On 13 March 2026 the FTC sent warning letters to 97 auto groups nationwide, telling them that the prices they advertise must be the total price — including all mandatory fees — that consumers will actually be required to pay. There is no new rule behind this; the FTC is enforcing Section 5 of the FTC Act, which prohibits deceptive acts and practices. The practical consequence is that the price field on your vehicle detail page is now a compliance surface, not just a design element.
I'm a developer, not a lawyer, and nothing here is legal advice — take the specifics to your dealer counsel or your state association. What I can tell you is what this looks like in the code, because the price block on a VDP is something I build, and most of the compliance failures I've seen are structural rather than deliberate.
This article covers US federal expectations. State advertising rules are stricter in many places and are not covered here.
What the FTC actually said
The warning letter template is public. It opens by telling the recipient they "may be advertising prices for cars that are lower than what you actually charge consumers," and states that the FTC "is committed to ensuring that the price consumers see in advertising is the actual price they will pay (aside from required government charges, like taxes)."
It then lists examples of illegal pricing practices:
- advertising a price that does not reflect all required fees
- advertising a price that reflects rebates or discounts not available to all consumers
- advertising a price that fails to account for an additional required down payment
- conditioning the advertised price on the consumer using dealer financing
- requiring consumers to buy additional items not reflected in the advertised price
- advertising unavailable or nonexistent vehicles
The minimum action it asks for is blunt: evaluate your advertised prices against your actual prices and confirm they match. Christopher Mufarrige, Director of the Bureau of Consumer Protection, framed the campaign as preventing dealers from "misleading consumers with low advertised prices and then adding on mandatory fees at the end of the purchasing process."
The letter also cites the enforcement history it's building on: FTC v. Lindsay Chevrolet (Dec 2024), alleging dealerships advertised prices they refused to honour and falsely claimed consumers had to finance through the dealership; FTC v. Leader Automotive Group (Dec 2024), alleging deception about price and availability including charges for pre-installed products; and Asbury Automotive Group (Aug 2024), alleging inflated prices through hidden charges and required add-ons.
The rule you may have heard about isn't in effect
A lot of dealers still think the CARS Rule governs this. It doesn't. The FTC's Combating Auto Retail Scams Rule was finalised in January 2024 and covered misrepresentations across 16 categories, required total upfront pricing, and required express informed consent for added charges. NADA and the Texas Automobile Dealers Association petitioned the Fifth Circuit the same day it was published, and on 27 January 2025 the court vacated it 2–1 — on procedural grounds, because the FTC had failed to issue an Advance Notice of Proposed Rulemaking as its own regulations required. The court explicitly did not rule on whether the underlying practices were unfair or deceptive.
This matters for how you read the current situation. The rule is gone, so the specific CARS disclosure mechanics don't bind you. But the conduct it targeted is still actionable under Section 5, which is exactly what the 2026 warning letters and the 2024 enforcement actions demonstrate. "The rule got struck down" is not a defence.
What this means for the price field on your VDP
Six things, all of them build decisions.
One price, and it's the one you'll honour. Whatever number sits in the largest type on the page should be the total the buyer pays, excluding only required government charges like taxes. If your site's price is a pre-fee figure and the fees appear later in the funnel, that's the precise pattern the letters describe.
Mandatory fees belong in the price, not in a footnote. A dealer documentation fee that every buyer pays is not a disclosure, it's part of the price. The technical tell is a price template with a * and a tooltip carrying "plus dealer fees." If the fee is unavoidable, a tooltip doesn't fix it.
Conditional discounts can't be baked into the headline. Military, first-responder, recent-graduate and loyalty rebates aren't available to everyone, so a price net of them isn't the price. The compliant build shows the price everyone can get, then lists conditional incentives separately with their conditions attached.
Finance-contingent pricing has to be labelled as such. Conditioning the advertised price on using dealer financing appears on the FTC's list by name.
Availability is a pricing issue. Advertising unavailable or nonexistent vehicles is on the same list. That makes your inventory sync frequency a compliance question, not a convenience question — how fast a sold car disappears from your site is the thing being tested. This is worth reading alongside how inventory actually gets from your lot onto your website.
Pre-installed add-ons need to be in the number. If a vehicle physically has a $1,200 protection package on it that the buyer cannot decline, the advertised price includes it.
Here is what a compliant price block looks like in markup, with example figures:
<!-- 1. Headline price: the total the buyer pays, before government charges -->
<p class="price">$24,995</p>
<p class="price-note">Includes the $499 dealer documentation fee and every other
required dealer charge. Plus tax, title and registration
(government charges).</p>
<!-- 2. Conditional incentives, listed separately with their conditions -->
<ul class="incentives">
<li>$500 military rebate: active-duty and veterans only, proof required</li>
<li>$750 bonus: only if financed through the dealership</li>
</ul>
<!-- 3. Sold state: the price disappears with the car -->
<p class="status">Sold. This vehicle is no longer available.</p>Read against the FTC's list, each element does a specific job. The headline price includes every mandatory fee, which covers the "all required fees" and "additional required items" examples. Tax, title and registration are the only exclusions and they're labelled as government charges, which is the one carve-out the letter allows. Rebates that not everyone qualifies for sit outside the headline number with their conditions attached, and the finance-contingent bonus is labelled as such rather than being subtracted from the price. Finally, a sold vehicle stops advertising a price at all, which answers the "unavailable vehicles" example.
The template problem
Here's where this becomes a website question rather than a policy question. Vendors do sell tooling for this — DealerOn, for example, markets a drag-and-drop pricing display tool that lets dealers change the colour, size and placement of prices, and as of September 2026 its site references updated pricing display capabilities and a product called OnGuard for data retention and OEM compliance. So the capability exists on major platforms and you should ask your vendor exactly what theirs does.
The structural risk is different. On a template platform, your price block is a configured component: you get the fields the platform gives you, arranged how the platform allows, updated when the platform ships an update. If your fee structure doesn't map onto those fields, your options are to misrepresent it or to file a ticket and wait. When a regulator's position shifts, the question becomes how fast your vendor can change the template and whether you can verify what changed.
When you own the code, the price block is a component you can change on the afternoon your lawyer tells you to change it. That's not an argument that custom is always right — it isn't — but price display is one of the clearest cases where control over the template has a concrete value, and it belongs in the custom versus platform calculation.
What this means for your dealership
Pull up five of your own VDPs and compare the displayed price to what your finance office actually writes on the buyer's order for the same vehicle. If they differ by a mandatory fee, you have found the issue the FTC's letters describe, and you found it more cheaply than a regulator would have. Then check what your site does with a vehicle the moment it sells, and whether any conditional rebate is being subtracted from a headline price.
Where I'd tell you not to hire me
If you're a franchise dealer, your OEM co-op and compliance requirements probably constrain price display in ways that a platform with an existing OEM programme handles better than a bespoke build. And if what you actually need is a legal review of your advertising, that's a dealer attorney's job, not a developer's. I can build whatever they tell you the price block has to show — I can't tell you what it has to show.
Sources
- FTC, FTC Warns 97 Auto Dealership Groups About Deceptive Pricing (press release) and Template Auto Warning Letter (sent 13 March 2026).
- Holland & Knight, Fifth Circuit Strikes Down FTC's Auto Retail Scam Rule (Feb 2025) — CARS Rule vacated 27 Jan 2025 on ANPRM procedural grounds.
- DealerOn product pages, as published September 2026 — pricing display tool and OnGuard, cited as the vendor's own published claims.
Not legal advice. If you want the technical side checked, send me a vehicle URL and I'll tell you what the price block is actually doing.