Every OEM is its own jurisdiction. A US group acquiring a Canadian Toyota rooftop deals with Toyota Canada Inc., not TMS USA — and the approval criteria, panel composition, and timeline are not the same. The brand-by-brand friction map below is the version we hand to every cross-border buyer at the start of the process.
We group OEMs by approval pattern, not by sales volume or prestige. The four patterns below cover roughly 90% of cross-border dealership transactions we run.
Separate Canada and US approval panels. Each must approve independently. Toyota Canada Inc. and TMS USA do not consult each other.
Single approval process spanning both markets. Faster but less flexible — one objection on either side blocks the entire transaction.
Domestic OEMs with mature dealer-development functions on both sides of the border. Predictable processes, public criteria, well-documented timelines.
Korean OEMs (Hyundai, Kia, Genesis) and EV-only brands (Rivian, Polestar, Lucid) have less mature cross-border consent frameworks — outcome more case-by-case.
Toyota Canada Inc. (TCI) and Toyota Motor Sales USA (TMS) operate as separate franchisors with separate dealer-development panels. A US-based group acquiring a Canadian Toyota dealership submits to TCI's Dealer Development Committee in Scarborough, Ontario. A Canadian group acquiring a US Toyota dealership submits to TMS's regional dealer-development function in Plano, Texas (or San Francisco for west-coast deals).
Neither panel consults the other. We have seen identical buyer entities approved on one side of the border and rejected on the other in the same calendar quarter — same buyer, same financial position, same management team, different outcomes.
Toyota panels weight:
Honda Canada and American Honda Motor Co. operate similarly to Toyota — bilateral approval panels, no cross-consultation. Honda's criteria are more publicly documented than Toyota's, including specific capital adequacy ratios and operational benchmarks.
The Honda Canada Dealer Council process is faster than TCI's, typically 60–90 days end-to-end. American Honda's process is slower, 90–150 days.
Stellantis (Chrysler, Dodge, Jeep, Ram, Fiat) runs a unified North American Dealer Development function out of Auburn Hills, Michigan. Cross-border buyers submit a single application that covers both Canadian and US operations.
The unified model is faster (typically 60–90 days for the whole approval) but less flexible. A single area of buyer-side concern — a financial-covenant issue, a CSI problem at an existing rooftop, a personnel question — blocks the entire cross-border transaction. With bilateral panels, the buyer can sometimes proceed on one side while resolving issues on the other.
Nissan moved from bilateral panels to a unified North America approval process in 2022 (following Renault-Nissan alliance restructuring). The transition is still settling. Cross-border buyers should expect more variability in Nissan timelines than for Stellantis through at least 2027.
Both GM and Ford have mature dealer-development functions with bilateral structures (separate Canada and US panels) but well-documented criteria and predictable timelines. Both publish dealer-network plans annually. Both have area-of-primary-responsibility (APR) frameworks that constrain where a buyer can acquire.
For cross-border buyers, the predictability is a feature. GM and Ford rarely surprise on approval timing.
Hyundai, Kia, and Genesis are still building out their cross-border dealer-development frameworks. We have seen Korean OEM approvals run 90 to 240 days with little obvious pattern. Buyer characteristics that helped on one Korean OEM transaction were not material on the next.
For Korean OEM cross-border transactions, we recommend building 90 additional days of regulatory buffer into the deal timeline beyond the typical estimate.
Rivian, Lucid, Polestar, and other EV-only brands operate hybrid factory-direct / franchised models. Cross-border ownership transitions don't fit traditional dealer-development frameworks because the frameworks themselves are still being built.
For EV-only brand transactions, expect direct negotiation with the OEM's corporate development team — not a panel process. Outcomes are more bespoke and less predictable.
Coussa Group runs the full lifecycle — valuation, NDA-bound buyer process, regulatory review, OEM consent on both sides — as a single coordinated workstream.