On October 15, 2026, New York City's Department of Consumer and Worker Protection (DCWP) sued CarGurus in New York State Supreme Court. The city says CarGurus labeled used cars "Great Deal" or "Good Deal" based on asking prices that left out mandatory dealer fees, down payment conditions, and trade-in requirements, and that it did so more than 2,000 times. CarGurus says the claims don't reflect the facts and that it will defend itself.
CarGurus is the defendant, but every listing quoted in the complaint was posted by a dealer. Two days before the suit, on October 13, CarGurus also rewrote its Dealer Pricing Policy with tighter fee rules and a list of fee labels it will treat as violations. If you list used cars on CarGurus, your Deal Ratings now depend on how you fill out the fee setup tool and what you leave in your vehicle descriptions. This post covers what the city alleges, what the October 13 policy says, and the changes an independent lot can make to its CarGurus listings and its own website this week.
What New York City says CarGurus did
DCWP enforces the New York City Consumer Protection Law, which bans false advertising and special offers with hidden conditions. The complaint makes three main claims against CarGurus.
- Deal Ratings and "below market" savings figures were calculated on an asking price that did not include every fee or condition in the dealer's offer. The complaint counts at least 1,211 NYC listings rated "Great" or "Good" on a false asking price between September 15, 2023 and June 29, 2026, and at least 2,017 published savings calculations it calls deceptive.
- The fee badges CarGurus added in late April ("Price includes fees," "No additional dealer fees," "Fees not disclosed") were wrong on at least 149 NYC listings between April 30 and June 29, 2026, because the dealer disclosed a small fee in the tool and kept larger fees in a disclaimer.
- CarGurus' AI chatbot could generate lists of "Great Deals" in New York City without showing the dealer disclaimer or vehicle description, so a shopper using it had no way to see the extra fees without clicking through to each listing.
The city also argues that CarGurus publishes dealer pricing guidelines and says it enforces them, but left deceptive listings up after DCWP sent cease-and-desist letters in July 2023 and May 2025. The complaint asks for a permanent injunction, restitution, and civil penalties of up to $3,500 for each knowing violation.
A New York City rule sits underneath all of this. Under 6 RCNY § 2-103(i), the selling price of a car from a licensed second-hand dealer is the price advertised, and it "shall include all charges connected with the sale." DCWP also proposed a citywide junk fee rule in July that would require the full price, with all mandatory charges, up front for any good or service.
The listings in the complaint
Two listings from the complaint show what a shopper saw.
On June 15, 2026, CarGurus showed a 2018 Honda CR-V EX AWD from Elite Mitsubishi at $16,174, $2,212 below market and rated a "Great Deal." The listing carried the "includes dealer fees" badge, and clicking it showed a $175 documentation fee inside the price. Further down, a separate disclaimer listed Prep & Destination at $1,995, a Conveyance Fee of $995, and an Admin Fee of $695. That is $3,685 in fees outside the price. By the city's math the car was $1,473 above market, which by CarGurus' own definitions is no Great Deal.
On September 22, 2026, a 2018 Mercedes-Benz GLE 350 from Novo Motors was listed at $18,590 and shown as $3,413 below market. The dealer disclaimer at the bottom said the advertised price reflected "the balance after a 20% downpayment." The complaint puts the real cost $1,234.50 above market.
The complaint also says DCWP denied Elite Mitsubishi's most recent license application, in part over its persistent misleading ads. Dealers whose listings end up as exhibits can face their own consequences.
A CarEdge report cited in the complaint found that mandatory fees added about $1,100 on average to listed prices across more than 40,000 online quotes. If your doc fee and prep fee sit outside your CarGurus price, your listing looks like the ones in this complaint.
What CarGurus changed this year, and what the October 13 policy adds
CarGurus has been moving toward all-in pricing for months, and the complaint lays out the timeline.
- Around April 30, CarGurus added fee badges and a shopper filter for listings that include dealer fees.
- On June 24, it told dealers that starting July 14, used listings without disclosed fees would get "No Rating" and drop lower in search results, and that IMV (Instant Market Value) and Deal Ratings would be calculated on the all-in price including disclosed fees.
- On July 29, according to the complaint, CarGurus reported that more than 90% of used inventory from subscribing dealers included disclosed fees.
The updated Dealer Pricing Policy, dated October 13, 2026, goes further than a disclosure requirement. Every price on CarGurus must be the price available to any shopper and must include all mandatory dealer-imposed fees, with only tax, title, license, registration, and other government fees left out. A price cannot be conditioned on a down payment, a trade-in, dealer or preferred-lender financing, a payment method, or buying another product. Rebates and discounts can only be baked in if every shopper gets them without applying or qualifying.
The policy names the fees it expects to see disclosed: documentation fees, reconditioning fees, dealer processing fees, electronic filing fees, market adjustments, and mandatory dealer-installed or pre-installed products and packages. It also lists fee entries that will not pass, including "John's Dealership Financing Rebate," "Down payment required," a fee named "120," and "Price Does Not Include Prep Fee 299."
The policy also says dealers "must not manipulate the CarGurus fee disclosure tools," which the policy defines as disabling, mislabeling, or toggling fee entries to make the price look lower or earn a better Deal Rating. And CarGurus says it may check your own website, shopper feedback, and other platforms when it decides whether you comply. Penalties run from pulling your Deal Ratings and pricing to removing some or all of your inventory, with or without notice.
Why a lawsuit against the marketplace lands on your listings
CarGurus has a lawsuit to answer, and its fastest lever is enforcement against dealers. Its CEO's statement says the Trust and Safety team uses AI tools and human review to find listings that break the rules and can remove Deal Ratings, pricing, or dealers from the platform. With a lawsuit pending, it is reasonable to expect more of those checks, comparing your disclosed fees against your description text and the price on your own vehicle pages.
Regulators are working the same issue from the dealer side. The FTC warned 97 dealer groups in March to advertise prices that include all mandatory fees, and its October 8 settlement with Greenway Auto Group spelled out how a dealer's third-party listings are treated. We covered what the Greenway order requires and how its listing safe harbor works last week, and the fee math for building an advertised price is in our walkthrough of the FTC's dealer pricing guidance. This post sticks to what changes inside CarGurus.
A "No Rating" listing also ranks lower, and shoppers can now filter to see only listings with fees included. If CarGurus is a meaningful lead source for your store, a fee setup that is incomplete or gamed costs you visibility before any regulator gets involved.
Set up CarGurus fee disclosure so the Deal Rating holds up
Start with your buyer's orders before you open the dashboard. Pull three recent retail deals and write down every charge that was not tax, title, or registration. That list is what CarGurus means by mandatory dealer fees. If a charge showed up on every deal, it belongs in the price.
- Open the dealer fee setup tool in your CarGurus Dealer Dashboard and enter each mandatory fee as its own line. Use the same name the buyer sees on paperwork. CarGurus' Digital Deal setup guide asks for consumer-facing fee names of 40 characters or less that match how the fee appears in store.
- Leave government charges out. Tax, title, and registration are excluded by the policy, and CarGurus' setup guide says it pulls them from a third party.
- If your feed already sends an all-in price, turn on the setting that says fees are included in your inventory feed. Leaving it off can cost you the Deal Rating even when the number is right. Turning it on when the feed price excludes fees is the kind of toggling the October 13 policy calls manipulation.
- Check the price preview in the tool against a real buyer's order for one car. The preview number should match what your desk would quote a cash buyer before tax and tags.
- Update fees the same day they change at the store. If you raise the doc fee on the first of the month, the CarGurus number changes on the first of the month.
Mandatory packages need a decision. Nitrogen tires, window etch, or a theft device that is already on the car and cannot be declined is a mandatory charge under the policy. Either put it in the price or make it optional in practice, which means a buyer can say no and pay the advertised number.
Delete the fee disclaimers buried in your descriptions
Almost every example in the complaint followed the same pattern. A small fee was disclosed through the tool, and larger fees were listed in the vehicle description or a disclaimer box near the bottom of the page. That pattern got the listings flagged, and the October 13 policy now names it.
Most lots did not write those disclaimers last week. They came from a template in the DMS, a feed provider default, or a description someone wrote in 2022 and nobody touched since. Search your feed or description templates for these strings:
- "does not include," "plus," "excludes," and "not included"
- "prep," "reconditioning," "conveyance," "admin," "processing," "dealer fee," and "documentation"
- "down payment," "with approved credit," "when financed," "with trade," and "after rebates"
- "internet price" or "e-price" when it differs from what the desk will honor
Every hit has two possible fixes. Fold the charge into the price and delete the sentence, or confirm a buyer can decline the charge and rewrite the line so it says so plainly. Do not keep a disclaimer that contradicts a "Price includes fees" badge. That combination is the core of the city's case.
Watch payment and down-payment language too. A listing that advertises the balance after 20% down, like the GLE 350 in the complaint, fails the policy outright. If you want to show payments, show them as a separate figure below a price any cash buyer can pay.
Keep your website and your CarGurus price on the same number
CarGurus says it may look at your own website when checking compliance. If the VDP on your site shows $16,174 with "plus $1,995 prep" and your CarGurus listing shows $19,859 with fees included, the mismatch looks like an error at best and a bait price at worst.
The fix is one price source. Set the all-in price once, in your inventory system or website platform, and send that same number to your site, CarGurus, Facebook, Cars.com, and Google. Every marketplace has its own rules for fees, and the safest feed is one where no destination has to add anything. We made the same argument for Google in our guide to feed and landing-page price mismatches, where Merchant Center disapproves vehicles when the feed and the page disagree.
Check timing as well as amounts. If your website updates prices hourly and your CarGurus feed runs once a night, a price drop can leave the two numbers apart for most of a day. Ask your feed provider when each export runs and whether price changes trigger an extra push.
If you display CarGurus Deal Rating badges on your own VDPs, read that section of the policy closely. Badges have to be requested from CarGurus each time a page loads, shown only in the exact form CarGurus provides, and the price beside them has to follow the same fee rules. A saved image of a "Great Deal" badge next to a fee-excluded price would put the problem New York is suing over onto your own site.
Down payment, trade-in, and financing-only prices
Buy-here-pay-here and finance-focused lots run into the October 13 rules more than anyone. A price that only works with in-house financing, a minimum down payment, or a trade cannot be the CarGurus price. Neither can a price with a rebate that only some buyers qualify for, such as a military or loyalty discount.
You can still advertise financing. The headline price on CarGurus and on your VDP has to be the cash price any shopper can pay, with payment offers below it and their own terms. If your business model depends on a lower "with financing" number, expect CarGurus to treat those listings as non-compliant, and expect a shopper who reads the city's press release to ask about it.
What the chatbot claim means for your listing data
The chatbot section of the complaint is short. It says the chatbot's "Great Deal" lists showed price and rating but left out the dealer disclaimer and vehicle description. Assume every AI shopping tool, marketplace search page, and Google listing works the same way, reading structured fields like price, mileage, and Deal Rating and skipping the fine print at the bottom of your description.
Anything that changes what a buyer pays has to live in the price field. If that field excludes $2,000 in fees, every tool that quotes it is quoting a price your desk won't honor.
A one-week CarGurus Deal Rating cleanup for a 40 to 150 car lot
This is a few hours of work spread across a week, and most of it is checking.
- Monday: Pull three recent buyer's orders and list every non-government charge. Decide which are mandatory and which a buyer can really decline.
- Tuesday: Update the CarGurus fee setup tool to match that list, with fee names buyers will recognize. Set the feed-includes-fees option to match what your feed sends.
- Wednesday: Search description templates and dealer disclaimers for fee, down payment, and financing language. Fold charges into price or rewrite them as optional.
- Thursday: Compare ten VINs across your website, CarGurus, and Facebook. The headline price should match on all three, and any CarGurus listing showing "Fees not disclosed" or "No Rating" goes on a fix list.
- Friday: Brief the sales desk. A shopper who saw $19,859 with fees included should get a buyer's order that starts at $19,859 before tax and tags. Save screenshots of ten listings and their matching buyer's orders in a dated folder.
Keep the screenshots. If CarGurus pulls a Deal Rating or a shopper complains to a regulator, a dated record showing the listing price matched the quote is the most useful thing you can produce.
Repeat the ten-VIN check monthly. Fees change, new templates get added, and staff paste old descriptions onto new cars. Our post on how VINMax picks which cars to promote covers why a clean price matters before you pay to boost a listing, and our comparison of the two biggest used-car marketplaces covers how CarGurus stacks up against Autotrader on reach and cost.
Where AutoFire fits
AutoFire gives independent used-car dealers a lot website where every car gets its own page, and the same inventory record feeds the site and your marketplace syndication. You set the price once, with your fees inside it, and that number goes everywhere. If your CarGurus and website prices have drifted apart, you can get your lot online with AutoFire or book a short demo to see how one price source works.
Sources
- NYC DCWP press release, October 15, 2026
- DCWP summons and complaint against CarGurus
- CarGurus statement on DCWP claims, October 15, 2026
- CarGurus Guidelines for Dealer Pricing and Marketing, October 13, 2026
- CarGurus dealer fee transparency update, June 24, 2026
- CBT News coverage of the lawsuit, October 19, 2026
- Dealership Guy on the July 14 fee disclosure deadline
