The Federal Trade Commission has released long-awaited price transparency guidance for automobile dealers, giving the industry clearer direction on how vehicle prices should be advertised under the Federal Trade Commission Act. Published on September 15, 2026, in a Frequently Asked Questions format, the guidance explains how dealers should present vehicle prices so consumers can understand the actual amount they are expected to pay. The update follows warning letters sent by the FTC in March 2026 to 97 auto dealership groups across the country. Christopher Mufarrige, director of the FTC’s Bureau of Consumer Protection, said the agency remains focused on preventing dealers from advertising low prices and then adding mandatory fees during the purchasing process.

The guidance covers far more than a simple headline price. It addresses mandatory fees, document charges, online advertising, social media, telephone and text communications, MSRP displays, conditional discounts, optional add-ons, vehicles in transit, stock photography, leasing advertisements and responsibility across dealers, manufacturers and third-party advertising providers. The FTC also clarified that the FAQs are not a new formal rule-making process like the former CARS Rule, which was vacated by the Fifth Circuit in January 2025. Instead, they explain the FTC staff’s view of how longstanding Section 5 principles concerning deceptive advertising apply to automotive advertising.

1. FTC’s All-In Pricing Standard for Auto Dealers

At the centre of the new guidance is a straightforward requirement: the advertised price of a vehicle must represent the actual price that a consumer can pay when purchasing the vehicle. The FTC states that the only charges that can be excluded from this advertised price are amounts that a federal, state or local government agency directly requires the consumer to pay, including applicable taxes, official registration fees and title transfer fees. This means dealers cannot advertise a vehicle at one figure and then require customers to pay additional mandatory dealer charges before completing the purchase. Any dealer-required charge that does not fall within the narrow government-required exclusions must be incorporated into the headline advertised price. The approach is designed to make the number consumers see in advertisements more closely match the amount they are actually required to pay.

The Core Pricing Requirements:

• Advertised prices must reflect reality
• Mandatory dealer fees must be included
• Government charges have limited exclusions
• Document fees belong in advertised prices
• Consumers should see upfront costs

The all-inclusive approach also applies when a government body authorises a particular charge without directly requiring the consumer to pay it. Likewise, if a government entity requires the dealer to pay a fee and the dealer passes that cost to the customer, the amount must still be included in the advertised price. The FTC provides a clear example involving a vehicle advertised at $40,000. If every purchasing customer must also pay an $85 document fee, the advertised price needs to be $40,085. Where different customers are charged different mandatory document fees, the advertised figure must reflect the highest mandatory document fee that any customer could be required to pay.

2. Auditing Mandatory Fees and Dealer Advertising

The new guidance means dealership leadership needs to examine how prices are presented throughout its entire advertising operation. Dealers should conduct a detailed review of vehicle prices across every platform they use, checking whether mandatory fees have been incorporated correctly into the advertised figures. Document fees deserve particular attention because the FTC’s guidance requires the highest mandatory amount charged to any customer to be reflected in the advertised price. State laws may also require separate document-fee disclosures, but satisfying a state disclosure requirement does not replace the FTC Act’s all-in pricing requirement.

Compliance Checks Dealers Need:

• Audit every advertised vehicle price
• Review mandatory fee structures
• Identify highest document fee
• Check state disclosure requirements
• Update advertising procedures consistently

The scope of the guidance extends across virtually every advertising channel. Traditional newspaper and print advertisements, roadside billboards, dealership websites, social media posts and third-party vehicle listing platforms are all covered by the truth-in-pricing principles. The FTC also treats direct communications from dealership sales staff as advertising when they involve vehicle pricing. That means telephone conversations and text messages can fall within the same requirements. Dealers therefore need their internal sales communications to remain consistent with the prices appearing in their formal advertising.

3. Online Advertising and Price Prominence

Digital advertising receives particular attention because consumers frequently begin their vehicle search online. The FTC states that when a webpage lists an amount a consumer might pay for a vehicle, the actual all-in price must appear as the most prominent price on that page. This requirement applies to broad inventory-search results as well as individual vehicle listing pages. Simply placing the correct price somewhere on a webpage is not enough if another number receives greater visual attention. The FTC considers factors such as placement, visual emphasis, size and proximity to other text when determining whether a price is sufficiently prominent.

Digital Pricing Essentials:

• Display the all-in price prominently
• Apply rules across inventory pages
• Check individual vehicle listings
• Review visual price emphasis
• Align sales communications with advertisements

Dealerships should therefore review their websites and digital advertising systems rather than assuming that correct pricing data alone guarantees compliance. The way information is visually presented can also matter. Dealers should coordinate with their sales teams so telephone and text quotations match the advertised figures. They should also communicate with third-party advertising partners because entities exercising operational control over advertising can have responsibilities under the FTC’s approach. Clear internal procedures and regular monitoring can help maintain consistency across every consumer touchpoint.

4. MSRP, Discounts and Promotional Incentives

The FTC does not prevent dealerships from displaying or referencing a manufacturer’s Suggested Retail Price. Dealers can continue using MSRP in their advertising, but the actual all-in price that any consumer can pay must remain the most prominent figure. An MSRP cannot be presented in a way that overshadows the actual selling price. The central principle is that consumers should be able to identify the real amount required to purchase the vehicle without being distracted by a different, potentially higher reference figure.

Rules for Promotional Pricing:

• All-in price remains most prominent
• MSRP may still be displayed
• Conditional discounts need clear terms
• Eligibility requirements must be conspicuous
• Universal pricing comes before incentives

The same principle applies to conditional discounts and promotional rebates. Dealers can advertise savings available only to particular groups or customers who meet specific requirements. Examples include a $1,000 discount for first responders or a $2,000 incentive available when the customer uses dealer financing. However, the universally available price for a customer who does not qualify for those programmes must remain the primary advertised figure. The eligibility conditions for any special offer must then be disclosed clearly and conspicuously alongside the main price.

5. Negotiations, Add-Ons and Optional Products

The FTC guidance also addresses the distinction between the advertised vehicle price and optional products or services. Dealers may offer protection packages, accessories and other add-ons, but they cannot represent an optional product as though every customer is required to purchase it. The advertised price must accurately represent what a consumer is required to pay regardless of whether that person negotiates with the dealership. Optional products should remain genuinely optional, and dealers must not create the impression that a customer has no choice about purchasing an add-on.

Important Add-On Principles:

• Optional products must remain optional
• Dealers cannot misrepresent add-on costs
• Installed options cannot be falsely described
• Unauthorised charges cannot be added
• Negotiations do not change advertised prices

The guidance also addresses situations where an option has already been installed on a vehicle. Dealers cannot imply that the customer is required to pay for an optional item simply because it has already been fitted. Similarly, dealers cannot state or suggest that an optional product cannot be removed when that representation is inaccurate. Charging customers for optional products they did not explicitly agree to purchase is also inconsistent with the guidance. These provisions are intended to ensure that the advertised vehicle price remains meaningful and that customers are not presented with supposedly mandatory charges after becoming committed to a purchase.

6. Advertising Vehicles That Are Offsite or In Transit

Dealers frequently advertise vehicles that are not physically sitting on their dealership lots. A vehicle might be stored at another facility, held within an affiliated inventory network or travelling from the manufacturer to the dealership. The FTC does not automatically prohibit advertising these vehicles. However, dealers need to clearly disclose when an advertised vehicle is not physically located on the dealership’s lot. Consumers should not be given the impression that a vehicle is immediately available for inspection when it is actually somewhere else.

Rules for Offsite Vehicles:

• Offsite vehicles can still be advertised
• Location disclosures must remain clear
• Transit claims must reflect reality
• Available vehicles cannot be misrepresented
• Bait-and-switch practices remain prohibited

Vehicles advertised as being “in transit” must genuinely be travelling from the factory and must be available for open purchase when they arrive. Dealers cannot use a vehicle that has already been sold or allocated to satisfy another customer’s paid order simply to attract shoppers. Doing so could amount to an illegal bait-and-switch practice. Although the guidance does not specifically prohibit advertising vehicles that are still in production, dealerships need to be particularly careful about describing a vehicle as “in transit” before it has actually left the manufacturing facility.

7. Stock Images, Used Vehicles and Leasing Advertisements

Vehicle photography is another area addressed by the FTC. Dealers can use stock or representative photographs when those images accurately represent the make, model, condition and other material characteristics of the vehicle being advertised. This approach can be practical for new vehicles or vehicles travelling to a dealership because factory-produced units of the same model may be substantially similar. Used and antique vehicles create a different situation because their individual condition, wear and appearance can vary considerably.

Photography and Leasing Guidance:

• Stock images can represent new vehicles
• Images must accurately represent vehicles
• Used cars require greater accuracy
• Antique vehicle condition needs attention
• Lease fees must be included upfront

For used or antique vehicles, consumers can reasonably expect photographs to represent the specific vehicle being offered. A generic photograph that creates a materially inaccurate impression of an individual used vehicle can therefore create advertising concerns. The guidance also covers automotive leasing. When a lease advertisement states the total amount due at signing, any mandatory processing or document fees that must be paid upfront need to be included in that advertised amount. These requirements operate alongside existing obligations under the Consumer Leasing Act through Regulation M and the Truth in Lending Act through Regulation Z.

8. Shared Responsibility Across Automotive Advertising

One of the most important aspects of the FTC guidance is that responsibility can extend across the broader automotive advertising ecosystem. The agency identifies auto dealers, third-party advertising platforms and Original Equipment Manufacturers as entities that can have responsibility when they exercise control over vehicle advertising. A dealership therefore cannot simply blame a software provider, advertising agency or another outside company when a non-compliant advertisement appears under its name. Dealers need systems that allow them to monitor advertising even when outside businesses assist with creating or distributing that advertising.

Who Needs Compliance Oversight:

• Dealers remain responsible for advertisements
• Third-party platforms require monitoring
• OEM advertising programmes need review
• Vendors should provide compliance commitments
• Contracts can include indemnification protections

Original Equipment Manufacturers should also review their promotional standards and cooperative advertising programmes to ensure that those arrangements do not conflict with the FTC’s pricing principles. At the same time, dealerships remain independently responsible for advertisements published under their brands. The guidance therefore encourages stronger relationships and clearer contractual arrangements with third-party providers. Contracts can include explicit compliance obligations and indemnification protections, giving dealerships additional safeguards when outside companies handle parts of their advertising operations.

9. Industry Response and the FTC’s Legal Position

The National Automobile Dealers Association has welcomed the additional clarity provided by the FTC. Following the March 2026 warning letters, NADA worked with dealers and the agency to address questions surrounding automotive advertising compliance. In its September 15 statement, NADA described the FAQs as an important step towards giving dealers clearer information about the FTC’s advertising expectations. The organisation also acknowledged the work carried out with dealers and the FTC following the earlier warning letters.

What The New FAQs Mean:

• Dealers receive clearer compliance guidance
• NADA worked with the FTC
• March warnings preceded the FAQs
• Existing law remains the foundation
• Formal CARS Rule is separate

The FTC has also clarified what the FAQs are not. They do not represent a new formal rule-making process comparable to the former Combating Auto Retail Scams, or CARS, Rule. That rule was vacated by the Fifth Circuit in January 2025. Instead, the FAQs express the expert view of FTC staff regarding how existing principles under Section 5 of the FTC Act apply to automotive advertising. The prohibition against deceptive advertising under Section 5 has existed for decades, meaning the FTC describes the guidance as an explanation of how established legal principles apply to modern vehicle marketing rather than a completely new set of laws.

10. Practical Compliance Tools and Transparent Car Pricing

For dealerships looking to implement the guidance, practical compliance work will involve reviewing advertising systems across every channel. Teams responsible for pricing, sales, marketing, websites, social media and customer communications need to work from consistent information. Specialised legal resources can also help dealerships examine their advertising practices. The supplied material highlights Holland & Knight’s Consumer Protection Defence and Compliance Team as an example of a group that provides advertising audits and assistance with transparent pricing programmes. Technology solutions such as Comply Auto’s Guardian tool can also monitor advertisements across different channels, including text messages and emails.

Building A Transparent Pricing System:

• Audit every advertising channel
• Monitor prices across platforms
• Train sales communication teams
• Review third-party advertising partners
• Maintain clear compliance procedures

The practical goal is to ensure that the price consumers encounter at every stage remains consistent. A price displayed on a website should align with the figure provided through a text message, telephone conversation, third-party listing or dealership advertisement. This also means dealerships should establish clear internal policies instead of relying on individual employees or outside providers to interpret pricing requirements independently. Regular monitoring can help identify inconsistencies before they become larger compliance problems.