Dealer addendum compliance checklist (2026)

Short version: a compliant-looking addendum identifies the vehicle exactly, lists every dealer-added product with its own price, keeps MSRP separate, shows a total the shopper can actually pay, says plainly that it's the dealer's document and not a factory sticker, states what the price excludes, and sits beside the Monroney label without covering it. Then you keep a record of what you printed and review the whole setup on a schedule. The checklist below covers each item, with the federal and state sources behind it.

Why a checklist, and why now

No single federal regulation governs dealer addendums. The FTC's CARS Rule, which would have, was formally withdrawn in February 2026 after a federal appeals court vacated it. What applies instead is a mix:

• Section 5 of the FTC Act, which declares unfair or deceptive acts or practices unlawful
• The FTC's September 2026 price transparency FAQs for auto dealers
• The Monroney label law for new vehicles, at 15 U.S.C. §§ 1232–1233
• The FTC Used Car Rule for used vehicles
• State law, such as California's CARS Act (SB 766), effective October 1, 2026, according to the California DMV

Because the rules come from several places, a checklist is the easiest way to make sure every sticker covers the basics. For background on the 2026 changes, read dealer addendum disclosures in 2026.

1. Vehicle identification

• Year, make, model, and trim
• VIN, matching the Monroney label or Buyers Guide exactly
• Stock number and exterior color

The Monroney label itself must show the make, model, and identification number under 15 U.S.C. § 1232. Your addendum's VIN should match it character for character. Pulling the vehicle from inventory instead of retyping is the most reliable way to get there.

2. Itemized products with prices

• Each dealer-added product or service on its own line
• Each line with its own price
• Only products actually on, or included with, the vehicle
• No factory equipment repeated as a dealer add-on

The FTC's FAQs say dealers "cannot suggest an add-on is required when it is in fact optional," can't misstate an option's cost, and can't charge for options the consumer didn't agree to. California's CARS Act also prohibits charging for add-ons that won't benefit the consumer, according to the bill author's announcement. For setting the prices themselves, see how to price dealer add-ons.

3. MSRP shown separately

On new vehicles, the manufacturer's suggested retail price comes from the Monroney label. Show it on its own line, apart from dealer add-ons, so a shopper can see where the factory price ends and the dealer's additions begin. The FTC's FAQs allow MSRP in ads as long as the actual price is more prominent. The Monroney vs. addendum guide explains the split.

4. Total or asking price

• Show the total of dealer-added products
• Show the resulting price, with the math visible
• Make sure it matches how you advertise the vehicle

The FTC's March 2026 warning letters to 97 dealership groups said advertised prices must include all mandatory fees. They listed "requiring consumers to buy additional items not reflected in the advertised price" as an illegal practice. If the addendum total is higher than the price online, find out why before the car goes on the lot.

5. Dealer-added, not-factory disclosure

The addendum should say clearly that it was added by the dealership and isn't a factory sticker. This keeps shoppers from confusing it with the Monroney label and makes it clear who's responsible for its contents. Use the same wording on every vehicle.

6. Fees and taxes exclusions

• State what the price doesn't include, such as government fees and taxes
• Use the same exclusions wording on every vehicle

Check this line against your advertising. The FTC's FAQs say dealers may exclude only government-required charges from an advertised price, and that the advertised price must include any mandatory fee, "including the full document fee." If your store charges a mandatory doc fee, ask counsel how your ads and your addendum's exclusions line should work together.

7. Placement beside the Monroney label

• New vehicles: Place the addendum beside the Monroney label, never over any part of it. Federal law, at 15 U.S.C. § 1233, makes it an offense to willfully remove, alter, or make illegible the label before the vehicle is delivered to the buyer.
• Used vehicles: Keep the Buyers Guide displayed so that "both sides are readily readable," as 16 CFR 455.2 requires, and don't cover it. See addendum stickers for used cars.

8. Record-keeping

Keep a record of every addendum you print: which vehicle, which products and prices, and when. Keep reprints too, so you can show what changed.

Some states set explicit retention periods. The California DMV's CARS Act implementation notice says dealers must retain compliance documentation, including add-on disclosures and consents, for two years. Check the requirements in every state where you operate.

9. Periodic review

• Review each store's product list and prices on a set schedule
• Check that disclosure and exclusions wording hasn't drifted
• Spot-check stickers on the lot against your records
• Re-read federal guidance and state law for changes

The FTC said in its FAQs that it will keep monitoring the market, and states are adding their own rules. A quarterly review is a reasonable habit.

Printable checklist

Use this table for a vehicle-by-vehicle spot check or a monthly audit.

A checklist catches mistakes. It doesn't replace legal review. Have counsel sign off on your disclosure wording and pricing approach before you roll it out.

FAQ

Is a dealer addendum legally required?

Federal law requires the Monroney label on new vehicles and the Buyers Guide on used vehicles. Neither requires a separate dealer addendum. But if you add products and charge for them, the FTC's guidance on optional items and advertised prices applies, and the addendum is where shoppers see those charges.

Did anything replace the CARS Rule?

No federal rule replaced it. The FTC continues to enforce Section 5 of the FTC Act and published price transparency FAQs in September 2026. California passed its own CARS Act, effective October 1, 2026.

How long should we keep addendum records?

It depends on the state. California's DMV says two years for CARS Act compliance documentation. Ask counsel what applies to each of your rooftops, and keep records at least that long.

Can we use the same checklist for every store?

Use the same core checklist everywhere, then add a line for each state's specific rules. Item 14 in the table is there for that reason.

How QP Addendums helps

QP Addendums builds several checklist items into every sticker. Each dealer-added product prints on its own line with its price. MSRP is shown separately. A fixed disclosure says the addendum was added by the dealer, not the manufacturer, and a standard exclusions line follows it. Nobody edits that wording at print time. Every print is saved with its reprints, so record-keeping happens as you work. Group Admin, Store Admin, and Print User roles, with admin-only price changes, help with periodic review. It doesn't guarantee compliance. You still own placement, state requirements, and legal sign-off. See how the controls work, download free sample templates, explore features, or view pricing, with plans from $99/month.