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California Regulatory Explainer

California SB 766 (CARS Act), ExplainedWhat Changes for California Dealers on October 1, 2026

Quick answer
California SB 766 — the Combating Auto Retail Scams (CARS) Act of California — was signed into law in 2025 and takes effect October 1, 2026. It requires California auto dealers to advertise honest out-the-door prices, itemize and separately consent each add-on product, ban junk fees, and keep records for two years. Importantly, SB 766 does NOT change the §11710 surety bond — $50,000 / $10,000 tiers remain in place.

For the current bond product, see the California motor vehicle dealer bond page. For a step-by-step pre-October checklist, see our CARS Act compliance checklist.

TL;DR
  • What: California's state-level CARS Act — honest pricing, itemized add-on consent, junk-fee ban, 2-year recordkeeping.
  • When: Effective October 1, 2026.
  • Who: Every licensed California retail motor vehicle dealer — new, used, and motorcycle.
  • Bond: This does NOT change the bond. $50K / $10K tiers and OL 25 form are unchanged.
  • Risk: Civil penalties and possible license revocation. BAR + CA DMV enforce.

Background: What SB 766 Is and Why California Passed It

SB 766 — formally the Combating Auto Retail Scams (CARS) Act of California — is California's 2025 consumer-protection statute targeting deceptive auto-retail practices. It was signed into law by Governor Newsom and is scheduled to begin enforcement on October 1, 2026. The bill grew out of years of complaints to the Bureau of Automotive Repair, the California DMV, and the Attorney General about hidden fees, surprise add-ons, and advertised prices that bore no relationship to what buyers actually paid.

SB 766 also runs in parallel with the federal FTC CARS Rule, which was struck down on procedural grounds by the 5th Circuit Court of Appeals in 2025. Rather than wait for federal re-promulgation, California adopted a state-level version with similar consumer protections. California can enforce SB 766 regardless of what happens to the federal rule.

The act is about how dealers advertise, disclose, and contract — not about who can hold a dealer license. The licensing framework, classification system, education requirements, and surety bond under the §11710 statutory framework all remain in place exactly as they were before SB 766, as verified by our NV-licensed surety producer.

Timeline: Signing to Enforcement

Dealers have a meaningful runway between the 2025 signing and the October 1, 2026 effective date. Here is how the runway breaks down — see also our biennial OL 45 renewal walkthrough to align CARS readiness with the next cycle.

2025: Signing

SB 766 passes the California Legislature and is signed into law by Governor Newsom. Effective date deferred to allow industry preparation.

Now – Sept 2026: Prep

Dealers update advertising, build add-on consent flows, install DMS updates, and train staff. BAR and CA DMV publish implementing guidance.

October 1, 2026: Live

Enforcement begins. All California retail dealer activity must comply with SB 766. Expect a grace-period educational posture from regulators through year-end.

What SB 766 Changes

Six concrete things change for California dealers on October 1, 2026 — including those operating in the San Diego & Otay Mesa cross-border market. Each one is a real workflow change, not just a paperwork tweak.

Pricing Transparency — The "Offering Price"

Dealers must clearly display the full out-the-door offering price — every dollar a buyer would actually pay minus only government taxes and government-imposed fees. The price must appear in advertisements and at the point of sale, and it cannot be conditioned on a trade-in, manufacturer rebate, or financing arrangement unless the same price is available to any buyer.

Junk Fee Prohibition

Add-on fees that do not provide a real, measurable benefit to the buyer are prohibited. So are deceptive descriptions of optional add-ons and any bait-and-switch tactic that swaps the advertised vehicle, price, or financing terms once the customer is in the dealership.

Add-On Product Disclosure & Consent

Every optional product — GAP, extended service contracts, paint protection, tire-and-wheel, theft etching, nitrogen fills, and the rest — must be itemized with its price and a plain-English explanation. The buyer must give affirmative, separate consent for each add-on, distinct from the main purchase contract.

Advertising Compliance

Every advertised price has to be a price an ordinary buyer could actually obtain without trade-in, financing, or eligibility tricks. "Down from" claims, conditional discounts, and fine-print disclaimers that swallow the headline are squarely targeted by SB 766.

Recordkeeping

Dealers must retain documentation of every required disclosure and every separate add-on consent for at least 2 years. Records must be producible on request by BAR or the California DMV during routine inspection or in response to a consumer complaint.

Enforcement & Penalties

The Bureau of Automotive Repair and the California DMV share enforcement authority. Civil penalties are available, and serious or repeat violations can support license suspension or revocation. Consumers may also have private remedies for deceptive pricing under California consumer-protection law.

What SB 766 Does NOT Change

This is the section every California dealer needs to read carefully. SB 766 reshapes the buyer-facing pricing and disclosure experience. It does NOT change the underlying licensing and bonding framework. In particular, this does NOT change the bond.

§11710 Surety Bond Amount

$50,000 for most new and used motor vehicle dealers; $10,000 for low-volume used dealers (25 or fewer retail sales annually). UNCHANGED by SB 766.

OL 25 Bond Form

The California DMV OL 25 bond form is unchanged. Existing bonds remain in force; renewals continue on the same form.

License Classes

New, used, motorcycle, wholesale, autobroker, and lessor-retailer classifications are unchanged.

Pre-Licensing Education

The required dealer pre-licensing class hours are unchanged, including the curriculum administered by the California DMV Occupational Licensing program.

Continuing Education (CE)

Annual CE requirements for renewing California dealer licenses are unchanged by SB 766.

Application & Renewal Process

The standard CA DMV dealer application packet, fees, and renewal schedule are unchanged. SB 766 layers on top of the existing licensing system rather than replacing any part of it.

Need to confirm your bond is still in good standing? The current product details and renewal mechanics live on the California motor vehicle dealer bond page, and the California dealer bond guide walks through every step of the bond process.

Federal Context: The FTC CARS Rule

The federal Combating Auto Retail Scams Rule was finalized by the Federal Trade Commission and then challenged in court. In 2025, the 5th Circuit Court of Appeals struck the rule down on procedural grounds — meaning the FTC may re-propose it in the future, but it is not currently enforceable nationally.

California did not wait. SB 766 is California's state-level adoption of very similar protections — honest out-the-door pricing, itemized add-on consent, a ban on junk fees, and recordkeeping requirements. The state has clear authority to enforce SB 766 even though the federal rule is in limbo.

The practical effect for California dealers: do not assume the federal court decision relieves you of any California obligation. SB 766 is independent of the FTC rule and takes effect on October 1, 2026 regardless.

Federal vs. California — Side by Side

FTC CARS Rule (Federal)
Finalized; struck down 2025 by the 5th Circuit on procedural grounds. Not currently enforceable nationally.
California SB 766
Signed 2025. Effective October 1, 2026. Enforceable by BAR and California DMV. Covers California retail dealer activity regardless of federal status.
Overlap
Both rules cover honest pricing, itemized add-on consent, junk-fee bans, and recordkeeping. Dealers who built compliance for the federal rule have a head start on SB 766.

Bond Renewal Coming Up Before October 1, 2026?

SB 766 does not change your §11710 bond, but your renewal still needs to happen on time. Same-day approval on the OL 25 form, $50K and $10K options, A-rated surety.

Compliance Checklist: What to Do Before October 1, 2026

Ten concrete steps every California dealer should work through between now and the effective date — covering retail dealers across the San Jose dealer corridor and the Fresno Central Valley dealer market. None of these are optional — they map directly onto specific SB 766 obligations.

  1. 1
    Audit every current advertisement (website, social, TV, radio, third-party listings) to confirm the offering price is shown and matches reality.
  2. 2
    Map every optional add-on product your store sells. Confirm each one has a real, measurable buyer benefit and a plain-English description.
  3. 3
    Build or buy an itemized add-on consent form. Each line item must capture a separate affirmative buyer signature.
  4. 4
    Talk to your DMS vendor about the SB 766 update path and target install date.
  5. 5
    Update your buyer disclosure packet to include the offering-price summary at the front.
  6. 6
    Build a 2-year retention workflow for all SB 766 disclosures and consents — cloud or paper, but indexed and producible.
  7. 7
    Schedule a one-time SB 766 training session for sales, F&I, and management before October 1, 2026.
  8. 8
    Review pay plans to ensure F&I incentives do not reward conduct SB 766 prohibits.
  9. 9
    Designate a compliance owner — usually a GM, controller, or compliance officer — accountable for SB 766 readiness.
  10. 10
    Document everything: a written compliance file is the cheapest defense against an enforcement letter.

For a printable version with deadline columns and assigned-owner fields, see the CARS Act compliance checklist page.

Penalties for SB 766 Violations

SB 766 is enforceable through multiple channels — and violations can trigger claims against the California dealer bond under §11711. Penalties are real but proportional — single, isolated paperwork misses are handled differently than systematic deceptive-pricing practices.

Civil Penalties

BAR and the California DMV can assess civil penalties. The exact schedule will be published by the regulator ahead of October 1, 2026.

License Action

Serious or repeat violations can support license suspension or revocation under existing California Vehicle Code authority.

Private Remedies

Consumers may also pursue private remedies under California consumer-protection statutes for deceptive pricing or unauthorized add-ons.

DMS & Vendor Implications

Most California dealers will not build SB 766 compliance from scratch — their DMS, F&I menu provider, advertising vendor, and website CMS will each ship updates. Plan the integration now.

DMS Updates

CDK, Reynolds, DealerSocket, VinSolutions, Dealertrack, and others are releasing California-specific SB 766 modules to capture itemized add-on disclosure, separate consent signatures, and the 2-year retention requirement.

Advertising Vendors

Website CMS, third-party listing platforms (AutoTrader, Cars.com, CarGurus), and paid-media agencies need to surface the offering price prominently and remove any conditional-pricing language SB 766 prohibits.

F&I Menu Providers

Menu products (MaximTrak, F&I Express, Darwin, StoneEagle) need to support line-by-line add-on consent capture with separate signatures distinct from the main retail installment contract.

Training Vendors

Most California dealer associations and compliance training firms have SB 766 courses available. Budget for a one-time training session plus refreshers in ongoing sales meetings.

Internal Training: What Your Staff Needs to Know

SB 766 fails or succeeds at the desk. A perfectly configured DMS does not help if the salesperson, sales manager, or F&I manager does not understand the rules. Build a one-time training session before October 1, 2026 and refresh it in monthly sales meetings.

Sales Staff

How the offering price is calculated, what cannot be added on the back end, and how to talk about the price without violating the advertising rules.

F&I Managers

Itemized add-on presentation, separate consent capture, how to describe each product accurately, and how to document that the customer was offered, not pressured into, every add-on.

Management

Compliance ownership, recordkeeping audits, advertising approval workflow, and handling regulator inquiries when they arrive.

California CARS Act: Common Questions

Direct, fact-checked answers about SB 766, the effective date, and what dealers actually owe.

What is California SB 766 in plain English?

SB 766 is the Combating Auto Retail Scams (CARS) Act of California. It is a consumer-protection law signed by Governor Newsom in 2025 that requires California auto dealers to advertise honest out-the-door prices, itemize and separately obtain consent for every add-on product, ban add-on fees that provide no buyer benefit, and keep documentation of those disclosures. It does not change dealer licensing classes, pre-licensing education, or the §11710 surety bond.

When does the California CARS Act take effect?

SB 766 takes effect October 1, 2026. Dealers have a multi-month window between signing in 2025 and enforcement in October 2026 to update advertising, point-of-sale forms, dealer management system (DMS) workflows, and staff training. The Bureau of Automotive Repair (BAR) and California DMV are expected to issue grace-period guidance through the end of 2026.

Does SB 766 change the California §11710 dealer bond amount?

No. SB 766 does NOT change the California Vehicle Code §11710 dealer surety bond. The $50,000 bond for most new and used motor vehicle dealers and the $10,000 bond for smaller-volume used dealers (25 or fewer retail sales annually) remain unchanged. The OL 25 bond form is unchanged. Licensing classes, pre-licensing education, and continuing education requirements are also unchanged.

Who has to comply with SB 766?

Every licensed California motor vehicle dealer that sells vehicles at retail to consumers — new-car franchised dealers, independent used dealers, and motorcycle dealers. Wholesale-only dealers who never sell to retail consumers fall outside the consumer-facing pricing rules but should still review advertising and recordkeeping requirements. Out-of-state dealers advertising to California consumers can also be reached by SB 766 enforcement.

How is SB 766 different from the federal FTC CARS Rule?

The federal FTC Combating Auto Retail Scams Rule was struck down by the 5th Circuit Court of Appeals in 2025 on procedural grounds. California passed SB 766 as a state-level adoption of similar protections regardless of the federal outcome. The state can enforce SB 766 even though the federal rule is in limbo. The two rules cover similar ground — junk-fee bans, add-on consent, and honest pricing — but SB 766 is the binding rule for California dealers.

What are the penalties for violating SB 766?

Civil penalties are available to BAR and the California DMV, and serious or repeat violations can support license suspension or revocation. Consumers may also have private remedies under California consumer-protection law for deceptive pricing. The exact penalty schedule will be published by the regulator, but the law is designed to be enforceable through both administrative action and civil litigation.

Do I need to change my DMS or paperwork before October 1, 2026?

Yes. Most major DMS vendors (CDK, Reynolds, DealerSocket, VinSolutions, and others) are releasing California-specific updates for SB 766 to capture itemized add-on disclosures, separate consent capture, offering-price displays, and 2-year recordkeeping. Talk to your DMS account manager now. If you use paper forms, you will need new add-on consent forms and an updated buyer disclosure packet.

Does SB 766 require new staff training?

The law does not name a specific course, but compliance in practice requires that every sales manager, finance manager, and salesperson understand the new offering-price rules, the add-on consent process, and the advertising prohibitions. Most dealers will run a one-time training session before October 1, 2026 and refresh it during ongoing sales meetings.

What is an "offering price" under SB 766?

The offering price is the full out-the-door price a customer can actually purchase the vehicle for, excluding only government taxes and government-imposed fees. It includes the vehicle price, dealer-added accessories already on the unit, and any mandatory dealer fees. It cannot be reduced by a trade-in, manufacturer rebate, or financing tactic unless the same price is available to any buyer. Advertisements must display this price prominently.

Where can I read SB 766 itself?

The full text and legislative history are at the California Legislative Information site (leginfo.legislature.ca.gov). BAR and the California DMV will publish implementing guidance ahead of the October 1, 2026 effective date. We link both at the bottom of this page.

Eric Drummond, Licensed Surety Producer
Reviewed by
Eric Drummond, Licensed Surety Producer

All content is researched from official state and federal sources (.gov) and verified before publication. BuySuretyBonds.com works with Treasury-certified, A-minimum rated surety carriers serving all 50 states.

SB 766 Does Not Change Your Bond. Renewals Still Happen on Schedule.

The §11710 bond stays at $50,000 / $10,000. The OL 25 form is unchanged. We issue same-day on A-rated paper, DMV-ready for upload.

§11710 Compliant ($50K / $10K)
OL 25 Form — DMV-Ready
Unaffected by SB 766