What dealer ads must disclose now that the CARS Rule is gone

If you sat through a compliance webinar in 2024, you were told the CARS Rule was coming and it would change how every dealer advertises a price. Then it went quiet, and most stores never heard the ending.

Here is the ending, and why it matters less than the headlines suggested and more than the silence implies.

What actually happened

The Federal Trade Commission finalised the Combating Auto Retail Scams Rule, known as the CARS Rule, in late 2023. It set out specific requirements around advertised pricing, add-ons, and disclosures. It was challenged before it ever took effect.

In January 2025 the Fifth Circuit vacated the rule, finding that the FTC had not followed its own required rulemaking procedure. The Commission did not appeal, and in February 2026 the rule was formally withdrawn from the federal rulebook.

So the CARS Rule is gone. Its specific requirements are not in force, and any vendor still selling you compliance software on the basis that the rule mandates something is selling you a product for a regulation that no longer exists.

What did not change

This is the part that gets missed. The CARS Rule was never the source of the prohibition on deceptive pricing. It was one attempt to codify specifics on top of a much older and still perfectly operational authority.

Section 5 of the FTC Act prohibits unfair and deceptive acts and practices, and it applies to vehicle advertising exactly as it did before the rule existed and after it was vacated. In March 2026 the FTC sent warning letters to dealership groups restating its position: an advertised price should be the total price including mandatory dealer-imposed charges such as documentation fees, dealer preparation, and market adjustments, with government taxes and registration the accepted exclusions.

In other words, the rule that would have spelled it out is gone. The expectation it was spelling out is not.

State rules are frequently stricter

Federal law is the floor, not the ceiling. State advertising regulations and state attorney general enforcement operate independently of what the FTC does, and in several states the requirements around advertised price, disclaimers, and availability are more demanding than anything the CARS Rule proposed.

The vacating of a federal rule changes nothing about your state obligations. If your compliance posture was built on the federal rule alone, it was already incomplete.

The practical version for your ads

Strip away the regulatory history and the operating principle is unchanged and fairly simple: the price you advertise should be a price a real customer can actually pay, on a vehicle that actually exists, for as long as you say it runs.

• If a fee is mandatory and you impose it, it belongs in the advertised price rather than in a disclaimer.
• If the offer has conditions, they need to be legible in the format the ad actually runs in. Type sized for a desktop preview is unreadable in a phone feed, and a disclaimer nobody can read protects nobody.
• If a unit sells, the ad carrying its price should come down. This is the most common problem in practice and it is an operations issue, not a legal one.
• If an offer expires, the creative expires with it. That is an argument for producing creative you can update rather than one expensive spot you cannot.

Why this is a creative problem, not just a legal one

Most compliance failures are not a store trying to deceive anyone. They are a store that cannot update its advertising fast enough to keep up with its own inventory and offers.

A spot that took six weeks and a crew to produce cannot be corrected when a unit sells on Thursday. So it keeps running, and a technically stale ad becomes a compliance exposure by accident. Production speed and compliance are the same problem wearing different clothes.

Build creative that can be versioned and re-rendered when the offer changes, and most of this stops being something you have to remember.

This is orientation, not legal advice

We produce dealer advertising, we are not your lawyers, and nothing here is legal advice. Regulatory positions move, this one moved twice in eighteen months, and your state rules and OEM co-op requirements sit on top of the federal picture described here.

Have counsel review your offer and disclaimer language before it runs. What we can tell you is that the compliance posture, the production process, and the media plan should be designed together, because in practice they fail together.