Most likely. I bet almost all auto manufacturers are guilty of it in some form or another. Subaru's case doesn't seem like it is at Dieselgate level of seriousness yet but who knows what they will uncover during their investigation.
It's pretty much what many of us said when Dieselgate broke. Not to minimize the sleazery that VW laid on us, at all, but there was widespread feeling that this sort of thing was endemic due to the friction that occurs when profit margins meet government regulations.