FTC Dealer Pricing FAQs 2026: What to Check on Your Website
The FTC's September 2026 pricing FAQs for car dealers: what the advertised price must include, what it can leave out, and how to audit your website.
A customer finds a car at one price online, then gets a different number at the dealership. The gap might be an overlooked fee, a conditional discount or a listing nobody updated. Whatever the cause, the problem starts before the sale does.
On September 15, 2026, FTC staff published Automobile Industry Pricing Transparency FAQs, fourteen questions and answers on how dealers advertise price (the FTC's announcement). They are staff guidance, not a new regulation. Don't read that as optional, though. Staff presents them as what the FTC Act already requires, and there is no grace period: the FAQs say plainly that price transparency is not a new requirement.
For a dealer, the practical next step is to follow one car's advertised price through your website, your ad feeds and your sales conversations.
What the advertised price has to include
The FAQs set one test for the most prominent price in a vehicle ad. It must be the actual price any consumer can walk in and pay, whether they negotiate or not.
So the price carries every charge you require a buyer to pay:
- The doc fee, in full, if any buyer has to pay it. If your doc fee varies from buyer to buyer, the advertised price carries the highest mandatory amount. The FAQs' own example is a $40,000 car with an $85 doc fee, advertised at $40,085.
- Fees a government allows but doesn't require. A dealer fee doesn't turn into a government charge because a state permits it.
- Government fees charged to you that you pass on to the buyer.
- Anything else the buyer can't decline, such as a required prep fee or an add-on already installed that the buyer has to pay for.
Only one kind of charge may stay out: an amount a federal, state or local government requires the consumer to pay directly, such as sales tax. Use the government's actual amount. If you add a processing charge on top of a government fee, that part is yours, and it belongs in the price.
Discounts, rebates and dealer financing
MSRP, discounts and rebates can still appear in an ad, as long as the actual price is the most prominent amount and shoppers know what they would pay to get the car. Prominence isn't only font size. Placement and visual hierarchy count too.
The FAQs give two examples. A car advertised at $34,999 with a $1,000 first-responder discount is fine when $34,999 is the price that stands out and the discount's terms are clear. A discount tied to dealer financing works the same way: the price any consumer would pay, with any financing, has to lead.
What you can't do is build the headline price around a discount or rebate only some buyers can get. The warning letters the FTC sent to 97 auto dealership groups in March 2026 listed that practice among its examples of illegal pricing, along with prices that leave out required fees, prices that ignore an additional required down payment, prices that depend on using dealer financing, and requiring buyers to purchase items the advertised price doesn't reflect.
Where it applies
The FAQs reach well past the vehicle detail page. They cover your website and third-party sites, social media, print ads, roadside signs, and phone calls and texts with your staff. Any webpage that states an amount a consumer may pay is in scope, including inventory search pages and individual vehicle listings.
Responsibility is shared, too. Everyone with control over an ad is responsible for making it state the actual price as the most prominent amount. For a dealer, that means giving marketplaces and other third parties the actual price and taking the steps within your control to get it published correctly.
The head of the FTC's Bureau of Consumer Protection put it bluntly in prepared remarks to the National Automobile Dealers Association the day after the FAQs came out: "Software providers, advertising platforms, dealers, and OEMs all play a role in conveying accurate pricing information." He noted the remarks were his own views, not necessarily the Commission's.
Is this the FTC CARS Rule?
No. The CARS Rule (Combating Auto Retail Scams) never took effect. The Fifth Circuit vacated it in January 2025, and the FTC formally withdrew it effective February 12, 2026.
The FAQs don't replace it with a new rule. They rest on Section 5 of the FTC Act, which prohibits deceptive or unfair practices and has applied to dealer advertising for decades. The FTC's separate rule on unfair or deceptive fees covers live-event tickets and short-term lodging, not vehicle sales.
State law can add more. California's CARS Act becomes operative on October 1, 2026, with its own total-price requirements for ads and first responses. Our California CARS Act guide walks through them.
What enforcement looks like
Two 2026 cases show what the FTC asks for once a case reaches an order. In April, the FTC and Maryland's attorney general settled with Lindsay Automotive Group: consumers charged a total of more than $75 million between April 2020 and December 2025 may be eligible for redress, and a $3.1 million civil penalty goes to the Maryland Attorney General's office. The order requires the dealer group to disclose the total amount a consumer must pay, excluding only required government charges.
In August, a $4 million settlement with Manchester City Nissan in Connecticut required the dealer to show the maximum total price, excluding only required government charges, as the most prominently displayed item.
Start with one vehicle, not a sitewide redesign
Pick an available car and collect its inventory record, its search-results listing, its vehicle detail page, its third-party ads and a sample written quote.
Put them side by side. Can a salesperson explain every difference without adding a required charge the shopper never saw?
Illustrative example: a car's selling price is $20,000, and every buyer pays a $500 doc fee. A $500 first-responder discount is open only to eligible buyers. Under the FAQs' approach, the ad leads with $20,500, with no other charges except those a government requires the buyer to pay. The discount can appear, less prominently and with its terms, but $20,000 can't be the headline as though everyone qualified.
Run the same check on a car from your own lot:
Advertised price check
Build the price every shopper can pay, then compare it with the number in your ad. It starts with the example above; try it on a real car from your lot.
Your ad is $500 below what every shopper can pay. It could be leaving out the required charges or building in a discount only some buyers get. Either way, the most prominent price should be $20,500.
- Selling price
- $20,000
- Required dealer charges
- $500
- Price every shopper can pay
- $20,500
- With every conditional discount (show less prominently)
- $20,000
Arithmetic based on FTC staff's September 2026 pricing FAQs, for your own review. It is not legal advice and does not cover state advertising rules, so have counsel review your actual ads. Charges a government requires the buyer to pay directly can stay out of the advertised price, at the government's actual amount.
Then have counsel review the actual presentation, your fee treatment and your state's requirements.
Check the places where pricing can drift
Inventory settings. Find the field that controls the public price. Keep acquisition cost, asking price, required charges and conditional incentives apart, so nobody publishes the wrong number.
Website templates. Review the search results page and the vehicle detail page on a phone. Judge the whole presentation, fine print included. Which number does a shopper see first?
External feeds. Confirm which price field each marketplace receives. After you correct a listing, check that the destination actually changed. Updating the source doesn't prove every downstream ad refreshed, and the FAQs expect you to give third parties the actual price and take the steps within your control.
Availability and photos. An ad for a car that's in transit or parked offsite has to say so plainly, and a sold car shouldn't stay up to pull in traffic. For used cars, the FAQs say shoppers can reasonably expect the photo to show the exact car.
Sales conversations. Calls and texts count. Give staff one consistent way to explain the advertised price and any optional products, and don't let an old saved reply undo a corrected listing.
Documentation. Keep dated examples of the pages you reviewed, the changes you asked for and who confirmed them. Set a review schedule that matches how often your advertising changes.
Payment ads are a separate check
The FAQs deal with price, not payment advertising. That falls under Regulation Z, which implements the Truth in Lending Act. If an ad states a payment amount, a down payment, the number of payments or a finance charge, it also has to state the down payment, the repayment terms and the APR. A corrected price with an old payment banner beside it is still a problem.
Where AutoDealer.io fits
On AutoDealer.io's dealer management software, your website and your marketplace feeds read the same asking price from the vehicle record, so a corrected price has one place to start. You still check that each destination picked it up.
Its dealer compliance software adds document storage with expiration reminders and a full audit log of compliance actions such as OFAC screening and Red Flags checks. That keeps your compliance records organized. It doesn't review or certify an ad, and it doesn't replace legal review.
Frequently asked questions
Are the FTC's pricing FAQs a new rule?
No. They are staff guidance, not a regulation. Staff presents them as what the FTC Act already requires, and they come with no grace period, so treat them as the FTC's reading of current law.
Does the advertised price have to include the doc fee?
Under the FAQs, yes, if any buyer has to pay it. If the fee varies, the advertised price carries the highest mandatory amount. A state doc-fee disclosure can still appear, as long as the actual price is the most prominent amount.
Can we still advertise rebates and conditional discounts?
Yes, if the price any buyer can pay stays the most prominent amount and the discount's terms are clear. A discount only some buyers qualify for can't set the headline price.
Do we need to rebuild the entire website?
Start with an audit. Correcting price fields, templates and feed settings may fix what you find without a full redesign.
Does a connected website make a dealership compliant?
No. Connected data cuts duplicate work, but the dealership still needs accurate inputs, the right disclosures and a check on the final ad.
Bottom line: Audit what the shopper actually sees. The price stored in your DMS is only where it starts.
This article is general information, not legal advice. Have qualified counsel review your advertising and your state's requirements.