FTC Enforcement: Review Your Social Media Policy

March 18, 2026

Background

With the FTC's March 13 announcement that advertised vehicle prices must reflect the total price — a major change that will impact Virginia dealers — VADA has developed resources you can use starting today to ensure compliance and avoid costly penalties that could impact your bottom line and reputation.

To comply with the FTC Act, the advertised price of a vehicle should be the total price the consumer is expected to pay, which must include all fees and charges (i.e., processing fee and freight) and only excludes governmental fees (i.e, tags, title and taxes).

Today, we encourage you to review your social media policy.

With the changes to your advertising necessitated by last Friday’s FTC announcement, it is a good time to review your social media policy. Social media postings can be a major hole in your compliance program. Here are some quick points to consider as it relates to advertising:

  • Social media posts with offers are advertising. If a salesperson’s posts violate federal or state laws applicable to advertising, your dealership could be liable in a government regulatory action.
  • Employees must make sure they identify themselves. If the post relates to the dealership, the poster should identify himself or herself and his or her role at the dealership. When the person is speaking personally and not for the dealership, that should be clear.
  • When employees use their own social media accounts, you have no control — but the dealership will be held responsible for those posts. Your policy should clarify that any postings having anything to do with the dealership should be through dealership hosted or subscribed media platforms.

We have included broader resources on social media for your review at the buttons below: a deeper article by our counsel Barrie Beaty, a sample social media policy that you may use, and a consent form for appearing in social media content.

For further questions, contact VADA general counsel and executive vice president Anne Gambardella, Esq.