Unsurprisingly, Tesla disagrees with this summation. And the company released a two-sentence rebuttal on its website citing a new survey:
In response to Germany's Kraftfahrt-Bundesamt (KBA)'s suggestion that using the name "Autopilot" is misleading, we worked with a third-party to survey Tesla owners in Germany to better understand how they perceive Autopilot.
98% of customers surveyed said they understand that when using Autopilot, the driver is expected to maintain control of the vehicle at all times.
That's the complete statement. The full results of the survey can be found here. Other questions regarding functionality all showed that at least 93% of respondents understood the features and requirements of Autopilot.
Tesla's curt response may have something to do with the fact that Germany isn't the only organization that has come out against the "Autopilot" name. California has legislation in the works concerning the use of autonomous terminology in advertising that may require Tesla to change the name. Consumer Reports has also publicly advised Tesla to change the name. It, like the Germany government, cited concerns that people would falsely believe Autopilot-equipped cars could operate fully autonomously.