FTC warns auto dealership groups about pricing practices

The Federal Trade Commission (FTC) recently announced that it sent letters to 97 auto dealership groups nationwide, “warning them that the prices they advertise must be the total price—including all mandatory fees—that consumers will be required to pay.”

The letters encouraged dealers to review their advertising and pricing to ensure they are not engaging in the following 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 consumers using dealer financing
• Requiring consumers to buy additional items not reflected in the advertised price
• Advertising unavailable or non-existent vehicles

The FTC stated on March 13, 2026, that the agency is “committed” to monitoring and preventing “auto dealers from misleading consumers.” The FTC’s letters are another example of its ever-expanding focus on promoting price transparency across multiple markets, including rental housing, ticketing and hotels, grocery and delivery services, and now, auto sales and leasing.

The letters follow several pending enforcement actions the FTC filed against three automotive groups in August and December 2024; the FTC’s 2025 Rule on Unfair or Deceptive Fees, requiring upfront pricing disclosures for businesses in the live-event tickets and short-term lodging sectors; and its March 2026 announcement of an Advance Notice of Proposed Rulemaking to potentially address similar pricing and fee disclosure practices in the rental housing sector.

In light of the FTC’s increased focus on the automotive industry and intent to take further action where needed, stakeholders – including automotive manufacturers, dealers, and retailers – may wish to review existing fee disclosure and advertising practices.

DLA Piper’s Pricing Solutions & Litigation team regularly helps clients navigate compliance with pricing-related rules and best practices. For questions or guidance, please contact your DLA Piper representative or the authors of this alert.