California's CARS Act puts the price in the first message about a specific vehicle

From October 1, 2026, SB 766 requires California dealers to show a vehicle's total price in their first written communication with a shopper about that vehicle, and a growing share of those first communications are written by software.

The law now covers the first message. Increasingly, software writes the first message.

Most of what has been published about SB 766 treats it as a problem for pricing pages and ads. Two of its three price triggers are about advertising, so that is fair. The third is the dealer's first written communication with a consumer that references a specific vehicle for sale, or any monetary amount or financing term. At a growing number of stores, that message is not written by a salesperson. It is a text, a web chat reply or an email sent at nine at night, written by software before anyone at the store has seen the lead.

What is the CARS Act?

The CARS Act is California's Combating Auto Retail Scams Act, created by Senate Bill 766 and added to the Civil Code at Title 1.5B.

Senator Ben Allen authored the bill, and it was signed on October 6, 2025. Its price rule requires a dealer to disclose a vehicle's total price, clearly and conspicuously, in three situations: any advertisement that references a specific vehicle, any advertisement that states a monetary amount or financing term, and the dealer's first written communication with a consumer that references a specific vehicle for sale, or any monetary amount or financing term.

The same bill also sets rules on cancellation, add-on labeling, record keeping and refunds, listed in the FAQ below. This page is about price, and mostly about the third trigger.

When does the CARS Act take effect?

The CARS Act takes effect on October 1, 2026, a little under a year after the bill was signed.

What does total price include under SB 766?

Total price includes the vehicle's full sale price, any dealer price adjustment or markup, and the cost of anything already installed on the vehicle.

It leaves out the charges listed in Vehicle Code 11713.1(e), including sales tax, vehicle registration fees, the California tire fee, the smog certificate fee, finance charges, the electronic registration or transfer charge, and the dealer document processing charge. A rebate cannot be used to reduce total price. It can be shown separately.

The definition sits at Civil Code 1784.31(j), and the disclosure requirement at 1784.41(a). On paper the definition is short. Applied to a real vehicle, it gets harder.

Why do dealers read total price differently?

Because the law defines total price by what goes into it, and the data behind a vehicle can carry several prices without saying which one fits.

Start with the inventory feed. For the same vehicle it may carry an MSRP, a selling price, and sometimes rows with no label at all. Nothing in the data says which of those numbers the dealer would stand behind.

Dealers and their attorneys read the definition differently too. In a single week, dealers gave us three different definitions of the price the law requires. Podium does not decide which of them is right. That call belongs to the dealer and the dealer's counsel.

What does the CARS Act mean for the first message a shopper gets?

The law's third trigger is the dealer's first written communication with a consumer that references a specific vehicle for sale, or any monetary amount or financing term, so the first reply a shopper gets about a car can fall under the same price requirement as the ad that brought them in.

As the law is described, that trigger is framed around what a message references - a specific vehicle for sale, a monetary amount, a financing term. If an automated reply names a car or a price, ask your counsel whether it is your first written communication for SB 766.

That makes it a different problem from a pricing page. A pricing page is one screen someone can check. First replies are written one conversation at a time, on every channel, and when software writes them, nobody at the store reads them first. The practical questions are which number your software states, where it gets that number, and whether it is the number your counsel treats as total price.

How does SB 766 compare with the FTC's September 2026 guidance?

The FTC's guidance asks that an advertised price include mandatory dealer fees, a required document fee among them, while SB 766 lets California dealers leave the document processing charge out of total price.

On September 15, 2026, the FTC published "Automobile Industry Pricing Transparency FAQs" on ftc.gov. Its position is that an advertised price must be the actual walk-in price, leaving out only charges a government agency requires the consumer to pay directly. Mandatory dealer fees belong in that price, in the FTC's words "including the full document fee if the dealer requires any consumer to pay it". The FTC's own example is a $40,000 vehicle with an $85 mandatory document fee, advertised at $40,085.

Under SB 766, the dealer document processing charge is one of the charges excluded from total price. Legal commentary, including from the law firm Kelley Drye, describes state pricing rules as applying in addition to federal all-in pricing, not instead of it. In March 2026, the FTC sent warning letters to 97 dealer groups over pricing.

We set the two side by side because your counsel will want to read them together. How they fit together for your store is a question for that counsel.

What should a California dealer check?

Start with where your first messages come from, then work back to where their price comes from. This works whether or not you use Podium.

1. List every place a shopper gets a written reply from your store: texts, web chat, email, lead-form auto-replies, social messages, automated follow-ups.

2. For each, note whether a person or software writes the first reply, and whether it can name a vehicle, a price or a payment.

3. Agree with your counsel, in writing, what total price includes at your store, including adjustments, installed items and fees.

4. Pull a sample of your inventory feed. Count the prices it sends per vehicle and note how each is labeled.

5. Ask every vendor that writes to shoppers which price field it reads, and whether you can choose it.

6. Check that your ads, website and automated replies show the same number for the same vehicle.

7. Check that no rebate is subtracted from the number shown as total price. The law allows rebates to be shown separately.

8. Ask each vendor how long it keeps sent messages and whether you can export them. The law requires ads and price communications to be kept for two years.

What has Podium built for the CARS Act?

For California locations, when a shopper asks about a specific vehicle, Podium's AI states that vehicle's price in its first response, on every written channel it answers, using the price the dealer designates.

The dealer chooses which price the AI may state, under Settings > AI > Vehicle Price. It is set once per store, not once per vehicle. Podium does not calculate the price or assemble it; the AI states the price the dealer designated.

The reason is the feed problem above. When a vehicle arrives with an MSRP, a selling price and an unlabeled row, the only party who knows which one the store stands behind is the store.

One detail from the build. The Vehicle Price screen shows the dealer one of their own vehicles so they can compare the prices on file. It deliberately picks a vehicle that has more than one price. A vehicle with a lone MSRP gave dealers nothing to choose between.

For California locations, the policy makes it consistent. A dealer who would rather the AI not quote prices can have AI price quoting switched off, and the AI then points the shopper to the vehicle's listing.

None of this decides what your total price is. It lets the store choose the number the AI states.

Already a Podium customer?

If you have California locations, the price your AI states in a first response is the one chosen under Settings > AI > Vehicle Price, set once per store. Review that choice against your counsel's reading of total price. Your CSM can walk through the screen with you, including the option to switch AI price quoting off.

Talk it through with us

If you want to talk through how first messages work at your store, which channels, which software, where the price comes from, our auto team is glad to talk with you, whether or not you use Podium. Bring your counsel's definition of total price if you have one. We will show you what our AI does with a price. We will not tell you what your price should be. Talk to a specialist