Critical Shifts:
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"All-In" Price Transparency: Advertised vehicle prices must represent the total price any consumer can actually pay, requiring mandatory fees (such as dealer documentation fees) to be built into the advertised figure rather than added later.
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Universal Applicability & Prominence: Pricing disclosures apply across all marketing channels—including social media, third-party sites, and text messages—and the actual base price available to all buyers must be displayed more prominently than conditional discounts, rebates, or MSRPs.
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Enforcement & Guidance Scope: Released Sept. 15, these staff FAQs follow FTC warning letters sent to 97 dealership groups earlier this year, reinforcing existing FTC Act standards against deceptive pricing without establishing new statutory regulations.
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The Federal Trade Commission has issued new guidance aimed at helping auto dealers understand what must be included in an advertised vehicle price, reinforcing that the advertised price generally must be the actual price any consumer can pay to purchase the vehicle.
The FTC’s new automobile industry price-transparency FAQs, published Sept. 15, explain how the Federal Trade Commission Act applies to vehicle advertising. The guidance states that dealer-required fees must be included in the advertised price, with an exception for charges that a government agency requires the consumer to pay directly, such as taxes.
The guidance comes as the FTC continues to make auto pricing transparency an enforcement priority.
“The FTC Act requires truthful and accurate pricing, which brings significant benefits for consumers and competition,” said Christopher Mufarrige, director of the FTC’s Bureau of Consumer Protection.
The FTC’s FAQs address several areas of vehicle advertising, including:
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What must be included in an advertised price
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How document fees should be handled
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How discounts and rebates should be presented
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How advertised prices apply when consumers negotiate
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How optional products and services should be disclosed
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Pricing across websites, social media, print and other advertising
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How to advertise vehicles that are still in transit
One of the central points in the guidance is that a dealer cannot advertise a vehicle at a price that is only available to a limited group of consumers if other consumers would be required to pay more.
For example, the FTC says a dealer advertising a vehicle for $24,999 cannot use that figure if the price is actually available only to certain shoppers and another consumer walking into the dealership would be quoted $26,499.
The same principle applies to mandatory fees. The FTC gives the example of a vehicle advertised at $40,000 with an $85 mandatory document fee. In that situation, the advertised price should be $40,085 rather than $40,000 plus the document fee later in the transaction.
The agency also says the actual price must be the most prominent price when advertisements show multiple prices. Dealers can advertise MSRP, rebates or discounts, for example, but the price any consumer can actually pay must be presented most prominently and the terms of any discount must be clear.
The guidance applies beyond a dealership's website. The FTC says pricing statements appearing on third-party sites, social media, print advertisements, roadside signs, phone calls and text messages can all fall under the FTC Act's requirements for truthful and transparent pricing.
FTC has already warned dealer groups
The new FAQs follow a warning the FTC issued earlier this year to 97 auto dealership groups nationwide. The agency urged the groups to review their advertising and pricing practices and warned that advertised prices must include mandatory fees consumers are required to pay.
The FTC says it also continues to pursue cases involving dealers accused of advertising one price and charging consumers more through undisclosed fees or other charges.
The agency's FAQs emphasize that the guidance does not create a new price-transparency requirement. Instead, it explains how existing requirements under the FTC Act apply to automotive advertising. The FTC also notes that the FAQs represent the views of FTC staff and are not binding on the public or the Commission.
