The FTC CARS Rule, Explained: What the Dealer Junk-Fee Crackdown Means for Car Buyers (2026)

Updated 2026-06-28 · Reviewed by Sam Reynolds, Lead Researcher, CarWhere

The short version

The FTC's CARS Rule would have banned dealer junk fees and forced dealers to advertise one all-in “offering price.” A federal appeals court vacated it in January 2025, and the FTC formally withdrew it in February 2026 — so it is not in effect. Deceptive and hidden pricing is still illegal under Section 5 of the FTC Act (a record $20 million dealer settlement in 2024; warning letters to 97 dealer groups in March 2026), and states are filling the gap. The practical takeaway for buyers: the law won't force transparency for you, so you have to bring your own price data.

For a few years it looked like the federal government was about to make car-buying radically more honest. The Federal Trade Commission's CARS Rule — short for Combating Auto Retail Scams — promised to outlaw the surprise fees and worthless add-ons that turn an advertised price into a much bigger number at signing. The FTC estimated it would save Americans more than $3.4 billion and 72 million hours every year. Then the dealer lobby sued, and the rule never took effect.

What happened to the CARS Rule

June 2022
The FTC proposes the "Motor Vehicle Dealers Trade Regulation Rule" to ban junk fees and bait-and-switch tactics.
Dec. 12, 2023
The FTC finalizes it as the CARS Rule (Combating Auto Retail Scams), with a July 30, 2024 effective date.
Dec. 2023
The National Automobile Dealers Association (NADA) and the Texas Automobile Dealers Association petition the Fifth Circuit to strike it down.
Jan. 2024
The FTC pauses the July 30, 2024 effective date pending the court challenge.
Jan. 27, 2025
The Fifth Circuit vacates the rule (2–1), holding the FTC skipped a required procedural step (an advance notice of proposed rulemaking).
Feb. 12, 2026
The FTC formally withdraws the CARS Rule from the Code of Federal Regulations — a ministerial step conforming the rules to the court's decision. No appeal, no re-proposal.

The court never ruled on whether banning junk fees was a good idea — it threw the rule out on procedure, because the FTC skipped a required preliminary notice step. In theory the FTC could start over. As of mid-2026 it has shown no sign of doing so.

What the rule would have required

It's worth knowing what protections were on the table, because they describe exactly the tactics to watch for now that the rule is gone. The CARS Rule would have:

  • Banned bait-and-switch advertising about price, availability, financing, and add-ons.
  • Required dealers to disclose an "offering price" — the actual price any consumer can pay, excluding only government taxes and registration.
  • Banned charging for add-on products or services that provide no benefit to the buyer.
  • Required express, informed consent for every charge — no fees sneaked into the contract, no add-ons falsely labeled "required."
  • Required disclosure of the total amount you would pay when a dealer quotes a monthly payment.
  • Added explicit protections for military servicemembers and their families.

So are dealer junk fees legal now?

There's no federal rule that bans them by name — but that doesn't mean anything goes. Section 5 of the FTC Act still prohibits unfair and deceptive practices, and the FTC has kept enforcing it against dealers. In December 2024 it won a $20 million settlement against Leader Automotive Group — the largest monetary judgment the FTC has ever obtained against an auto dealer — over undisclosed add-ons, junk fees, and deceptive pricing. In March 2026 it sent warning letters to 97 dealership groups, stating plainly that an advertised price must be the total price including every mandatory dealer-imposed fee — doc fees, dealer prep, e-filing charges, and “market adjustments” — with only government taxes and registration left out, in all 50 states.

States have stepped in too. Roughly 22 states cap dealer doc fees while about 28 don't; California signed its own state-level CARS Act in 2025. The upshot: a fee that's clearly disclosed and consented to is generally legal, but one that's hidden, misrepresented, or tacked on without your agreement may not be — and you can push back on any of them.

What actually protects you now: your own price data

The CARS Rule would have forced the all-in number into the open. Without it, the burden is back on you — and the single best defense against a junk fee is knowing what a fair number looks like before you walk in. That's the gap CarWhere fills with real transaction data, not advertised prices:

  • The Dealer Fee Index →

    The median dealer doc fee in your state, from thousands of verified buyer quotes — so you can tell a standard fee from an inflated one.

  • Verified buyer-paid deals →

    What real buyers actually paid for the car you want — the “offering price” the rule would have required, reconstructed from data.

  • Out-the-door price calculator →

    Add taxes, registration, doc fees, and add-ons to see the true total before you sign — and catch anything that doesn't belong.

  • Negotiation guide →

    How to demand an itemized out-the-door price and refuse add-ons you never agreed to.

You just got the basic decode. Unlock the full picture for $9.99.

One-time. No subscription, ever. You see exactly what your report includes before you pay — no blind-box reports.

Pay $9.99 for Full ReportSee a sampleNo subscription, ever · Availability confirmed before you pay

FAQ

Is the FTC CARS Rule in effect in 2026?

No. The CARS Rule was vacated by the Fifth Circuit Court of Appeals on January 27, 2025, and the FTC formally withdrew it from the federal rulebook effective February 12, 2026. The FTC did not appeal and has not re-proposed it, so none of its specific requirements are in force.

Are dealer junk fees illegal now?

There is no federal rule that bans dealer junk fees by name. But deceptive and undisclosed pricing is still illegal under Section 5 of the FTC Act. In March 2026 the FTC sent warning letters to 97 dealership groups stating that an advertised price must be the total price including all mandatory dealer-imposed fees — doc fees, dealer prep, e-filing, and "market adjustments" — with only government taxes and registration excluded. So a hidden or misrepresented fee can still be unlawful; a clearly disclosed one generally is not.

What is a fair dealer doc (documentation) fee?

It varies enormously by state. About 22 states cap the fee and roughly 28 do not. CarWhere's analysis of thousands of verified buyer quotes found a national median around $490, ranging from California's $85 cap to roughly $995 in states like Florida. A doc fee well above your state's typical figure is a negotiation flag — see the CarWhere Dealer Fee Index for your state's median.

Can a dealer charge me for an add-on I never agreed to?

They should not, and doing so can violate Section 5 of the FTC Act and state consumer-protection law. Always get an itemized out-the-door price in writing before signing, and refuse to pay for any add-on (nitrogen tires, paint sealant, VIN etching, "protection packages") you did not affirmatively request.

Next read: Dealer junk fees — which to pay and which to refuse · How to negotiate car price

Sources

FTC, “FTC Announces CARS Rule” (Dec. 12, 2023) and “FTC Pauses CARS Rule Effective Date” (Jan. 2024); U.S. Court of Appeals for the Fifth Circuit, No. 24-60013 (Jan. 27, 2025); Federal Register, withdrawal of the CARS Rule (eff. Feb. 12, 2026); FTC, “FTC, Illinois Take Action Against Leader Automotive Group” (Dec. 19, 2024); FTC, “FTC Warns 97 Auto Dealership Groups About Deceptive Pricing” (Mar. 13, 2026). Doc-fee figures: CarWhere Dealer Fee Index. This article is general information, not legal advice.