The Federal Trade Commission’s Bureau of Consumer Protection published a set of frequently asked questions on price transparency in vehicle advertising on September 15, 2026. The full FAQ document is available at ftc.gov/business-guidance/resources/automobile-industry-pricing-transparency-faqs. 

The guidance follows the warning letters the FTC sent to 97 auto dealer groups nationwide in March 2026 and builds on the enforcement actions discussed in MADA’s prior alerts on this topic. It’s the most detailed statement the agency has issued on how it reads Section 5 of the FTC Act as applied to vehicle pricing.

The Core Rule

The FAQs restate a single governing principle: the price a dealer advertises has to be the actual price any consumer can walk in and pay. The only amounts a dealer can leave out are charges a government agency requires the consumer to pay directly, such as taxes, title, and registration fees. Everything else the dealer requires a consumer to pay, including fees the government authorizes but does not mandate, and fees the government charges the dealer but the dealer passes on to the consumer, has to be built into the advertised number.

This rule applies across every advertising channel a dealer uses: dealership and third-party websites, inventory-search pages, individual vehicle listings, social media, print ads, roadside signs, and even phone calls or texts with dealership staff.

Document Fees

The FAQs directly address a question MADA has covered before: how document fees fit into this framework. The FTC’s answer is unchanged from what NADA relayed after its March 2026 meeting with FTC staff, and the new guidance makes it official. The advertised price must include the full document fee if the dealer requires any consumer to pay it. The FTC gives a specific example: if a dealer advertises a $40,000 vehicle and would also charge any consumer an $85 document fee, the advertised price has to be $40,085, with no other charges layered on beyond what the government requires.

The guidance also closes a possible workaround. If a dealer discounts the document fee for some buyers but charges a higher, mandatory fee to others, it can’t advertise a price based on the lower, discounted fee. The advertised price has to reflect the full fee that any consumer might actually be required to pay.

On the relationship between this federal rule and state law, the FAQs say state requirements don’t change the underlying FTC Act obligation. Some states, including Minnesota, require dealers to separately itemize fees on the purchase agreement itself. Minn. R. 7400.5200, subp. 2(E) requires an itemized list of all fees and taxes collected in connection with a transaction, and that purchase agreement requirement is unaffected by this FAQ. The FTC’s position is that once a dealer has satisfied the federal requirement that the actual, all-in price is the most prominent figure in an advertisement, it’s then free to add whatever state-law disclosures are separately required.

It is worth noting that MADA’s own advertising standards (https://mada.org/wp-content/uploads/2026/05/MinnesotaAdvertisingStandards2026May.pdf) go a step further than the federal floor set by these FAQs. Where the FTC only requires the all-in price to be the most prominent figure, without necessarily specifying how that figure is broken down, MADA’s standards require dealers to itemize and disclose the document fee within the advertisement itself. That extra step removes any ambiguity about whether the prominent price a consumer sees actually includes the doc fee, rather than leaving a consumer to assume it does.

MSRP, Discounts, and Rebates

Dealers can still list MSRP, discounts, and rebates in an ad, but only if the actual, all-in price remains the most prominent figure. The FAQs note that prominence is not just about font size: if a smaller-font MSRP appears somewhere more likely to catch a shopper’s eye than the larger-font actual price, that can still violate the rule. A dealer advertising a $34,999 vehicle can offer a $1,000 discount to a specific group, like first responders, as long as $34,999 (the price any consumer could actually pay) stays the most prominent number and the discount’s terms are clear.

Negotiated Prices and Optional Add-ons

The FAQs confirm that dealers and consumers can still negotiate, and a consumer can end up paying less than the advertised price. But the advertised price itself always has to reflect what any consumer, not just a favored subset of past buyers, could walk in and pay. A dealer can’t advertise a price based on a discount that was only available to a handful of prior customers if a new shopper would actually be quoted more.

The same logic applies to optional items like protection packages or accessories. Dealers can offer them, but can’t suggest an optional item is required, can’t imply an installed “option” can’t be removed, can’t misstate its cost, and can’t charge for anything the consumer didn’t agree to.

Vehicles In Transit or at Other Locations

The FAQs also address advertising vehicles that are not physically on the lot, whether they are in transit from the manufacturer, stored offsite, or available through inventory sharing. It is not deceptive on its own to advertise a car that is not currently on the lot, but the ad has to make that clear. Dealers also cannot advertise a vehicle that has already been sold and delivered as a way to draw shoppers in and then steer them toward something more expensive.

Who is Responsible?

The FAQs make clear that responsibility for accurate pricing runs across everyone with control over an ad: the dealer, any third-party advertiser, and the manufacturer, where applicable. Dealers should supply the accurate, all-in price to any third party handling their advertising and confirm that price is what actually gets displayed most prominently.

Why This Matters

This guidance does not create new law, but it does give dealers a clearer sense of how the FTC will scrutinize specific advertising practices, particularly around document fees, MSRP placement, and discount-based pricing. Given the recent warning letters and the recent multi-million settlements, the FTC has signaled this is an active enforcement priority, not just a guidance document sitting on a shelf. Members already following MADA’s advertising standards, including itemized doc fee disclosure, should be well positioned against this federal guidance.