FTC Junk Fee Rule for Hotels: Displaying Resort Fees Legally

On this page 7 sections

1. What the FTC Junk Fee Rule Means for Hotels and Lodging Businesses
2. Which Mandatory Fees Belong in Hotel All-In Pricing
3. Updating Your Booking Engine and OTA Listings to End Hotel Drip Pricing
4. Credit Card Surcharges and the Total-Price Requirement
5. State Hotel Mandatory Fees Laws That Go Further Than the Federal Rule
6. Reducing Fee-Related Chargebacks With Clear Resort Fee Disclosure
7. Next Steps for Your Property

Key takeaways

• Mandatory fees a guest can't avoid, such as resort, amenity, or destination fees, are the main concern of total-price rules. Confirm with counsel how yours should be displayed.
• Check every place a rate appears: your booking engine, OTA listings, metasearch feeds, ads, and phone scripts.
• Card surcharges can be affected by the federal fee rule, state law, and card network rules. Confirm your setup with counsel and your processor before adding one.
• Clear fee disclosure at booking, confirmation, and check-in is also your best evidence when a guest disputes a resort fee.

The FTC junk fee rule for hotels changes how lodging businesses should think about advertised room rates. If your property charges a resort fee, amenity fee, destination fee, or any other charge every guest must pay, adding that charge for the first time at the last booking step is a real compliance risk. This guide explains how to sort your fees and update your booking engine and OTA listings. It also covers card surcharge practices and how clear disclosure can reduce fee-related chargebacks.

This article is general information, not legal advice. We have not summarized the rule's specific definitions, exclusions, or deadlines here. Read the current rule text and the FTC's business guidance at ftc.gov, and confirm your setup with a qualified attorney.

What the FTC Junk Fee Rule Means for Hotels and Lodging Businesses

The FTC has published a federal fee rule and business guidance on how mandatory fees are advertised. Lodging is among the businesses it addresses. Before you change anything, read the official text to confirm whether and how it applies to your property type. Hotels, motels, inns, resorts, and vacation rentals can each raise different questions.

This guide doesn't restate the rule's specific requirements. It works from two consumer-protection principles that reduce risk under federal and state law:

1. Show what the guest will actually pay. A price that reflects mandatory fees is easier to defend than a stripped-down nightly rate with charges added later. The rule text explains how a total price must be presented and how it may appear alongside other price figures. Read those provisions directly instead of relying on summaries, including this one.
2. Describe fees accurately. A fee's name, amount, and purpose should match reality. A "resort fee" for amenities guests can't use, or a property fee named to look like a government tax, creates misrepresentation risk.

The practice drawing attention is hotel drip pricing: advertising a low nightly rate, then adding mandatory charges as the guest clicks toward checkout. When the price a guest sees first is the price they pay, they can fairly compare your property with the one down the street.

For a broader look at how federal rules treat ticketing and lodging together, see our overview of FTC total price rules for tickets and hotels.

Which Mandatory Fees Belong in Hotel All-In Pricing

Hotel all-in pricing starts with sorting every charge on your rate plans. A practical first question is whether the guest can actually avoid the charge. The table below groups common fee types and lists questions to settle with counsel against the current rule text. It does not state how the rule treats any fee.

A few judgment calls trip up properties:

• "Optional" fees that aren't optional. If parking is the only practical way to reach your property, or an amenity fee applies whether or not the guest uses the pool, ask counsel whether the fee should be treated as mandatory.
• Fees that look like taxes. A property-imposed charge named to resemble a government tax is a misrepresentation risk. Name it accurately.
• Fees that vary by room or date. If the fee changes with room type or season, your system needs to calculate it for each stay. A blanket footnote doesn't solve the problem.
• Per-guest or per-pet fees. If a fee depends on details the guest enters, the displayed total should update as soon as those details are known.

Make a written inventory of every fee: what it covers, who pays it, whether it can be avoided, and where it is displayed. This document becomes your compliance map and your training guide for front desk and reservations staff.

Updating Your Booking Engine and OTA Listings to End Hotel Drip Pricing

Most compliance gaps live in technology settings, not policy. A rate can be correct in your property management system (PMS) and still display incorrectly on a third-party channel.

Your Direct Booking Engine

Work through these checks with your booking engine provider:

1. Search results and rate calendars. Consider whether the first price a guest sees reflects mandatory fees. Fees that appear only on the payment page are the core of drip pricing.
2. Price layout. If you show both a base rate and a total, compare your layout (font size, placement, contrast) with what the current rule text and FTC guidance say about how prices are presented.
3. Fee descriptions. Show what each fee is for and how much it is before the guest commits to pay.
4. Tax display. If taxes are shown separately, make sure they are clearly visible before the guest enters payment details. Confirm the timing with counsel.
5. Promotions and packages. Promo codes, member rates, and packages need the same all-in treatment as standard rates.

Here is an illustrative example using made-up numbers for a two-night stay:

All figures are illustrative only.

If you're rebuilding your direct channel anyway, our guide to hotel booking engine payments for direct bookings covers the payment side, from deposits to card storage.

OTA, Metasearch, and Wholesale Channels

OTAs and metasearch sites display prices using the fee data you send them. Review each extranet and your channel manager mappings:

• Confirm mandatory fees are loaded as structured fees in each channel, not only as text in the property description.
• Check how each channel displays your price in search results, not just on your property page.
• Re-check after rate plan changes, new fees, or channel manager updates.
• Keep dated screenshots as evidence of how your rates appeared.

Ads, Phone, and Walk-Ins

Price displays extend well beyond your website. Review paid search ads, social posts, email promotions, and the scripts your reservations team uses. If an agent quotes a nightly rate over the phone, the quote should handle mandatory fees the same way your website does.

Credit Card Surcharges and the Total-Price Requirement

Card surcharges sit where three rule sets can overlap. Lodging properties need to satisfy every one that applies:

• The federal fee rule. Ask counsel whether a card surcharge must be built into your advertised total. The answer may depend on how the rule and FTC guidance treat payment-method fees, including whether a guest can avoid the charge by paying another way. Don't rely on any interpretation until counsel has reviewed it against the current text.
• State law. States differ on whether and how surcharging is allowed. State price-transparency laws may also treat payment fees differently from federal rules.
• Card network rules. Card networks set their own surcharging requirements. Check the current rules for each brand you accept and confirm the details with your processor before you start.

Practical steps for hotels that surcharge or are considering it:

1. Disclose any surcharge before the guest enters card details, both online and at the front desk.
2. Make sure the surcharge on the folio matches what was disclosed.
3. Confirm with your processor that your system applies surcharges only where network rules and state law allow.
4. Consider alternatives. A dual pricing program for hotels shows both card and cash prices. A cash discount program offers a discount for non-card payment. Each has its own disclosure requirements, and the displayed price must still be clear and accurate.

MannyPay offers compliant surcharging programs where permitted, along with cash discount and dual pricing options. Set up any of these to fit your state's rules and your rate display. To understand what you're paying before you pass on any costs, start with our breakdown of hotel credit card processing fees and lodging rates.

State Hotel Mandatory Fees Laws That Go Further Than the Federal Rule

Federal rules may not be the only ones that apply. Some states have their own hotel mandatory fees law or broader price-transparency statutes, and others are considering them. State laws can differ from federal rules in several ways:

• Scope. Some state laws reach well beyond lodging.
• Taxes and government charges. A state may expect more of the final price to appear in the advertised figure.
• Enforcement. State attorneys general can bring their own cases, and the available remedies vary by law.
• Where the guest books. A property in one state that markets to guests in another may need to ask which state's law applies.

These laws keep changing, so this article doesn't list specific states. Instead:

1. Check the law in the state where your property is located.
2. Ask counsel whether laws in your key source markets also apply.
3. Build your display to meet the strictest rule that applies to you. One compliant display is easier to manage than a separate version for each state.

Reducing Fee-Related Chargebacks With Clear Resort Fee Disclosure

Good resort fee disclosure does more than reduce regulatory risk. It also gives you evidence when guests dispute charges. These disputes usually sound like "I wasn't told about this fee" or "the amenities weren't available." They typically fall under consumer dispute categories, which our explainer on Visa chargeback reason codes walks through.

Build a disclosure trail at every step:

• At booking: Show the fee name, amount, and purpose with the total price. Keep logs or screenshots of what the guest saw.
• In the confirmation email: Restate the total, each mandatory fee, and the cancellation policy.
• At check-in: List the fees on the registration card and collect a signature or electronic acknowledgment.
• On the folio: Use the same fee names as at booking so the guest recognizes each charge.
• When amenities are down: If the pool or fitness center closes, decide in advance whether you'll reduce the fee. Charging full price for unavailable amenities invites disputes.

When a dispute arrives, respond with the booking record, confirmation email, signed registration card, and folio. Our guide to winning hotel chargebacks for no-show, fraud, and "didn't stay" cases covers how to assemble that evidence. For prepaid stays, review the network rules in our article on hotel advance deposits for prepaid stays.

Next Steps for Your Property

A practical order of operations:

1. Inventory every fee and label it as property-imposed and mandatory, optional, or government-imposed.
2. Audit how prices appear on your booking engine, every OTA, metasearch, ads, and phone scripts.
3. Fix fee mapping in your PMS and channel manager, then re-check each channel.
4. Review any surcharge, cash discount, or dual pricing setup against the federal fee rule, state law, and current card network rules.
5. Update confirmation emails, registration cards, and folios so fee names match everywhere.
6. Have a qualified attorney review the finished setup against the current rule text and FTC guidance.

If your payment setup is part of the update, MannyPay supports lodging payment processing for hotels and online payment acceptance for booking engines, with gateway integrations including Authorize.net and NMI. To review your current costs and options, request a free processing quote. A MannyPay specialist will respond within one business day.

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About the author

MannyPay Editorial Team

Beyond the Swipe's editorial desk researches the publication's guides and news and cites its sources in every article. Articles reviewed by a named MannyPay editor carry that editor's byline.

This article is for general educational purposes and is not legal, tax or financial advice. Card network rules and state laws change; confirm current requirements for your business.