Introduction of a technical compliance system – an interplay of compliance, R&D, and quality

A technical compliance management system can help to reduce the risk of product-related
binding technical obligations. When introducing such a system, there are various points to
consider that can be an essential lever to success. This includes, among other things, a clear
understanding of the interfaces to compliance, legal, quality and R&D and the risk-based
approach to defining the focus of the tCMS. The following article will go into these points
in more detail.

Technical compliance is becoming increasingly important

Technical compliance or product compliance “means the adherence to the obligations binding on the company.” [1] This topic has received increasing attention in recent years, especially in the automotive industry, partly because regulatory requirements and product complexity are constantly increasing. As a result, more companies are introducing a technical compliance management system [2] and recognizing its importance. The question arises as to how this can be implemented sensibly and in accordance with current standards. It helps that many com panies already have compliance management systems. At the same time, the VDA (Verband der Automobilindustrie ) also publishes recommendations specifically for the implementation of product compliance systems. [1] Further more, the publications of the US Department of Justice provide orientation.

Technical compliance is part of an overarching compliance management system

The Schaeffler Group has compliance management systems for business integrity, exportcontrol, taxes, human rights, and technical compliance, among other things. It makes for these systems to be uniform and aligned with industry and assurance standards. At the Schaeffler Group, responsibility for this lies with the Group Chief Compliance Officer. It should also be noted that integrity is a fundamental component of the Schaeffler Group’s business practices. It is an essential element in all compliance systems and is enforced by uniform compliance management.

The Technical Compliance Management System (TCMS) at Schaeffler is established on the basis of the IDW PS 980 [3] auditing standard – analogous to the other compliance systems. It is an essential component of compliance management. This ensures a systematic approach of the overarching compliance management that utilizes the compliance competencies already available in the company. TCMS is also anchored within the Board of Management Department for Research and Development. This enables a good understanding of existing and new products and technologies. The organizational anchoring of a TCMS is company-specific and depends, among other things, on the respective responsibilities and organizational forms. It can be seen that technical compliance is often located in quality or compliance in addition to R&D [2].

When introducing a TCMS, which is a second-line responsibility, the connection to quality assurance should also be carefully considered. There are requirements to establish the product integrity of a product placed on the market [4].

A risk-based approach to a technical compliance system

Risk management is an essential part of any compliance management system. In order to develop an appropriate and effective TCMS, it is advisable to proceed in a risk-based manner, i.e. to systematically derive which topics the respective TCMS must focus on [1]. This is company-specific and depends on the respective products and markets. It should be noted that compliance with the binding obligations applies across the entire product lifecycle. From a process point of view, more than the respective product development process should be considered.

The assessment of technical compliance risks should be carried out regularly and system atically, so the main focus of a TCMS can adapt accordingly over time. This is an essential tool in the continuous development of a TCMS. For companies with a broad portfolio of different products, the TCMS risks of the product groups will vary. Accordingly, risk-based focal points must be identified in the TCMS.

The new version of the auditing standard IDW PS 980 explicitly addresses the fact that it is advisable to introduce a risk control matrix in order to identify and document the corresponding  compliance risks [3]. With the help of the risk-based approach, i.e. identification of the relevant key topics, a risk-control matrix can be created in a structured manner. This is a helpful way to see if the identified risks are matched by sufficient measures and controls to reduce the risk. The effectiveness of the risk reduction must then still be tested in the application. In the next step, the risk-control matrix can be an essential factor in continuously improving and developing the TCMS.


As a result, the TCMS can reduce the corporate risk of TCMS incidents, take into account the due diligence of company management, and provide orientation for employees.

[1] Product Compliance, Volume 1: Product Compliance System;
VDA QMC; 1st edition; November 2023
[2] Compliance Transformation 2025+, PwC study.
[3] IDW Auditing Standard: Principles of Proper Auditing of Compliance Management Systems (IDW PS 980 n.F. 09.2022)
[4] Product integrity; VDA QMC; 1st edition; November 2018

The authors:

Dr. Christian Gabriel is Head of Technical Compliance at Schaeffler AG. He holds a doctorate in physics and has been with the Schaeffler Group for 12 years in various functions.





Dr. Jörg Metzger is Head of Technical Compliance Management System at Schaeffler AG and has been with the Schaeffler Group for 25 years in various functions.





The Schaeffler Group has been driving forward groundbreaking inventions and developments in the field of motion technology for over 75 years. With innovative technologies, products and services for electric mobility, CO2-efficient drives, chassis solutions, Industry 4.0, digitalization, and renewable energies, the company is a reliable partner for making motion more efficient, intelligent and suistanable – over the entire life cycle.