Devices that allow tracking when no accident occurred, violate the current regulation. This is stressed multiple times. "not connected to the mobile phone networks until a serious accident happens" -- https://ec.europa.eu/newsroom/dae/redirection/document/5963
"it is not permanently connected to mobile networks" -- https://ec.europa.eu/commission/presscorner/detail/fr/MEMO_1...
"not connected to the mobile phone networks until a serious accident happens" -- https://ec.europa.eu/newsroom/dae/redirection/document/5963
There is even a technical test to check if the device is compliant with the privacy regulations: "Procedure for verifying the lack of traceability of an eCall in-vehicle system", where the "Failure to establish the connection can be attributed to the 112-based eCall in-vehicle system not being registered on the network" -- https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32...
Registering the SIM on the network before an accident occurred could be considered a violation indeed.