTANT NOTE: Model years prior to 2022 are not affected by this change. Additionally,
vehicles with WiFi hotspot capability will still be able to access AT&T 4G data services should
customers wish to pursue a subscription directly with AT&T.
BULLETIN PURPOSE:
This Service Information Bulletin has been prepared to inform retailer employees and Technicians
of the impact of the Massachusetts Data Law. This bulletin also provides insights to reference when
responding to customer inquiries and addressing Telematics-related repairs as part of these new
business requirements.
CAUTION: VEHICLE SERVICING PERFORMED BY UNTRAINED PERSONS COULD
RESULT IN SERIOUS INJURY TO THOSE PERSONS OR TO OTHERS.
Subaru Service Bulletins are intended for use by professional technicians ONLY. They
are written to inform those technicians of conditions that may occur in some vehicles,
or to provide information that could assist in the proper servicing of the vehicle. Properly
trained technicians have the equipment, tools, safety instructions, and know-how to
do the job correctly and safely. If a condition is described, DO NOT assume that this
Service Bulletin applies to your vehicle, or that your vehicle will have that condition.

Subaru of America, Inc. is
ISO 14001 Compliant
ISO 14001 is the international standard for
excellence in Environmental Management
Systems. Please recycle or dispose of
automotive products in a manner that is friendly
to our environment and in accordance with all
local, state and federal laws and regulations.

Continued...
Bulletin Number: 15-284-21R; Revised: 10/28/24

Page 1 of 5

All customer inquiries regarding the Data Law or eligibility to enroll in STARLINK must be referred
to Subaru’s Customer Advocacy Department (CAD) or the STARLINK Call Center. CAD and the
STARLINK Call Center have received training on how to respond to these inquiries.
Retailers should check to confirm the name and address found in Vehicle Inquiry match the
information on the Repair Order (RO). If the address on the RO is not located in MA, the
retailer should either update the customer record or, direct the customer to update the address
in MySubaru. Contact CAD for further assistance.
STARLINK SERVICES AND MYSUBARU:
STARLINK subscriptions and services will remain available on all vehicles prior to MY2022
and on all MY2022 and later vehicles which are not associated with a MA address. Additionally,
MySubaru access will remain available for all model years and all customers, including MY2022
vehicles associated with a MA address to allow customers to access preferred retailer information,
maintenance service scheduling, and reminders.
IMPORTANCE OF DCM COMMUNICATION CHECKS IN MA:
Ensuring optimal telematics and SXM360 is vital for confirming functionality.
Cause of Concern:
Despite the limitations imposed by MA law on telematics enrollment, the DCM (Data
Communications Module) plays a crucial role in enabling various vehicle features, including
SiriusXM’s SXM360 service. Due to the increasing complexity of modern vehicles and the
availability of MA-compliant telematics options, technicians may have become complacent about
performing thorough communication checks on DCMs. This oversight can lead to undiagnosed DCM
issues, customer dissatisfaction, and unnecessary repairs.
Corrective Action Required:
1. Mandatory Communication Checks:
•

NVI/PDI: Ensure that all DCMs undergo comm checks during New Vehicle Inspection
(NVI) or Pre-Delivery Inspection (PDI).

•

After DCM Replacement: Perform comm checks on DCMs immediately after they are
replaced to verify proper functionality.

2. Understand DCM’s Role:
•

Beyond Telematics: Recognize that the DCM is not solely for telematics. It facilitates
a range of vehicle features, including SXM360, which requires a functioning DCM for
operation.

•

MA Law: While MA law limits telematics enrollment, it does not restrict the use of the
DCM for other essential functions.

3. Address Undiagnosed Issues:
•

Thorough Diagnosis: If a customer experiences issues with SXM360 or other features
related to the DCM, conduct a thorough diagnosis to identify the root cause.

•

Avoid Unnecessary Repairs: By performing proper communication checks, technicians
can prevent unnecessary replacements of CCUs or DCMs.
Continued...

Bulletin Number: 15-284-21R; Revised: 10/28/24

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IMPORTANT NOTE TO RETAILERS:
Due to the interdependency between the DCM, infotainment system, and other vehicle systems
via CAN communication, there may be repair situations which will require replacement or
additional diagnosis of Telematics system components even in the absence of an active STARLINK
subscription. In order to be eligible for warranty claim reimbursement, Telematics system repairs
on vehicles restricted by the new Data Law must be accompanied by clear documentation of the
customer’s concern, detailed Technician notes with findings including specific DVOM readings when
applicable and all steps taken to verify and repair the customer’s concern. A lack of documentation
for Telematics system repairs on vehicles restricted by the new Data Law may result in claim review,
audit proceedings, or claim denial.

Continued...
Bulletin Number: 15-284-21R; Revised: 10/28/24

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A copy of SOA’s Official Communication to Customers is supplied below:

Continued...
Bulletin Number: 15-284-21R; Revised: 10/28/24

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IMPORTANT REMINDERS:
•

SOA strongly discourages the printing and/or local storage of service information as previously
released information and electronic publications may be updated at any time.

•

Always check for any open recalls or campaigns anytime a vehicle is in for servicing.

•

Always refer to STIS for the latest service information before performing any repairs.

Bulletin Number: 15-284-21R; Revised: 10/28/24

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