California's Combating Auto Retail Scams Act, known as the CARS Act or Senate Bill 766, takes effect on October 1, 2026. From that date, every California dealership ad that references a specific vehicle has to show that vehicle's total price, and so does the first written message a salesperson or BDC agent sends a shopper about it. The law also covers contracting, add-on products and a new three-day cancellation option on used vehicles priced under $50,000, but this article focuses on advertising: what the statute requires, which existing California rules it keeps in force, and where dealership marketing is most likely to fall short.
This article is a marketing execution guide, not legal advice. Confirm your dealership's specific obligations with your counsel.
The CARS Act is a California consumer protection law that sets new pricing disclosure, advertising and sales requirements for retail sales and leases of new and used vehicles. Governor Gavin Newsom signed it in October 2025, it's codified in the California Civil Code beginning at Section 1784.20, and it becomes operative on October 1, 2026. The California DMV's CARS Act summary is the clearest plain-language overview, and the full text of SB 766 is published by the legislature.
Some transactions fall outside the law. Civil Code Section 1784.31(f) excludes wholesale transactions, fleet sales, commercial buyers who purchase five or more vehicles a year from the dealer for business use, and vehicles with a gross vehicle weight rating of 10,000 pounds or more.
The obligations in the law are written for the dealer. That means the dealership carries the exposure for a noncompliant ad regardless of who built it, whether that was the in-house marketing team, a website provider, an OEM co-op program or a marketing partner.
The CARS Act is also frequently confused with the FTC's CARS Rule, a similarly named federal regulation. A federal appeals court vacated the FTC rule in January 2025, so it doesn't apply to dealers anywhere. California's law is separate, and it takes effect this week.
Total price is the full sale price of the vehicle, including any dealer markup or adjustment and any add-ons already installed on the vehicle. Under Civil Code Section 1784.31(j), it excludes taxes, government fees, the dealer document processing charge and the electronic filing charge, and it doesn't subtract manufacturer rebates.
In practice, a vehicle carrying a $2,000 market adjustment and $795 in dealer-installed window tint and wheel locks has both amounts built into its total price. An ad that leads with MSRP, or with a price that only exists after rebates most buyers won't qualify for, doesn't meet the definition.
The two dealer fees excluded from total price are both capped by the Vehicle Code, and neither is a flat statewide number. Vehicle Code Section 4456.5 caps the document processing charge at $85 for dealers enrolled in the DMV's private industry partner program and at $70 for dealers who aren't. A 2025 bill that would have raised that cap, SB 791, was vetoed in October 2025, so the $85 ceiling stands. The electronic filing charge has no fixed dollar amount in the law. It's limited to what the dealer's first-line registration service provider actually charges, which is why the figure changes over time. Pull the current number from your provider and update it in your templates rather than hard-coding a figure that will go stale.
Total price has to be disclosed clearly and conspicuously in any advertisement that references a specific vehicle for sale, in any advertisement that states a monetary amount or financing term for a specific vehicle, and in the dealer's first written communication with a consumer that references a specific vehicle for sale or states any monetary amount or financing term for any vehicle. Those requirements are in Civil Code Section 1784.41(a).
The advertising half of that rule reaches every place a dealership shows a specific vehicle with a price or payment attached, including homepage slides, the specials page, search results pages, vehicle detail pages, third-party listing sites, paid search ads, vehicle listing ads, paid social, display and email campaigns.
The first-communication half reaches further than most marketing teams expect, because it's triggered by a price, payment or rate on any vehicle, not only a named unit. The DMV describes it as the first email, text, document or form that mentions the vehicle or its financing. That covers lead auto-responders, CRM email templates, BDC text scripts and the first written quote a salesperson sends. We'd treat chat responses the same way. Under Civil Code Section 1784.44, dealers also have to keep records of these communications for two years, along with every internet-based listing that displays a vehicle's total price, features or financing terms. That's a records question worth settling with your CRM and website providers now.
We expect this rule to generate more problems than any ad. Ads get reviewed before they go live. A lead response template written three years ago by someone who no longer works at the store usually doesn't.
It isn't allowed on any listing for a specific vehicle. Because SB 766 requires total price in any ad that references a specific vehicle, a vehicle detail page, search results tile or third-party listing that says "call for price" or "contact us for pricing" can't satisfy the law. The statute doesn't name the phrase, but the conclusion follows directly from the total price requirement.
This applies to used inventory as much as new. Aged units, vehicles still in reconditioning and in-transit inventory with a VIN assigned all need either a total price or removal from advertising until they have one. The same goes for "unlock ePrice" buttons and other tools that hide the price behind a lead form. If the shopper can see the vehicle, the shopper has to be able to see its total price.
Add-ons already installed on a vehicle belong in its total price, and optional add-ons have to be disclosed at least once as not required, with a statement that the consumer can buy or lease the vehicle without them. That disclosure requirement is in Civil Code Section 1784.41(b).
For advertising, the practical effect is that a pre-installed protection package or accessory bundle can't sit below the advertised price as a separate charge the shopper discovers later. If it's on the vehicle, it's in the total price.
The law also bans some add-ons outright. Section 1784.42(a) prohibits charging for an add-on the buyer wouldn't benefit from, and the examples it lists include nitrogen tire fills below 95% purity, oil change plans sold on electric vehicles, and catalytic converter theft markings on vehicles that don't have a catalytic converter. If any of those are baked into your advertised pricing, they need to come out.
When a dealer makes a written representation about a monthly payment while negotiating the purchase or lease of a specific vehicle, the dealer has to disclose at least once, clearly and conspicuously and in writing, the total amount the consumer will pay after making every scheduled payment. If that payment assumes a down payment or trade-in, the dealer has to disclose that amount too. Those rules are in Civil Code Section 1784.41(c), and they apply to emailed desking sheets, texted payment quotes and any other written payment figure shared during a deal.
Section 1784.41(d) adds a rule for side-by-side payment options. When a dealer compares monthly payments, it has to disclose that lower monthly payments often increase the total amount the consumer will pay. Online payment calculators that let shoppers adjust their own down payment, credit tier or term don't violate this rule, provided they don't alter the vehicle's advertised total price.
Advertised lease and finance specials tied to a specific vehicle also fall under the total price rule in Section 1784.41(a), because they state a monetary amount or financing term. Those ads still carry their existing federal disclosure requirements under the Truth in Lending Act and the Consumer Leasing Act, along with any OEM co-op rules. SB 766 adds to that list without replacing anything on it.
All of them still apply. Civil Code Section 1784.41(f) states that the CARS Act doesn't modify the vehicle advertising requirements in Vehicle Code Sections 11713.1 and 11713.16, including the practice of disclosing rebates and incentives separately from a vehicle's total price.
That matters because Vehicle Code Section 11713.1 already required two things many California dealer ads have ignored for years. An ad for a specific vehicle has to identify it by model, model year and either its license number or part of its VIN. An ad offering vehicles at a specified price has to disclose how many vehicles are in stock at that price. An offer that reads "on select models" with no VIN and no unit count was noncompliant long before SB 766.
The CARS Act raises the stakes on those older rules. Section 1784.40(d) separately prohibits misrepresenting the availability of vehicles at a total price the dealer has communicated, so an advertised price with nothing on the lot to back it now runs into both laws.
The statute sets the requirements, and the dealer decides how to present them. The structure below is the standard C-4 Analytics uses for California offers. It's built to make total price unmistakable and to keep every other figure in a logical order, and it goes further than the law strictly requires in a few places.
Start with MSRP, followed by any dealer discount or markup as its own line, followed by any installed add-ons. Those lines resolve to total price, which should be the most prominent figure in the offer. SB 766 requires "clear and conspicuous," not a specific size, but making total price the largest number is the simplest way to show you met the standard. Rebates available to every customer come next and produce a net price. Conditional incentives, such as military, first responder, recent graduate or loyalty cash, come after the net price along with their eligibility terms. The document processing charge and electronic filing charge appear as separate lines outside total price, and the offer closes with the VIN and the number of vehicles available at that price.
| Line Item | Amount |
|---|---|
| MSRP | $38,450 |
| Dealer Discount | -$1,200 |
| Dealer-Installed Window Tint | +$495 |
| Total Price | $37,745 |
| Manufacturer Rebate (All Customers) | -$1,000 |
| Net Price | $36,745 |
| Military Rebate (If Eligible) | -$500 |
Example only. Excludes tax, registration, document processing charge of up to $85 and electronic filing charge. VIN ending 004821. 1 at this price.
Payment offers follow the same logic. A lease or finance payment should appear alongside the vehicle's total price, not in place of it, with the amount due at signing and the rest of the required federal disclosures in the offer terms.
Most California dealers will get the specials page right, because that's where everyone is looking this week. The risk sits in the channels that pull pricing automatically or were set up once and left alone.
Model-level offers such as "$2,500 off every 2026 Explorer" with no VIN and no unit count are the most common problem. Every offer on a slide or specials page needs to resolve to a real vehicle, with total price as the lead figure and the unit count stated.
Character limits make a full price stack impossible in a search headline, which is the reason to rethink price-led ad copy rather than squeeze it. An ad that states a price or payment for a specific vehicle needs total price in it. Headlines built around selection, availability and the dealership itself avoid the issue, and the landing page can carry the full offer.
Google vehicle listing ads, Facebook automotive inventory ads and third-party marketplaces all pull price from an inventory feed. If that feed sends an internet price that excludes a market adjustment or installed add-ons, every listing it touches is advertising the wrong number. Check what price field each feed sends, and check it again whenever pricing rules change in your DMS or inventory tool. Those listings also fall under the two-year record retention requirement, so confirm your providers can produce historical listing data if you're ever asked for it.
Creative built weeks in advance with a payment in the headline and the terms in fine print was a common pattern before October 1. Any social or video ad that references a specific vehicle with a price or payment now needs the total price shown clearly within the creative itself.
Lead auto-responders, first-touch email templates and text scripts that reference a specific vehicle need total price in the first message. This is the channel most likely to be owned outside the marketing department, so assign someone to audit it by name.
Audit every live price the dealership publishes, starting with inventory feeds, because one bad feed setting can put hundreds of noncompliant listings online at once. Rebuild the specials page and homepage offers around specific VINs with total price leading. Rewrite CRM and BDC templates so the first written message about a vehicle includes its total price, and confirm with your CRM and website providers that those messages and your internet listings are being retained for two years. Brief your sales and BDC teams on the monthly payment disclosures, since they apply to every written quote they send. Then have your dealership's counsel review the finished templates, because a marketing partner can build compliant ads but can't sign off on your legal obligations.
The work doesn't end on October 1. Offers change monthly, incentives change mid-month and feeds get reconfigured when vendors change, so compliance has to be checked every time pricing moves.
Feeling overwhelmed? Request a Free Comprehensive Market and Digital Presence Analysis, and our team will show you where your dealership's digital marketing stands against the competition in your market.