California's CARS Act is not coming. It is here. SB 766, the California Combating Auto Retail Scams Act, codified at California Civil Code section 1784.1 and following, has been operative since October 1, 2026, and its best-known rules land squarely on your website and on the first messages your store sends. We covered the bigger picture, why transparency is becoming the way dealer websites win, in transparency is the future of the dealer website. This post is the practical companion: a checklist you can walk through against your own site, page by page and message by message.
1. The total price is the most prominent number, everywhere the car appears
Any ad or listing that references a specific vehicle, or states a price or a financing term for one, has to carry that vehicle's total price, and the total price has to be the most prominent price on the page. That applies on your own site and everywhere your feed sends the car:
- Inventory search and listing pages: the total price is the headline number on every card, not a smaller figure underneath it.
- Vehicle detail pages: the total price leads; any MSRP or other reference figure sits below it, clearly secondary.
- Third-party listings and ad feeds: the same total price travels with the car to listing sites, Google vehicle ads and social ads, because the feed, not a person, fills those pages in.
- Specials, banners and landing pages that name a specific car: if the car is named, its total price goes with it.
2. Build the total price the way the Act defines it
A prominent number built the wrong way is still the wrong number. Under the Act, the total price for a specific vehicle:
- Includes anything already installed on the car: accessories, equipment and dealer add-ons fitted before the sale are in the total, never added later as a surprise.
- Includes any dealer markup or market adjustment. If the store adds it, the advertised total carries it.
- Does not deduct a rebate. A price that only works after a rebate, especially one not every buyer qualifies for, is not the total price.
- Discloses the document processing (doc) fee separately, so a shopper can see exactly what that charge is.
- Excludes only government charges: taxes and government fees sit outside the total price and are shown as what they are.
Our guide to out-the-door pricing and pre-qualification online shows how that same total carries through an itemized online checkout instead of restarting at the desk.
3. The same total price appears in your first written communication
The Act follows the shopper off the page. The first written communication about a specific vehicle has to include its total price at least once: the first email, the first text, the first chat reply, the first message out of your CRM or BDC tool. Check the automated messages as well as the hand-typed ones. An autoresponder, a chat agent or a follow-up template that quotes a different number, or no number, is still your first written communication, and it is the one that gets kept.
4. Add-ons are priced separately and stated, in writing, as optional
- Every add-on is priced on its own line, separate from the vehicle's total price.
- The shopper is told in writing, clearly, that add-ons are optional and are not required to buy or finance the car.
- Anything already installed on the car is not an optional add-on at all: it belongs in the advertised total price from the start.
- Charging for an add-on that gives that buyer and that car no benefit is banned. Think of the examples regulators keep naming, like a service product that does not apply to the vehicle it is sold on.
5. Payment quotes in writing show the full cost of the term
When a monthly payment is quoted in writing, on a vehicle page, in checkout or in a message, it has to be honest about the whole deal: the total of all payments over the term, and the down payment and trade value the quote assumes. A low monthly figure on its own, with the term stretched and the total cost left out, is exactly the pattern the Act aims at. A lower monthly payment can mean a higher total cost, and the written quote should say so rather than hide it.
6. Sold cars come down promptly
A listing for a car you no longer have is an ad for a price no shopper can pay. Sold vehicles should come off your site and out of your feeds promptly, and a car that is in transit or not yet on the lot should say so, with an expected arrival where you can give one. Used-car listings should show the actual vehicle, not a look-alike. This is also where a feed that refreshes often earns its keep: the longer a sold car stays up, the more first messages go out quoting a price on a car that is gone.
7. Keep the records for two years
The Act requires dealers to create and keep records that show what they advertised and what they told shoppers, for two years, and to be able to produce them. For the website, that means keeping:
- Copies or exports of internet listings and ads for a specific vehicle, showing the total price, features and any financing terms used.
- The first written communication sent about a specific vehicle, across email, text, chat and CRM templates, with the total price it carried.
- The version of each template and autoresponder in use at the time, not just the current one.
Ask whoever runs your site how those records are captured and where they live. 'The site just shows the current price' is not a records process.
The federal layer: there is no FTC CARS Rule
One point of confusion is worth clearing up in a checklist, because vendors still get it wrong. There is no federal FTC CARS Rule to follow: the Fifth Circuit vacated that rule on January 27, 2025, and the FTC formally withdrew it in February 2026. The federal layer is the older FTC Act, Section 5, which bans deceptive pricing, plus the FTC staff price-transparency FAQs published on September 15, 2026. Their test is simple to state: the advertised price must be the actual price any shopper can walk in and pay, excluding only government-required charges, with mandatory dealer fees included and no price built on rebates or conditions most shoppers cannot meet. California's total price and the FTC's advertised price point the same direction, and a website built for one should be checked against the other, because meeting one does not automatically prove the other.
What a website cannot do for you
A checklist for the website should be just as clear about its limits. The CARS Act also gives buyers of used vehicles priced at $50,000 or less a right to cancel within three business days, on the Act's mileage and restocking terms; it sets requirements for the contract paperwork and F&I process, and for signs and disclosures in the store. No website can run those parts. They belong to your sales process, your paperwork and your staff, and your dealership's own counsel should review them. A website's job is narrower: show the right number, the same way, everywhere it speaks for you, and keep the receipts.
A ten-minute self-audit
- Open three car pages at random on your phone. Is the total price the most prominent number on each one?
- Compare one car on your site, a listing site and a Google vehicle ad. Same total price in all three?
- Message your own store about a specific car. Does the first reply, in email, text or chat, include that car's total price?
- Find an add-on on a car page. Is it priced separately and stated in writing as optional, and is anything already installed included in the total instead?
- Read a written payment quote end to end. Does it show the total of payments over the term and what it assumes for down payment and trade?
- Pick a car you sold last week. Is it gone from your site and your feeds, and can you pull up what its listing showed and what the first message about it said, two years from now?
Where Frontlot fits
Frontlot sites are built for California's CARS Act: total-price-first display on search pages, vehicle pages and the feeds that supply third-party listings, with the same number carried into checkout and the first written response, and designed around the FTC Act price-transparency guidance described above. That is a design position, not a guarantee about any dealership: each dealer remains responsible for its own pricing, add-ons, contracts, communications and in-store practices, and should review its setup with its own counsel. You can see the approach on our home page, and the fastest way to judge it is on your own inventory: ask for the free private preview of your store, usually ready within one business day, and walk this checklist against it. Book a demo or request the preview on the same form.