Tesla investor Gary Black, managing partner of the Future Fund Active ETF, is calling on Tesla to adopt an Apple-style ecosystem strategy to accelerate adoption of its Full Self-Driving software subscriptions. The pitch arrives at a tense moment for the automaker: federal safety regulators are actively investigating whether FSD executes maneuvers that amount to traffic violations, and Tesla has been given additional time to respond to the probe. If Tesla cannot grow recurring FSD revenue while satisfying regulators, the company’s long-term profitability thesis faces a serious test.
What is verified so far
The regulatory pressure on Tesla’s FSD program is well documented. The National Highway Traffic Safety Administration opened an investigation into whether the software performs driving actions that constitute traffic-safety violations, a probe that covers a range of reported incidents. In early December 2025, NHTSA issued a formal letter to Tesla that both extended the company’s deadline to respond and requested additional technical information about how FSD behaves on public roads. That correspondence, reported by the Associated Press, emphasized that the agency is monitoring a rise in consumer complaints and treating the issue as an ongoing safety matter rather than a closed case.
Separately, federal officials have stated that the investigation’s core aim is to determine whether FSD executes maneuvers that breach basic traffic rules. The scope of the inquiry goes beyond individual crashes to examine whether the software’s decision-making logic systematically produces unsafe outcomes in routine driving situations, such as lane changes, turns, and responses to traffic controls. That distinction matters because it could lead to a broader recall or mandatory software changes rather than isolated fixes tied to specific incidents.
Against this backdrop, Black has argued publicly that Tesla should create a tighter link between FSD and the vehicle ownership experience, much the way Apple bundles services like iCloud, Apple Music, and AppleCare with its hardware. His thesis is straightforward: if FSD becomes inseparable from the Tesla driving experience, subscription retention and new sign-ups should rise. The logic mirrors Apple’s playbook of making it inconvenient for customers to leave the ecosystem once they have invested in multiple services tied to a single platform.
The Apple playbook and its limits for Tesla
Black’s comparison to Apple is appealing on the surface. Apple generates substantial recurring revenue from its services segment, and its hardware-software integration creates strong customer lock-in. For Tesla, the equivalent would mean making FSD so embedded in the daily driving experience that canceling the subscription feels like a meaningful downgrade, not just the removal of an optional add-on.
However, the analogy has real limits that much of the discussion around Black’s proposal has glossed over. Apple’s services ecosystem works because its products already function reliably and safely without subscriptions; the paid layer adds convenience, content, and productivity. FSD, by contrast, is still a driver-assistance system that requires constant human supervision and is under active federal investigation for safety concerns. Trying to bundle a product more aggressively while regulators question whether it follows traffic laws creates a tension Apple never had to manage with its cloud storage or music offerings.
There is also a fundamental pricing and value-perception question. FSD currently costs $99 per month as a subscription or can be purchased outright for a much larger upfront fee. By comparison, Apple’s services are generally priced in the single digits or low teens per month, which lowers the psychological barrier to experimentation and long-term adoption. For Tesla to replicate Apple-style adoption curves, it would likely need to rethink how FSD is positioned financially, potentially by folding part of the cost into vehicle financing, offering multi-year bundles, or creating lower-priced tiers that unlock only subsets of features.
Black has not publicly detailed how Tesla should resolve this pricing gap, leaving open whether his vision involves discounting, restructuring, or simply more aggressive marketing. Tesla, for its part, has not disclosed granular subscription metrics that would show how many owners are paying monthly for FSD, how many bought it outright, and how many are on free trials. Without that information, it is difficult to know whether an Apple-style bundling push would be aimed at expanding a stagnant base, improving churn, or monetizing a largely untapped pool of existing vehicles.
What remains uncertain
Several key questions remain unanswered. Tesla has not released official FSD subscription figures in its recent earnings reports, leaving analysts and investors to estimate adoption rates from indirect signals such as software update patterns, app telemetry, and owner surveys. Those methods can suggest trends but are not a substitute for audited disclosure. As a result, there is no consensus baseline for how many Tesla drivers actively use FSD today or how that number has changed over time.
The regulatory timeline is also unclear. While NHTSA granted Tesla more time to respond to the investigation in the December letter reported by national wire coverage, the agency has not set a public deadline for concluding the probe or signaled what enforcement actions it might pursue. Possible outcomes range from no action, to targeted software modifications, to a large-scale recall if the agency concludes that FSD’s core behavior is defective or noncompliant. Any of those scenarios would directly shape how aggressively Tesla could market FSD as an integral part of the ownership experience.
There is no public statement from Tesla executives responding directly to Black’s specific proposal. Historically, Tesla has experimented with different monetization models for FSD, including one-time purchases, monthly subscriptions, trial periods, and price adjustments. But the company has not indicated whether it is considering an Apple-style bundling strategy that would tie FSD more tightly to other services or to the base purchase of the vehicle. Absent such guidance, observers cannot tell whether Black’s idea is aligned with Tesla’s internal roadmap or diverges from it.
The relationship between complaint growth and subscription behavior is another open question. NHTSA is tracking an increase in consumer complaints about FSD, but public documents do not specify whether those complaints primarily come from long-term subscribers, one-time purchasers, or short-term trial users. If the bulk of dissatisfaction stems from paying subscribers, that would strengthen Black’s argument that Tesla needs a retention-focused strategy that improves perceived value and reliability. If complaints are spread evenly across all user types, the issue may point more directly to core product quality and safety rather than to the business model used to sell it.
How to read the evidence
The strongest evidence in this story comes from two distinct threads that do not yet intersect cleanly. On one side, NHTSA’s investigation and its associated correspondence represent primary government documentation of safety concerns with FSD. The agency’s decision to extend Tesla’s response deadline and its tracking of complaint growth are concrete, verifiable actions that signal sustained regulatory attention. These are not speculative; they are procedural steps with legal consequences that could culminate in binding requirements for how FSD operates.
On the other side, Black’s proposal is an investor opinion, not an internal Tesla strategy document or a confirmed business plan. He is a prominent Tesla shareholder with a clear interest in the company’s long-term valuation, and his views resonate with a segment of the investor community that sees software subscriptions as critical to Tesla’s future margins. But his call for Apple-style bundling is a recommendation from outside the company, not evidence that Tesla has adopted or even seriously evaluated the approach.
The gap between these two evidence types matters. Regulatory filings and agency letters carry legal authority and can force corporate action regardless of investor preferences. Investor commentary, even from sophisticated fund managers, reflects a thesis about what a company should do, not what it will do. Conflating the two risks overstating Tesla’s current strategic direction or understating the constraints that regulators may impose on how FSD is designed, marketed, and sold.
For readers trying to make sense of the situation, the most reliable conclusions are narrow ones. It is established that NHTSA is scrutinizing whether FSD’s behavior on public roads complies with traffic-safety rules, and that the agency has expanded its information requests as complaints have grown. It is also clear that some investors, led by Black, believe Tesla should borrow elements of Apple’s ecosystem strategy to deepen FSD adoption and lock in recurring revenue. What remains unknown is whether Tesla will embrace that vision, how regulators will ultimately judge FSD’s safety record, and whether the product can evolve into a must-have feature rather than a contentious option under investigation. Until those uncertainties resolve, any projection about FSD as the centerpiece of an Apple-style ecosystem should be treated as a scenario, not a foregone outcome.
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*This article was researched with the help of AI, with human editors creating the final content.
