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FTC pricing rules for car dealers: doc fees, rebates and add-ons

The FTC's September 2026 pricing FAQs say a car's advertised price must be the price any buyer can pay, with doc fees and other required fees included. There is no single FTC pricing rule for dealers; these FAQs, the FTC Act and the federal ad rules are what apply.

By Jason L. Baptiste · Updated

At a glance

Doc fees
In the advertised price
Rebates
Only if every buyer gets them
Add-ons
Never shown as required when optional
Warning letters
97 dealer groups, March 2026
On this page

The FTC's pricing FAQs (September 2026)

FTC staff published Automobile Industry Pricing Transparency FAQs. They ask that "the advertised price be the actual price any consumer can walk in and pay," leaving out only government charges. In plain terms:

  • Doc fees go in the price. Mandatory fees, doc fees included, belong in the advertised price. If the fee varies, use the higher one.
  • No rebates some buyers can't get. Don't build in discounts or rebates that not every buyer qualifies for.
  • Optional means optional. Don't present an add-on as required when it isn't.
  • Lease ads. If a lease ad states the amount due up front, upfront processing fees must be in it.

The FAQs rest on section 5 of the FTC Act. They say they don't change Truth in Lending or Consumer Leasing duties.

Warning letters and cases

In March 2026 the FTC sent warning letters to 97 auto dealership groups about deceptive pricing. Its recent cases include Leader Automotive Group (bait-and-switch pricing and add-ons), Lindsay Auto Group (deceptive pricing and unwanted add-ons), Manchester City Nissan (deceptive fees) and Greenway Auto Group (advertised prices below what buyers paid). What happened to the CARS Rule.

Payment and lease ads

  • Credit ads (Reg Z 1026.24(d)): a down payment, number of payments, payment amount or finance charge in an ad triggers the full disclosures: down payment, repayment terms and the "annual percentage rate".
  • Lease ads (Reg M 1013.7(d)): a payment or an amount due at signing triggers: that it is a lease, the total due at signing, the payment schedule, whether a security deposit is required, and a possible end-of-lease charge.

The Used Car Rule

Every used car you offer needs an FTC Buyers Guide in the window (16 CFR Part 455), in Spanish too when the sale is conducted in Spanish. The FTC's Dealer's Guide says violations can bring penalties of up to $53,088 per violation. Make a Buyers Guide free.

A pricing checklist for your store

  1. Price = what anyone can pay

    Advertised price includes the doc fee and every fee all buyers pay. Only taxes and government fees are extra.

  2. Same price everywhere

    Your website, third-party listings and the window should show the same price.

  3. Conditional offers stay out of the price

    Loyalty, military or financing discounts can be mentioned, but not baked into the headline price.

  4. Add-ons are a separate, signed choice

    Show them as optional, with their price, and keep the signed consent in the deal jacket.

  5. Check before you post

    Run the free price check on a listing or ad.

Rules checked and limits

Rules checked October 31, 2026. We read every rule on this page in the eCFR or on the agency's own site, and each is linked in the sources below. We re-check them every quarter.

California dealers have extra duties under SB 766; see our California CARS Act guide.

Templates and tools, not legal advice. CarShots is software, not a law firm. For a question about your own dealership, ask your attorney or your state dealer association.

Common questions

Does my advertised car price have to include the doc fee?

Yes, per the FTC's September 2026 pricing FAQs. Mandatory fees including doc fees belong in the advertised price; if the fee varies, use the higher fee.

Can I add the doc fee at the desk if it is in my ad disclaimer?

The FAQs say the advertised price should be what any buyer can walk in and pay, so a mandatory fee belongs in the price itself, not only in fine print.

Are dealer add-ons allowed?

Yes, if they are truly optional, shown as optional and the buyer agrees to them. Don't present them as required.

What were the FTC warning letters?

In March 2026 the FTC sent letters to 97 auto dealership groups warning them about deceptive pricing.

Is there an FTC rule on dealer pricing?

Not a dealer-specific one since the CARS Rule was vacated and removed. The FTC applies section 5 of the FTC Act, explained in its pricing FAQs.

See your compliance gaps and a free draft plan

Answer about ten minutes of questions. Get your score, your gap list and a watermarked draft of your security plan, free with no card. Essentials is $99 per store a month when you're ready.