The FTC Used Car Rule and the Buyers Guide
The federal rule that governs every used vehicle on your lot — who it covers, how the Buyers Guide has to be posted, which version you must use, and what has to be in the customer's hand at the sale.
Key takeaways
- The Used Car Rule covers dealers who sell or offer more than five used vehicles in a 12-month period, in every state except Maine and Wisconsin
- A Buyers Guide must be posted before you display a vehicle or let a customer inspect it — both sides visible, in plain view, not in the glove box
- The Guide comes in two versions: 'As Is - No Dealer Warranty' and 'Implied Warranties Only'; which one you may use depends on your state
- If you conduct the transaction in Spanish, you must post a Spanish-language Buyers Guide on the vehicle
- You must hand the buyer the Guide reflecting all final changes at the sale; FTC penalties run up to $53,088 per violation
Disclaimer: This page is a general introduction to the FTC Used Car Rule for dealers. It is not legal advice. State law adds requirements on top of the federal rule and varies considerably. Consult the FTC's Dealer's Guide to the Used Car Rule, your state attorney general or dealer board, and counsel licensed in your state.
Quick Answer
The FTC Used Car Rule requires dealers who sell, or offer for sale, more than five used vehicles in a 12-month period to post a Buyers Guide on every used vehicle before it is displayed for sale or made available for a customer to inspect. The Guide states whether the vehicle is being sold "As Is - No Dealer Warranty" or with a warranty, and if with a warranty, what it covers and what percentage of repair costs the dealer will pay. It must be posted so both sides are visible and in plain view — hanging from a mirror, under a wiper, or on a side window, never in the glove box or trunk. The Rule applies in every state except Maine and Wisconsin, which have their own equivalent requirements. At the sale, the buyer must receive the Guide reflecting all final changes. Violations carry FTC penalties of up to $53,088 per violation.
Who has to comply
The threshold is low enough that it catches nearly every operating dealership: more than five used vehicles sold or offered for sale in any 12-month period. Note that "offered for sale" counts — the obligation attaches to inventory you display, not only to units you actually retail.
Who is exempt
- Banks and financial institutions
- Businesses selling vehicles to their own employees
- Lessors selling a leased vehicle to the lessee, an employee of the lessee, or a buyer found by the lessee
Where it applies
The Rule applies in every state except Maine and Wisconsin. Those two are exempt because they already require dealers to post comparable disclosures under state regulation — so if you operate there, you are not free of the obligation, you are meeting a different version of it. The Rule also applies in the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, and American Samoa.
What counts as a "used vehicle"
Broader than most people assume. Previously titled or not, any vehicle driven for purposes other than moving or test driving is a used vehicle for these purposes — which sweeps in demonstrators and program cars along with ordinary used inventory, as well as light-duty vans and light-duty trucks, provided the vehicle has:
- a gross vehicle weight rating (GVWR) under 8,500 pounds;
- a curb weight under 6,000 pounds; and
- a frontal area under 46 square feet.
Three things are excepted: motorcycles; vehicles sold for scrap or parts, where the dealer submits title documents to the appropriate state authority and obtains a salvage certification; and agricultural equipment.
Consignment and auctions
You must display a Buyers Guide on used vehicles for sale on your lot through consignment, power of attorney, or other agreement — the unit being someone else's property does not move the obligation. At public auctions, both the dealer and the auction company must comply. The Rule does not apply at auctions closed to consumers, which is why wholesale lanes look different from your retail line.
Posting the Buyers Guide correctly
The timing requirement is the one most often missed. You must post the Guide before you display a vehicle for sale or let a customer inspect it for the purpose of buying it — and explicitly, even if the car is not fully prepared for delivery. A unit sitting on the front line waiting on recon is a unit that needs a Guide on it.
Where it can go
The Guide must be displayed prominently and conspicuously, in plain view, with both sides visible. Acceptable placements:
- Hanging from the rear-view mirror inside the vehicle
- Hanging from a side-view mirror outside the vehicle
- Placed under a windshield wiper
- Attached to a side window
A Guide in the glove compartment, trunk, or under a seat is not compliant — it is not in plain sight. You may remove the Guide for a test drive, but it must go back as soon as the test drive is over.
What goes on it
At the top of the Guide: the vehicle make, model, model year, and VIN. A dealer stock number is optional. On the back: your dealership name and address, plus the name (or position) and telephone number of the person a consumer should contact with complaints.
The Guide itself also carries standard consumer-facing language telling the buyer about the vehicle's major mechanical and electrical systems and common problems to watch for, that oral promises are difficult to enforce, to get all promises in writing, to have the vehicle inspected by an independent mechanic before buying, to obtain a vehicle history report and check for safety recalls, and to keep the Guide after the sale.
Which version: As Is or Implied Warranties Only
The Buyers Guide comes in two versions, and which one you are permitted to use is a question of state law, not preference. Warranty is not a third version — it is a box you check on whichever version applies.
"As Is - No Dealer Warranty"
Use this version — and check the box next to that heading — if your state allows it and you are choosing to offer no warranty at all, written or implied. Not every state permits a dealer to disclaim implied warranties on a retail used vehicle sale, so this option simply is not available everywhere.
"Implied Warranties Only"
In states that limit or prohibit the elimination of implied warranties, you must use this version, and check the "Implied Warranties Only" box when you are not offering a written warranty. This is the practical default in a meaningful number of states, and using the As Is form there is a compliance failure regardless of what the customer agreed to.
"Warranty"
If you are selling with an express warranty, check the Warranty box and complete that section — including which systems are covered, the duration, and what percentage of repair costs you will pay. Warranties required by state law are disclosed here as well.
If you offer a written warranty, or the manufacturer's warranty still applies, you also pick up obligations under the Magnuson-Moss Warranty Act and the FTC's Warranty Disclosure Rule. One consequence catches dealers out: Magnuson-Moss prohibits you from eliminating implied warranties when you provide a written warranty. You cannot sell with a written warranty and also disclaim the implied ones.
Spanish-language sales, and what the buyer gets
The Spanish requirement
If you conduct a used car transaction in Spanish, you must post a Spanish-language Buyers Guide on the vehicle before you display or offer it for sale. Note the sequencing problem this creates in practice: the obligation attaches at display, but you often do not know the language of the transaction until the customer is standing in front of the car. Stores that sell meaningfully in Spanish generally solve it by stocking both versions and training the lot staff to swap the Guide when a Spanish-language deal begins, rather than treating it as an F&I-desk step.
At the sale
You must give the buyer the original or a copy of the vehicle's Buyers Guide at the sale, reflecting all final changes. If the Guide has been amended during negotiation — a warranty added, a term changed — the copy the customer leaves with has to be the amended one, not the version that was hanging in the window that morning. If you include a signature line on your Guides, make sure the buyer signs the Guide that reflects those final changes.
Penalties
Dealers who violate the Used Car Rule may face FTC penalties of up to $53,088 per violation (the figure in force as of August 2026, applying to penalties assessed after January 17, 2025). That amount is adjusted for inflation periodically, so check the current figure rather than relying on a number in an article. Many states also have their own laws and regulations covering the same ground, which means a single non-compliant unit can create exposure at both levels.
How this differs from Canada
Dealers operating on both sides of the border, or reading Canadian material, should know that the two systems put the same information in very different places.
- Where the disclosure lives. The American model is a posted form on the vehicle, required before display. The Canadian model is disclosure in the contract: Ontario's Regulation 333/08 requires a long list of history and condition facts to appear in writing on the bill of sale, with no window-sticker equivalent.
- What "as is" means. In the US, "As Is - No Dealer Warranty" is a warranty position, available only where state law permits it. In Ontario, "as-is" is a prescribed contract statement in 12-point bold that the purchaser must initial — and a dealer may not sell as-is to a retail customer at all if a current safety standards certificate has been issued for the vehicle.
- Vehicle history. The FTC Buyers Guide tells the buyer to go get a vehicle history report. Ontario instead obliges the dealer to disclose specific history facts directly — accident damage over a dollar threshold, prior taxi or rental use, out-of-province registration, brand status.
- Who enforces. A federal regulator with per-violation civil penalties, layered over state law, versus a provincial delegated authority administering a provincial statute.
If you sell in Canada as well, our guide to OMVIC mandatory disclosures covers the Ontario obligations in the same detail this page covers the federal ones.
Making compliance survive the lot
Almost nothing about this rule is intellectually difficult. The failures are operational, and they cluster in the same few places.
A unit arrives, goes through recon, and reaches the front line before anyone prints a Guide — but the Rule attached the moment it was available for a customer to inspect, prepared or not. A Guide blows off a windshield and nobody notices for a week. A vehicle comes back from a test drive and the Guide stays on the sales desk. A warranty position changes during negotiation and the window form is never reprinted, so the copy handed to the buyer contradicts the deal.
Each of those is a task with no owner and no check. The dealerships that stay clean treat "Buyers Guide posted, correct version, both sides visible" as a step in the same workflow that moves a vehicle to the front line — verified once when the unit is merchandised and re-verified whenever its warranty position or price changes — rather than as something the lot porter is assumed to have handled.
READY HUB tracks the work on each vehicle with clear ownership and status, visible across departments, so a step like this is something a store can confirm was done rather than assume.
Frequently asked questions
Who has to comply with the FTC Used Car Rule?
Dealers who sell, or offer for sale, more than five used vehicles in a 12-month period. Banks and financial institutions are exempt, as are businesses selling vehicles to their own employees and lessors selling a leased vehicle to the lessee, an employee of the lessee, or a buyer the lessee found.
Which states does the Used Car Rule apply in?
Every state except Maine and Wisconsin, which are exempt because they have their own regulations requiring comparable posted disclosures. The Rule also applies in the District of Columbia, Puerto Rico, Guam, the U.S. Virgin Islands, and American Samoa.
When does the Buyers Guide have to be posted?
Before you display the vehicle for sale or let a customer inspect it for the purpose of buying it — explicitly including vehicles that are not yet fully prepared for delivery. It also applies to consignment units on your lot and to vehicles at public auctions.
Where on the vehicle can the Buyers Guide be displayed?
The FTC identifies four acceptable placements: hanging from the rear-view mirror inside the vehicle, hanging from a side-view mirror outside it, under a windshield wiper, or attached to a side window. In every case it must be in plain view with both sides visible. Inside the glove compartment, in the trunk, or under a seat is not compliant. You may remove it for a test drive but must replace it immediately afterward.
What is the difference between "As Is" and "Implied Warranties Only"?
They are the two versions of the Buyers Guide. "As Is - No Dealer Warranty" may be used only where state law allows a dealer to offer no warranty at all, written or implied. In states that limit or prohibit eliminating implied warranties, you must use the "Implied Warranties Only" version instead when you are not offering a written warranty.
Do I need a Spanish Buyers Guide?
Yes, if you conduct the used car transaction in Spanish. In that case you must post a Spanish-language Buyers Guide on the vehicle before you display or offer it for sale. The Guide's standard text also tells consumers they can ask for a Spanish version when the sale is conducted in Spanish.
What are the penalties for violating the Used Car Rule?
Up to $53,088 per violation in FTC enforcement actions. The amount is adjusted for inflation, so confirm the current figure with the FTC. Many states have parallel laws, so the same conduct can create state-level exposure as well.
Can I disclaim implied warranties if I offer a written warranty?
No. Under the Magnuson-Moss Warranty Act, providing a written warranty prohibits you from eliminating implied warranties. If you offer a written warranty or the manufacturer's warranty still applies, you also take on obligations under Magnuson-Moss and the FTC's Warranty Disclosure Rule.
The bottom line
The Used Car Rule is the one federal requirement that touches every used vehicle you put out, and it is unusually literal: a specific form, in a specific place, in a specific version, before a specific moment. There is very little interpretive room, which cuts both ways — it is easy to comply with and easy to be plainly in violation of.
Treat the Buyers Guide as part of merchandising a unit rather than as paperwork, verify the version against your state's position on implied warranties, reprint whenever the warranty position changes, and make sure the copy the customer leaves with matches the deal that was actually done.
Related reading
Compliance steps you can confirm, not assume
READY HUB tracks the work on every vehicle with clear ownership and status, visible across Sales, Parts, Service, and F&I — so a step like a posted Buyers Guide is something your store can verify was done.