Total price rules for short-term rental fees

The FTC rule on short-term lodging fees

The Federal Trade Commission’s Rule on Unfair or Deceptive Fees, 16 CFR Part 464, has applied to short-term lodging since May 12, 2025². The Commission announced the final rule on December 17, 2024, after a 4-1 vote with Commissioner Andrew Ferguson dissenting, and set it to take effect 120 days after publication in the Federal Register¹. The rule was published on January 10, 2025, in volume 90 of the Federal Register, starting at page 2066².

The rule covers two kinds of purchase: live-event tickets, and short-term lodging, defined to include “temporary sleeping accommodations at a hotel, motel, inn, short-term rental, vacation rental, or other place of lodging”³. The FTC estimated that the rule would save consumers up to 53 million hours per year¹.

The FTC’s staff guidance on the rule, dated May 2025, lists home shares and vacation rentals offered through platforms such as Airbnb or VRBO, and discounted extended stays at a hotel, among its examples of covered lodging⁴. It says the rule applies to any business that offers, displays or advertises short-term lodging, “including third-party platforms, resellers, and travel agents”, and that intermediaries who display pricing for the seller must display the total price⁴. Business-to-business transactions are covered⁴.

The guidance lists three kinds of lodging outside the rule⁴:

• long-term or other rental housing with an ongoing landlord-tenant relationship⁴;
• short-term extensions to leases offered by rental housing providers⁴;
• temporary corporate housing offered by an apartment community under the same conditions as long-term leases⁴.

What the federal rule requires a price to show

The rule defines the total price as the maximum total of all fees or charges a consumer must pay for the good or service and any mandatory ancillary good or service³. Three kinds of charge may be left out of that figure: government charges, shipping charges, and fees for optional ancillary goods or services³. Government charges are fees or charges imposed on the transaction by a federal, state, tribal or local government agency, unit or department³.

Under section 464.2, it is an unfair and deceptive practice to offer, display or advertise any price of a covered good or service without clearly and conspicuously disclosing the total price². The total price must be disclosed “more prominently than any other pricing information”, and where the final amount of payment is displayed, that amount must be at least as prominent as the total price². Before the consumer consents to pay, the business must disclose the nature, purpose and amount of any fee or charge left out of the total price, and the final amount of payment². The rule also prohibits misrepresenting any fee or charge in an offer, display or advertisement for these goods and services².

The staff guidance applies this to rentals and hotels⁴:

• a vacation rental that adds a cleaning fee consumers must pay on top of the nightly rate must include the cleaning fee in the total price⁴;
• a required resort fee must be included in the total price⁴;
• taxes and other government charges need not be in the total shown up front, and the business must disclose the excluded charges before it prompts people to pay⁴;
• fees for optional extras need not be in the total price⁴.

The FTC describes the rule as “not prohibiting any type or amount of fee or specific pricing strategies”⁵. Section 464.4 says the rule does not displace state laws on unfair or deceptive fees except where they are inconsistent with it, and a state law that gives consumers greater protection is not inconsistent².

Federal penalties and enforcement

In announcing a warning letter to the ticket reseller StubHub on May 14, 2025, the FTC cited “civil penalties of up to $53,088 per violation” of the rule⁶. On February 11, 2025, the FTC had announced that the maximum civil penalty for violations of sections 5(l), 5(m)(1)(A) and 5(m)(1)(B) of the FTC Act had increased from $51,744 to $53,088, effective on publication in the Federal Register on January 17, 2025⁷.

On September 15, 2026, the FTC published a Federal Register notice saying its civil penalty amounts “will remain unchanged during 2026” and that it will continue to apply the 2025 levels⁸. The notice cites an Office of Management and Budget memorandum, M-26-11, which said the 2026 inflation adjustment was cancelled⁸.

The staff guidance says a business that violates the rule could be ordered to bring its practices into compliance, refund money to consumers and pay civil penalties⁴.

On July 2, 2026, the FTC filed a complaint and a stipulated proposed order against the travel app Hopper in the U.S. District Court for the District of Massachusetts⁹. The complaint alleged violations of the FTC Act and, for short-term lodging bookings since May 12, 2025, of the fees rule; the Commission voted 2-0 to file, and the proposed order required Hopper to pay $35 million for consumer redress⁹. The court entered the stipulated order on August 20, 2026, in civil action 1:26-cv-13058¹⁰.

California

California has two laws that require short-term rental prices to include mandatory fees, and both became operative on July 1, 2024¹¹¹³.

SB 478, which the Attorney General’s office also calls the Hidden Fees Statute, prohibits advertising, displaying or offering a price for a good or service that does not include all mandatory fees or charges¹¹. The prohibition sits in Civil Code section 1770(a)(29), which allows two exclusions: taxes or fees imposed by a government on the transaction, and postage or carriage charges reasonably and actually incurred to ship a physical good to the consumer¹². The Attorney General’s office names short-term rentals and hotels among the prominent industries the law applies to¹¹.

AB 537 added section 17568.6 to the Business and Professions Code, which covers room rates for short-term lodging¹³. A place of short-term lodging, a website, app or similar centralized platform, or any other person may not advertise, display or offer a room rate that leaves out “all fees or charges required to stay at the short-term lodging”, except taxes and fees imposed by a government on the stay¹³. Those government taxes and fees must still be part of the total price shown before the consumer reserves the stay¹³.

The section defines short-term lodging as any hotel, motel, bed and breakfast inn or other transient lodging, and includes a residential property rented to a visitor for 30 consecutive days or less through a centralized platform that advertises the rental and processes its payments¹³. It applies to advertising before the public in California and from California to the public in any state¹³. A person that knew or should have known it advertised a room rate in violation faces a civil penalty of up to $10,000 for each violation, in an action that a city attorney, district attorney, county counsel or the Attorney General may bring¹³.

Minnesota

Minnesota’s total price law took effect on January 1, 2025, under chapter 111 of the 2024 session laws, H.F. No. 3438, which the governor signed on May 20, 2024¹⁵. For industries whose prices are regulated by the Metropolitan Airports Commission, it took effect on June 1, 2025¹⁵.

Minnesota Statutes section 325D.44, subdivision 1a, makes it a deceptive trade practice to advertise, display or offer a price for goods or services that does not include all mandatory fees or surcharges¹⁴. A mandatory fee includes one that must be paid to buy the goods or services advertised, one the consumer cannot reasonably avoid, or one a reasonable person would expect to be included¹⁴. Taxes imposed by a government entity on the sale are excluded, and a reasonable postage or shipping fee actually incurred may be charged¹⁴.

The subdivision sets out other ways to comply. A seller of services whose total depends on consumer selections, distance or time complies by disclosing the factors that set the price, any mandatory fees and that the total may vary, and a food or beverage establishment, including a hotel, complies on gratuities by disclosing the percentage of any automatic and mandatory gratuities¹⁴. Fees authorized by law and charged by motor vehicle dealers, businesses regulated by the Public Utilities Commission and real estate settlement services are exempt¹⁴.

Virginia

Virginia’s rule took effect on July 1, 2025, as Chapter 686 of the 2025 Acts of Assembly, from SB 1212, which the state’s Legislative Information System records as identical to HB 2515¹⁸. The provisions sit in Chapter 58 of Title 59.1 of the Code of Virginia, sections 59.1-607 to 59.1-610¹⁷.

Section 59.1-608 bars a supplier, in a consumer transaction, from advertising or displaying a price for goods or services without clearly and conspicuously displaying the total price, “which shall include all mandatory fees or surcharges”¹⁷. Taxes or fees imposed by a government or government-approved entity, assessment fees of a government-created special district or program, and reasonable postage or shipping fees are outside the definition of a mandatory fee¹⁷.

The section lists ways for particular suppliers to comply¹⁷:

• a restaurant or hotel complies if every priced offer or advertisement clearly discloses the percentage of any automatic and mandatory gratuities¹⁷;
• a price-variable supplier, whose total depends on consumer selections or on distance or time, complies by disclosing the factors that set the final price, any mandatory fees and that the total may vary¹⁷;
• a provider of live-event tickets that complies with the FTC rule is deemed compliant, and the section names no such route for lodging¹⁷.

A violation is a prohibited practice under section 59.1-200 of the Virginia Consumer Protection Act¹⁷.

Massachusetts

Massachusetts set its rule by regulation. The Attorney General’s regulation 940 CMR 38.00, on unfair and deceptive fees, carries a date of March 14, 2025 in the state law library’s listing and cites the consumer protection law, chapter 93A, section 2, as its authority¹⁹. It became enforceable on September 2, 2025²⁰²¹.

Whenever pricing information is presented, and before a consumer is asked for personal information, a business must disclose the total price of a product including any mandatory charges or fees, and must display that total more prominently than any other pricing information²¹. It must also disclose the nature, purpose and amount of charges, and whether any are optional or waivable, with instructions for avoiding them²¹.

The Attorney General’s office says the regulations apply across industries to businesses that operate, advertise or sell in Massachusetts, including online and out-of-state businesses²⁰. Attorney General Andrea Joy Campbell cited hotel bookings and apartment rentals among her examples on the day the rules took effect²⁰. Violations can lead to enforcement by the Attorney General’s Office and to private actions under the state’s consumer protection law²¹.

Colorado

Colorado’s HB25-1090, Protections Against Deceptive Pricing Practices, was signed on April 21, 2025 and took effect on January 1, 2026, as chapter 94 of the 2025 session laws¹⁶.

The General Assembly’s summary says the law prohibits offering, displaying or advertising pricing information for a good, service or property without disclosing “the maximum total (total price) of all amounts that a person may pay”, not counting a government charge or shipping charge unless voluntarily included¹⁶. The summary lists cases in which a person is treated as compliant, including a person that can show it is governed by and compliant with applicable federal law, rule or regulation on pricing transparency for the transaction at issue¹⁶.

The summary says violations are deceptive, unfair and unconscionable trade practices under the Colorado Consumer Protection Act, and that the attorney general may adopt rules to carry out the law¹⁶. The same act sets separate limits on fees landlords may charge tenants¹⁶.

How Airbnb changed its price display

On November 7, 2022, Airbnb said it would begin rolling out an option to display the total price in December, with the total including all fees before taxes and shown in search results²².

On April 21, 2025, Airbnb said it was making total price display “the standard pricing format globally”²³. It said it first launched total price display in 2019 in parts of Europe, Australia, Canada and Korea, and that almost 17 million guests had used the optional toggle to book travel, based on internal data as of December 31, 2024²³. The displayed total includes all fees before taxes; Airbnb said taxes are included in some countries and regions, and the total including taxes is always shown before checkout²³. The post does not mention the FTC rule²³.

Common questions

Sources

1. Federal Trade Commission, Federal Trade Commission Announces Bipartisan Rule Banning Junk Ticket and Hotel Fees (2024-12-17). Primary source, read 2026-10-08.
2. Federal Register (U.S. Government Publishing Office), Trade Regulation Rule on Unfair or Deceptive Fees, final rule, 90 FR 2066, 16 CFR Part 464 (2025-01-10). Primary source, read 2026-10-08.
3. Legal Information Institute, Cornell Law School, 16 CFR § 464.1 Definitions. Secondary source, read 2026-10-08.
4. Federal Trade Commission, The Rule on Unfair or Deceptive Fees: Frequently Asked Questions (2025-05). Primary source, read 2026-10-08.
5. Federal Trade Commission, FTC Rule on Unfair or Deceptive Fees to Take Effect on May 12, 2025 (2025-05-05). Primary source, read 2026-10-08.
6. Federal Trade Commission, With NFL’s 2025 Schedule Set to be Announced, FTC Warns Ticket Reseller StubHub it Must Comply with Agency’s New Rule on Unfair and Deceptive Fees (2025-05-14). Primary source, read 2026-10-08.
7. Federal Trade Commission, FTC Publishes Inflation-Adjusted Civil Penalty Amounts for 2025 (2025-02-11). Primary source, read 2026-10-08.
8. Federal Register (U.S. Government Publishing Office), Federal Trade Commission, Civil Penalty Inflation Adjustments, notice, 91 FR 58446 (2026-09-15). Primary source, read 2026-10-08.
9. Federal Trade Commission, Travel App Hopper to Pay $35 Million to Settle FTC Allegations It Charged Fees Without Consent and Deceived Users About Fees and Benefits of Some Products (2026-07-02). Primary source, read 2026-10-08.
10. Federal Trade Commission, FTC v. Hopper (USA), Inc. (case page). Primary source, read 2026-10-08.
11. California Department of Justice, Office of the Attorney General, SB 478 - Hidden Fees. Primary source, read 2026-10-08.
12. California Legislative Information, Civil Code section 1770. Primary source, read 2026-10-08.
13. California Legislative Information, Business and Professions Code section 17568.6. Primary source, read 2026-10-08.
14. Minnesota Office of the Revisor of Statutes, Minnesota Statutes section 325D.44, Deceptive trade practices. Primary source, read 2026-10-08.
15. Minnesota Office of the Revisor of Statutes, Laws of Minnesota 2024, chapter 111 (H.F. No. 3438) (2024-05-20). Primary source, read 2026-10-08.
16. Colorado General Assembly, HB25-1090 Protections Against Deceptive Pricing Practices. Primary source, read 2026-10-08.
17. Virginia Legislative Information System, Code of Virginia, Title 59.1, Chapter 58, Mandatory Fees or Surcharges. Primary source, read 2026-10-08.
18. Virginia Legislative Information System, SB1212, 2025 Regular Session, Virginia Consumer Protection Act; prohibited practices, mandatory fees or surcharges disclosure. Primary source, read 2026-10-08.
19. Mass.gov (Trial Court Law Libraries), 940 CMR 38.00: Unfair and deceptive fees (2025-03-14). Primary source, read 2026-10-08.
20. Massachusetts Office of the Attorney General, AG Campbell Issues Statement On Effective Date Of New “Junk Fee” Consumer Protection Regulations (2025-09-02). Primary source, read 2026-10-08.
21. Massachusetts Office of the Attorney General, AG’s Office Releases Updated Business Guidance On New “Junk Fee” Rules; Businesses Must Comply By September 2 (2025-07-29). Primary source, read 2026-10-08.
22. Airbnb, Inc. (newsroom), Airbnb is introducing total price display and updating guest checkout (2022-11-07). Primary source, read 2026-10-09.
23. Airbnb, Inc. (newsroom), Total price display is now standard for guests worldwide (2025-04-21). Primary source, read 2026-10-09.