VW’s boss will meet board members later as the firm is sued by consumers and faces a criminal probe over cheating emissions tests.
A law firm is suing Volkswagen in the US over the “defeat devices” used to fool emissions tests on diesel cars.
Lawyer Robert Clifford said the impact was “massive” and that car buyers had not got what they paid for.
He said people were also affected because of “diminution of value” – meaning their car could now be worth less.
Mr Clifford claimed VW owners could have problems keeping their car on the road as officials might refuse to issue number plates and permits.
The class action lawsuit is on behalf of two people who say they would not have bought they cars had they known they were not environmentally friendly.
Volkswagen admits the software – which kicks in during exhaust tests – may be in some 11 million vehicles worldwide.
The “defeat devices” meant true emission levels, as much as 40 times the level legally allowed in the US, were hidden.
It now faces a criminal investigation in the US and further probes in countries including Germany, France and South Korea.
The German company’s boss, Martin Winterkorn, is under increasing pressure ahead of emergency talks.
He will meet members of the firm’s board later after the scandal wiped out a third of the company’s value, £19bn, in just two days of stock market trading.
New York Attorney General Eric Schneiderman has also confirmed an investigation.
“No company should be allowed to evade our environmental laws or promise consumers a fake bill of goods,” said Mr Schneiderman
Volkswagen’s boss has apologised but gave no undertaking to resign.
“I am endlessly sorry that we have disappointed this trust,” said Mr Winterkorn in a video message.
“I apologise in every way to our customers, to authorities and the whole public for the wrongdoing. We are asking, I am asking for your trust on our way forward. We will clear this up.”
But VW’s boss has reportedly lost the confidence of shareholders after stocks fell a further 20% on Tuesday.
The company has set aside €6.5bn (£4.6bn) to cover the scandal and has warned the bill could rise.
At least 482,000 cars will be recalled and VW could face penalties of more than $18bn in the US alone.
There are fears cars in the UK could also be recalled and that investigators might find similar devices were used by other firms – including in petrol cars.
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