What is a market adjustment, and is it negotiable?

What MSRP is

A new car’s window label must show “the retail price of such automobile suggested by the manufacturer,” the suggested prices of optional equipment attached when the car was delivered to the dealer, the charge to the dealer for transporting the car, and the total (15 U.S.C. 1232(f)). The statute calls it a suggested price. It requires the label to disclose that price, not the dealer to sell at it. A market adjustment is the dealer’s own amount above it, so it won’t be on the factory label. Items the dealer installed are a separate add-on charge, covered in What is a dealer addendum sticker, and do I have to pay for it?

Is it negotiable?

It’s part of the price, so yes. The CFPB says that “just like the price of the vehicle, the interest rate is negotiable” (CFPB). FTC staff, in non-binding FAQs, put it this way: “Dealers and consumers can negotiate, and consumers can certainly pay less than the price advertised” (FTC staff FAQs, non-binding). The FTC’s consumer advice is to get a written out-the-door price before you visit, which “will help you compare offers from different dealers on an apples-to-apples basis” (FTC).

Advertised prices and added charges

FTC staff’s September 2026 FAQs, which aren’t binding on the public or the Commission, set out how staff reads the FTC Act on advertised prices (FTC staff FAQs, non-binding):

• An advertised price “must reflect the actual price that any consumer can pay to purchase the car, whether they negotiate or not.”
• The advertised price “cannot be based on a lower price some consumers have gotten if another consumer who comes to the lot would be quoted more than that price.”
• An ad may show the MSRP “as long as the actual price is the most prominently displayed amount, and consumers know what price they would need to pay to get the car.”
• Required fees belong in it too: “if a dealer requires a consumer to pay a fee to purchase the car, that fee must be included in the advertised price,” including the full document fee. Each state’s doc-fee rule is in Dealer doc fees by state.

The FTC has acted on surprise adjustments. In 2024 the FTC and Arizona alleged that Coulter Motor Company advertised cars online below their suggested retail prices, told shoppers who came in that the advertised price wasn’t available, and “added hundreds or thousands of dollars more than the advertised price in a so-called ‘market adjustment,’ supposed add-ons that were pre-installed on the car, and other miscellaneous fees.” Coulter and its former general manager agreed to pay $2.6 million to settle the lawsuit, most of it for consumer refunds (FTC).

What you can ask for in writing

• The out-the-door price, before you visit. The FTC suggests asking dealers for “out-the-door prices in writing” and using them “to confirm that advertised prices, discounts, rebates, etc. are actually being applied” (FTC). How to ask for the out-the-door price covers how.
• The adjustment as its own line, so you can see it next to the MSRP for that exact car.
• The same request to other dealers, so you have written numbers to compare.

The out-the-door calculator adds up a quote, and How to read a dealer worksheet shows where an adjustment tends to sit.

What to say

Before you sign: checklist

State notes

FAQ

Sources

1. 15 U.S.C. 1232 (U.S. Code, 2024 ed., govinfo): the window label must show the manufacturer’s suggested retail price, factory options, transportation charge and total, (f) (accessed Oct 2026)
2. CFPB – Can I negotiate a car loan interest rate with the dealer?: the price of the vehicle is negotiable (accessed Oct 2026)
3. FTC – Automobile Industry Pricing Transparency FAQs (Sep 2026): non-binding FTC staff guidance: negotiation, the actual price any consumer can pay, MSRP in ads, required and document fees (accessed Oct 2026)
4. FTC – State of Arizona and FTC action against Coulter Motor Company (Aug 15, 2024): alleged “market adjustment” charges and supposed pre-installed add-ons above advertised prices; $2.6 million settlement (accessed Oct 2026)
5. FTC – Buying a Used Car From a Dealer: ask for out-the-door prices in writing before you visit (accessed Oct 2026)
6. FTC – Financing or Leasing a Car: a written out-the-door price helps you compare dealers’ offers (accessed Oct 2026)
7. Cal. Civ. Code 1784.31: “total price” includes any dealer price adjustment, (j); operative Oct 1, 2026 (accessed Oct 2026)
8. Cal. Civ. Code 1784.41: total price in ads for a specific vehicle, (a) (accessed Oct 2026)
9. Cal. Civ. Code 1784.40: misrepresenting availability at a total price, (d) (accessed Oct 2026)
10. Fla. Stat. 501.976 (2026): no price increase after accepting an order, with five exceptions, (15); fees in the advertised price, (16) (accessed Oct 2026)

About this guide

This page is general information about federal rules, and some state rules, as of October 2026. It isn’t legal advice. Your contract and the law control, including your state’s law, and the law can change. If a quote is higher than an ad for the same car, ask the dealer to explain the difference in writing.