Car dealership advertising laws for video: price, payment and APR rules

Updated 25 October 2026 · Written by Reyansh Juneja and Naman Dhiman, the co-founders of SOVE7GN, who run the campaigns and review the clips

Car dealership advertising laws in the US come in three layers: the FTC Act bans deceptive ads, Regulation Z and Regulation M set what a credit or lease ad must disclose once it mentions certain terms, and state law adds its own rules, such as California's CARS Act, in force since 1 October 2026. A payment said out loud in a reel counts the same as one printed in a newspaper, because Regulation Z defines an advertisement as "a commercial message in any medium" that promotes a credit transaction.

Which federal rules apply to a dealer's video ads?

Why 226 and not 1026: dealers predominantly engaged in selling and servicing vehicles are excluded from the Consumer Financial Protection Bureau's authority, with exceptions such as dealers who finance customers directly and keep the contracts (12 U.S.C. 5519). The Federal Reserve's version of Regulation Z (part 226) is the one usually cited for those dealers. The CFPB's version (12 CFR 1026.24) uses the same four trigger terms, so the practical advice is the same either way.

What are the Regulation Z trigger terms?

From 12 CFR 226.24(c) and (d). An ad may use an example of typical credit terms. A clip that says "only 72 months" is a trigger on its own, even with no payment amount, because it states the period of repayment.

Regulation Z has a shortcut for television and radio: state the APR and give a toll-free number people can call for the rest (226.24(g)). The text speaks of television and radio advertisements, and we found nothing in it that says a reel or a TikTok counts as either, so we would not rely on that shortcut for social video.

What triggers the lease rules in Regulation M?

Stating the amount of any payment, or a capitalized cost reduction or other payment due at signing, triggers these disclosures: that the deal is a lease; the total due at or before signing or delivery; the number, amounts and due dates of scheduled payments; whether a security deposit is required; and that an extra charge may be imposed at the end of the lease (12 CFR 213.7(d)). A lease ad may only advertise terms the dealer "usually and customarily" offers or will offer (213.7(a)).

The broadcast shortcut in 213.7(f) is narrower than Regulation Z's: some items must still be stated in the ad, and the toll-free number has to stay live for at least ten days. The same caution about reels applies.

Is the FTC CARS Rule still in effect?

No. The Fifth Circuit granted the dealer associations' petition and vacated the CARS Rule on 27 January 2025, because the FTC skipped an advance notice of proposed rulemaking (NADA v. FTC, No. 24-60013). Section 5 and the regulations above still apply.

What do state rules add? California as the example

California now has its own CARS Act (SB 766), effective 1 October 2026 for licensed dealers selling or leasing light-duty vehicles under 10,000 lbs, according to the California DMV's implementation notice. For video, three parts matter:

• Total price in the ad. Dealers must clearly and conspicuously disclose the total price in any advertisement that references a specific vehicle or financing terms.
• No misrepresenting pricing and availability, financing or lease terms, or add-on products.
• Keep the ads. Dealers must retain compliance records, including advertisements, for two years. Save a copy of every clip as posted, with its caption and date.

California's Vehicle Code already required an ad for a specific vehicle to identify it by model, model-year and either its license plate number or the distinguishing part of the VIN, and a dealer must sell at the advertised total price while the vehicle is unsold unless the ad says the price is time-limited (Vehicle Code 11713.1). A walkaround clip with a price on it is an ad for a specific vehicle, so the stock number on screen is not enough: add the VIN digits or plate.

Other states have their own dealer ad rules; New Jersey's is summarized on our luxury car dealer page. Canadian and UK dealers answer to provincial regulators and the FCA. General information, not legal advice. Checked October 2026.

A checklist for anything said out loud in a reel

1. Did anyone say a monthly payment, down payment, term length or finance charge? If yes, the full Regulation Z disclosures go in the clip, or the line comes out.
2. Did anyone say a lease payment or an amount due at signing? If yes, the Regulation M disclosures go in, or the line comes out.
3. Was a rate mentioned? It must be called an APR.
4. Is the price on screen the price you will actually sell at, with only the fees your state allows left out?
5. In California: does the clip show the total price, and does it identify the vehicle by VIN digits or plate?
6. Does a customer praise the car or the deal on camera? Get written consent, and follow the FTC rules on endorsements in clips.
7. Are condition and history claims ones you can document?
8. Is the car still for sale, and is a dated copy of the clip and caption saved?

Our clip map for one walkaround, with the lines that trigger these rules flagged, is on car dealership reel ideas. If you want clips cut with this checklist already applied, book a 30-minute call, or read our page for founder-led businesses.

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