I just received the following from my registrar. SO, I guess they think it is obligatory.
"The AIAG released the new
FMEA Manual June 3, 2019. The new FMEA includes VDA, AIAG and OEM guidelines for severity, occurrence and detection. There is also an additional requirement to communicate risks identified during the Failure Analysis process.
The expectation is that new projects started after July / August 2019 would implement the new FMEA requirements. "OUR" Auditors will verify implementation of these new projects during the next scheduled Audit."