New Utah Dealership Advertising Rules Explained
What Utah dealers need to know about prices, promotions, dealership signs, and sales statements that goes into effect December 2nd.
A vehicle’s advertised price should give a customer a clear understanding of what the dealer will charge. That principle is central to Utah’s revised vehicle advertising rule, R877-23V-7.
The revised language addresses mandatory dealer fees, installed products, conditional rebates, vehicle availability, and promotional claims. It also makes clear that advertising reaches beyond a dealership’s website or paid advertisements. Window stickers, showroom signs, banners, price tags, and spoken statements about vehicles offered for sale or lease all fall within the rule’s broad definition.
For dealers, the practical task is to make sure the advertised offer, the salesperson’s explanation, and the transaction presented to the customer agree.
The following overview explains the revised language and offers practical steps for dealership teams. Dealers should confirm the adopted text and effective date when implementing changes.
Start with a complete advertised price
Under the revised language, the total advertised vehicle price must be the most prominently displayed price. That total must include:
Dealer-required fees, including documentary and document-preparation fees.
Dealer-required products, services, equipment, and accessories.
Freight and destination charges.
Dealer preparation and handling charges.
A mandatory charge does not become optional because it has a different name or appears on a separate form.
For example, assume a dealer offers a vehicle for $30,000 and requires the customer to pay a $500 documentary fee and purchase a $1,000 protection package. Assuming there are no other required charges, the advertised price should be $31,500.
Advertising $30,000 and explaining the additional $1,500 in small print would not satisfy the revised pricing provisions. Nor would a sign in the finance office cure the omission from the advertised price.
The price must also be accompanied by a conspicuous identification of the vehicle’s year, make, model, and new or used status.
Understand when an add-on is required
The distinction between a required product and an optional product depends on what the customer must actually purchase.
If the dealer requires a product or service as a condition of buying the vehicle, its charge belongs in the advertised price. The definition also addresses certain preinstalled products, including products installed on every vehicle and products the dealership ordinarily will not remove or disable at the customer’s request.
The revised language expressly excludes genuinely optional products from the definition of dealer-required add-ons. An optional product is one the customer does not have to purchase to buy or lease the vehicle.
Dealers should review installed accessories and protection packages carefully. Describing a product as “optional” in an advertisement is inconsistent with requiring the customer to purchase it at the dealership.
Required fees and products listed on a supplementary or addendum sticker must also be included in the advertised price.
Know what may be added at the sale
The revised language generally prohibits charging more than the advertised price at the time of sale. It identifies limited exceptions:
An optional product the buyer agrees to purchase.
A tax or fee imposed on the buyer by law, including a qualifying temporary registration permit purchased by the dealer and issued to the buyer.
Buyer-requested shipping, subject to the separate requirement to include freight and destination charges in the advertised price.
These exceptions do not allow a dealer to add a mandatory documentary fee or required protection package after attracting the customer with a lower advertised price.
Dealers remain free to negotiate a sale price below the advertised price.
Make the advertised price available without conditions
The advertised vehicle price cannot depend on the customer:
Financing through the dealer or using a particular financing option.
Trading in another vehicle.
Qualifying for a discount, rebate, or incentive that is unavailable to every customer.
The revised language separately permits advertising a conditional rebate when eligibility is clearly disclosed. Advertisements must also identify who is offering the rebate.
Those provisions should be read together. Permission to advertise a military, college, loyalty, or other conditional rebate does not eliminate the prohibition on making the advertised vehicle price dependent on an incentive unavailable to everyone.
A practical approach is to display the generally available vehicle price most prominently and explain conditional rebates separately. Dealers should seek clarification from the Motor Vehicle Enforcement Division, or MVED, before using an additional net price that could be mistaken for the price available to every buyer.
Offer the lowest advertised price without making customers ask
The revised language requires dealers to offer their lowest advertised price to a buyer regardless of whether the buyer knows about it or mentions it.
It also prohibits “internet price,” “e-price,” and similar terms implying that an advertised price is available only to certain customers.
This makes coordination among advertising, sales, and finance especially important. A customer who walks onto the lot should not have to produce a website screenshot to receive the dealer’s lowest advertised price.
As a practical matter, dealerships should establish a way for sales staff to see current advertised prices across the dealership’s website and outside listing services. Questions involving expired promotions, incorrect listings, or conflicting prices should be addressed with MVED rather than resolved through assumptions about exceptions that are not stated in the revised language.
Review documentary-fee signs
The revised language allows a dealer to post a sign identifying a documentary fee or other document-preparation fee if the fee is already included in the advertised price and the sign states that the fee is not required by law.
Illustrative wording could read:
“Our $500 dealer-documentary fee is included in the advertised vehicle price. This fee is not required by law.”
The amount should match the dealership’s actual fee. This example is not an agency-approved form.
The sign explains an included charge; it does not authorize adding that charge again. Dealers also must not tell a customer that a product, service, or charge is required by law or by a lender unless that statement is true.
Advertise inventory accurately
The revised language distinguishes between new and used vehicles advertised at a specific price.
A used vehicle generally must be in the dealer’s possession at the advertised address. An exception applies when the vehicle is actually in transit to that address and the dealer can produce proof that it was purchased before the advertisement.
For a new vehicle that is not at the advertised location, the advertisement must accurately describe its status, such as “in transit,” “in production,” or a similar description. A dealer taking orders for a vehicle that is not in stock must clearly disclose that fact.
Dealers must be willing to show, demonstrate, and sell advertised vehicles, subject to the stated exception for new vehicles with accurate status disclosures. If an advertised vehicle has been sold, sales records must be shown upon request to a prospective buyer, peace officer, or MVED employee.
Bait advertising and bait-and-switch practices remain prohibited.
Use the right photographs and condition descriptions
When an advertisement includes a photograph and a price for a used vehicle, the photograph must show the actual vehicle being offered.
An illustration of a new vehicle must match the advertised vehicle’s make, model, condition, and other material characteristics. A reasonable customer must be able to understand that the picture is illustrative rather than a photograph of the exact vehicle.
Other identification requirements also deserve attention:
Used vehicles: The first line of the advertisement must identify the vehicle as used, pre-owned, certified used, certified pre-owned, or otherwise clearly used.
Branded titles and salvage certificates: The appropriate disclosure must immediately follow the year, make, and model in the same font and font size.
Mileage claims: The dealer must have a completed odometer disclosure supporting the advertised mileage and must produce vehicle records upon request so the mileage can be verified.
Demonstrator and executive vehicles: These descriptions have specific eligibility requirements. They cannot be used for vehicles previously sold or leased to the public or purchased or leased for personal use. Only a dealer franchised for that make of new vehicle may advertise qualifying vehicles under these descriptions, and the status must be clearly and prominently disclosed.
Check promotional language before it goes live
A familiar slogan can create a compliance problem even when the dealership considers it ordinary advertising language.
The revised rule addresses several common claims:
Used-vehicle savings. Specific savings claims on used vehicles are prohibited, including “Was $25,000, now $23,000.” Dealers may advertise the actual selling price.
New-vehicle discounts. A discount on a new vehicle must be stated by reference to the manufacturer’s suggested retail price. “List,” “sticker,” and similar terms refer to MSRP.
Wholesale. The word “wholesale” may not be used in retail vehicle advertising.
Trade-in amounts. Dealers may not advertise a specific trade-in amount or range, such as “$5,000 for any trade.” They also may not claim that a trade will be paid off regardless of the amount owed.
Lowest-price and highest-trade claims. Claims such as “we sell for less” or “highest trade-in allowance” require supporting evidence. That evidence must be included in the advertisement and available upon request.
Price matching. The advertisement must explain all conditions and the evidence a customer must provide. Those requirements cannot place an unreasonable burden on the customer. The rule permits requiring a written offer made to that customer by an authorized dealership representative on a substantially similar vehicle.
Free gifts. “Free” and similar terms may be used only when the gift does not depend on purchasing property or a service. “Free TV with vehicle purchase” does not meet that condition.
Name-your-own offers. Phrases such as “write your own deal,” “name your own price,” “name your own monthly payments,” and “appraise your own motor vehicle” are prohibited.
Invoice and cost. “Invoice” or “factory invoice” may be used if the dealer is willing to show the factory invoice to the prospective buyer. The term “cost” may not be used.
Auction language. “Auction,” “auction special,” and similar terms may be used only for vehicles offered or sold at a bona fide auction.
Dealers also must not falsely imply that they have a manufacturer sponsorship, approval, affiliation, or connection greater than that of other similar dealers.
Give financing and lease advertisements extra attention
A down payment must never be presented in a way that makes it appear to be the vehicle’s sales price.
For a purchase advertised with “no money down,” the revised language requires that the buyer be able to leave with the vehicle without paying money down toward the advertised price. Other material payment requirements must still be disclosed accurately.
Financing advertisements cannot imply that every applicant will qualify for credit. The rule specifically identifies “we accept all credit applications” as an example of prohibited wording when it represents or implies that no prospective buyer will be rejected for inability to qualify.
“No finance charge,” “no carrying charge,” and similar claims cannot be used if there is a charge for placing the transaction on a time-payment basis. If advertised payments change during the loan, the payments and loan terms must be disclosed together.
A dealer advertising a dealer-funded interest-rate buy-down must disclose the dealer contribution and state that it may increase the negotiated vehicle price. Because that provision must be considered alongside the advertised-price restrictions, dealers should obtain guidance before structuring an offer that would increase the price.
Lease advertisements have additional requirements:
Use the word “lease” prominently, in a font and size at least as large as the largest text directly advertising the vehicle.
Do not advertise “no down payment” or similar wording if any payment is required to lease the vehicle.
Do not advertise lease terms to the general public if those terms are unavailable to the general public.
Clearly disclose applicable limitations and qualifications.
Federal credit and lease advertising requirements also apply. Dealers should review financing and lease advertisements under the applicable federal rules as well as Utah’s requirements.
Put driving-trial promises in writing
If a dealership offers a trial period during which a customer may drive a vehicle and return it at the end, the offer must be in writing and provided before the customer takes possession.
The written offer must address:
The trial’s terms and conditions.
Cancellation and return of signed agreements.
Refund of money or other consideration paid to participate, unless the written offer provides otherwise.
Return of the trial vehicle and the customer’s vehicle.
These provisions govern a dealership’s driving-trial offer. They do not create a general right to return every purchased vehicle.
Treat dealership displays and conversations as advertising
A final review should include more than the marketing department’s files. Walk the lot and showroom. Look at windshield prices, addendum stickers, banners, desk signs, digital displays, and fee notices.
Then consider what employees say to customers. Oral statements about vehicles offered for sale or lease are included in the rule’s advertising definition. A compliant website can be undermined by an inaccurate explanation at the sales desk.
Written disclosures should be reasonably prominent through size, contrast, placement, or emphasis and understandable to the buying public. Audio disclosures must be understandable and delivered at a consistent speed throughout the advertisement. Fine print cannot be used to contradict the price or disclose mandatory charges omitted from it.
A practical review before publishing
Dealerships can use the following questions as a final check:
Is the vehicle description accurate, including condition, availability, photograph, mileage, and title status?
Does the most prominent price include every mandatory dealer charge?
Can a customer receive that price without financing, a trade-in, or a limited-eligibility incentive?
Are conditional rebates and their eligibility requirements clearly explained?
Can sales staff identify and offer the dealer’s lowest advertised price?
Do signs and addendum stickers agree with the advertised price?
Are required disclosures noticeable and understandable?
Are promotional claims permitted and supported?
Have financing and lease advertisements received the additional review they require?
Do employees and outside advertising vendors understand the same requirements?
Keeping dated copies of advertisements and their supporting records is a useful operating practice. So is assigning responsibility for correcting inaccurate or outdated listings across all advertising channels.
A complete price, an accurate vehicle description, and a clear explanation of the offer give dealership staff a consistent message to deliver—and give customers a reliable basis for deciding whether to visit and buy.