FTC Junk Fee Rule: Total Price Rules for Tickets and Hotels

On this page 7 sections

1. What Happened: The FTC Fee Rule and Its May 12, 2025 Effective Date
2. Who the FTC Junk Fee Rule Covers: Tickets, Hotels and Short-Term Lodging
3. What Must Be in the Total Price: The All-in Pricing Requirement
4. How Card Surcharges and Processing Fees Are Treated
5. Analysis: Compliant vs. Noncompliant Checkout Examples
6. State Junk Fee Laws That Add Requirements
7. Next Steps for Ticket Sellers, Hotels and Travel Businesses

Key takeaways

• Since May 12, 2025, sellers of live-event tickets and short-term lodging have had to show the total price, including mandatory fees, more prominently than any other price.
• Only government charges, shipping charges and truly optional add-ons can be left out of the total price, and each one still has to be disclosed before the customer pays.
• If paying by card is the only realistic way to pay, the card surcharge belongs in the total price. If a customer can reasonably pay another way with no fee, the surcharge can sit outside the total but still has to be disclosed.
• The federal rule doesn't override stronger state laws, so build your checkout to meet the strictest rules in every state where you sell.

If you sell concert seats, run a hotel or list vacation rentals, the price customers see first now has to be the price they actually pay. The FTC junk fee rule for tickets and hotels took effect on May 12, 2025, and it is still in force as of this writing (October 2026). This article covers what the rule requires, who it applies to, which charges have to be in the total price and which can be left out, how card surcharges fit, and what compliant and noncompliant checkouts look like.

This article is general information, not legal advice. Pricing rules depend on your facts and on the states where you sell. Confirm your setup with a qualified attorney.

What Happened: The FTC Fee Rule and Its May 12, 2025 Effective Date

The Federal Trade Commission announced its final rule on December 17, 2024. It is formally the Trade Regulation Rule on Unfair or Deceptive Fees, and it is codified at 16 CFR Part 464. The FTC proposed it in October 2023 and, according to its press release, received more than 60,000 comments on the proposal. That came after more than 12,000 comments on an earlier request for input.

The final rule was published in the Federal Register on January 10, 2025. It took effect May 12, 2025. In May 2025, a week before that date, the FTC under Chair Ferguson published a set of frequently asked questions that also serves as the official compliance guide for small businesses. Kelley Drye read that as a sign the agency did not plan to revoke or change the rule. Part 464 also appears in the January 1, 2026 edition of the Code of Federal Regulations.

Three points about the scope of the FTC unfair or deceptive fees rule:

• It does not cap or ban fees. The Federal Register notice says plainly that the rule only requires disclosures and prohibits misrepresentations. You can still charge a service fee or a resort fee.
• It is about how you display prices. The rule bans showing any price without clearly and conspicuously disclosing the total price. It also bans misrepresenting a fee's nature, purpose, amount or refundability.
• Violations can carry civil penalties per violation. Law firm alerts have cited different per-violation maximums depending on the year: Barnes & Thornburg cited $51,744, and a later Intellipay summary cited $53,088. Confirm the current figure.

Who the FTC Junk Fee Rule Covers: Tickets, Hotels and Short-Term Lodging

The rule covers only two kinds of products: live-event tickets and short-term lodging. The FTC first proposed a rule for all industries but narrowed it in the final version.

Live-event tickets include tickets to concerts, sporting events, theater and other performances watched as they happen. Pre-recorded performances are not included. Short-term lodging includes hotels, motels, inns and vacation rentals.

The rule applies to anyone who offers, displays or advertises these products, not just the venue or the property. Frankfurt Kurnit and TechCrunch both note that this includes third-party platforms, resellers and travel agents, and that business-to-business sales are covered too. So the rule reaches:

• Venues, promoters and box offices selling primary tickets (see payment processing for event and ticketing businesses)
• Resale marketplaces and brokers
• Independent hotels, chains, B&Bs and vacation rental managers (see hotel payment processing)
• Online travel agencies and travel agents that show lodging or ticket prices (see travel industry payment solutions)

The rule also applies in person. The definition of "clear and conspicuous" covers every medium, including face-to-face conversations. A rate quoted at the front desk or over the phone, or a price on a sign at the box office window, has to follow the same principles as your website.

What Must Be in the Total Price: The All-in Pricing Requirement

The all-in pricing requirement is the core of the rule. The regulation defines total price as the maximum total of everything a consumer must pay for the product, including any mandatory add-ons. The FTC's FAQ puts it in plain terms: the total price includes every charge you know about and can calculate upfront.

Under the FAQ, as Greenberg Traurig summarizes it, a fee has to be in the total price if:

• Customers have to pay it no matter what, or
• Customers can't reasonably avoid it. The FAQ's example is a card processing charge when there is no other viable way to pay.

The total price has to be more prominent than any other pricing information. The one exception is the final amount due: if you show it, it must be at least as prominent as the total price. You can break the total down into its parts, as long as the breakdown is truthful and doesn't overshadow the total.

Charges You Can Leave Out (And Still Must Disclose)

The FAQ allows only three kinds of charges to be left out of the total price:

Before you ask for payment, you have to disclose the nature, purpose and amount of each excluded charge, the product it applies to, and the final amount due.

ArentFox Schiff points out two limits on the "optional" category. First, a charge that is technically optional but that a reasonable customer would expect to be included, such as a separate charge for towels at a hotel, belongs in the total price. Second, an "optional" add-on that is pre-selected with a checked box can't be left out.

Resort Fees, Cleaning Fees and Other Lodging Charges

Many hoteliers call this the resort fee rule of 2025, and resort fees are the clearest example. A resort fee, destination fee or amenity fee charged to every guest is mandatory and has to be in the total price. The same goes for a vacation rental's required cleaning fee. Holland & Knight notes that truly optional amenities, such as parking or spa services, can be left out of the total and disclosed separately.

Card authorization holds are not fees under this rule because they aren't charges. Guests still notice them, though, so explain them clearly at booking. Our hotel incidental hold guide covers how much to authorize and when to release the hold.

Ticket Fee Disclosure Rules: Service, Facility and Delivery Fees

For ticket sellers, the rules on ticket fee disclosure mean that service fees, facility fees and per-order charges that every buyer pays go into the total price. The shipping exception only covers the cost of sending physical goods. A required "digital delivery" fee on a mobile ticket is not a shipping charge, so it belongs in the total.

Labels matter too. According to Greenberg Traurig, the FAQ tells businesses to describe fees truthfully and to avoid vague labels like "convenience fee," "service fee" or "processing fee" that don't explain what the customer is paying for.

How Card Surcharges and Processing Fees Are Treated

The rule does not ban credit card surcharges. What matters is whether the surcharge is mandatory in practice.

• The card is the only realistic way to pay: the surcharge can't reasonably be avoided, so it has to be in the total price. The FAQ uses this exact situation as its example.
• Customers have a viable no-fee way to pay: Payments Dive quotes the FAQ as saying that paying by the method with the fee then "is optional, and the business need not include the fee in the total price." You still have to disclose the fee before asking for payment.

Some practical questions to take to your attorney:

• Online-only checkouts. If your website accepts only cards, an alternative like paying cash at the box office may not count as viable for an online buyer.
• Debit cards. Holland & Knight notes that card network rules separately prohibit surcharging debit cards. Your surcharge setup has to tell credit cards apart from debit cards.
• Cash discount and dual pricing. These programs show a cash price and a card price. If almost every customer in a channel actually pays the card price, ask counsel which figure must be the most prominent. Programs like surcharging where permitted, dual pricing and cash discount programs each work differently, so confirm how yours appears at every step of checkout.
• Network and state rules. Card brands have their own surcharge disclosure rules and caps, and some states restrict surcharging. Confirm the current terms with your processor before you change your prices.

Analysis: Compliant vs. Noncompliant Checkout Examples

All dollar amounts below are illustrative and don't come from any real business.

Here is how the math works in one illustrative ticket order. A $100 ticket with a required $5 service fee has a total price of $105. An optional $20 T-shirt stays out of that total. If the customer pays $3 for shipping a physical ticket and $2 in tax, the final amount is $110. That $110 has to be at least as prominent as the $105 total.

Clear pricing can also help you defend disputes. When customers saw the final amount upfront, it is harder for them to claim they were surprised, which matters when you are winning hotel chargeback cases or defending refunds after a cancelled event.

State Junk Fee Laws That Add Requirements

The federal rule sets a minimum, not a maximum. Under Section 464.4, it doesn't override state laws on fees unless they conflict with it. A state law that gives consumers more protection is not treated as a conflict.

California and Minnesota have their own junk fee laws, and their attorneys general have published FAQs. According to Payments Dive, those FAQs treat payment-method fees much like the FTC's guidance does. Some state laws may be broader or stricter than the federal rule, for example by covering more industries or setting different disclosure details.

For a business that sells across state lines:

1. List every state where you advertise or sell, including online sales to out-of-state buyers.
2. Check each state's fee disclosure law and its surcharging rules.
3. Set your checkout to meet the strictest standard, so you don't have to maintain a separate version for each state.
4. Check again regularly, because state laws in this area keep changing.

The FTC is also still looking at fees in other industries. Its advertising guidance page lists an advance notice of proposed rulemaking on fees in online food delivery.

Next Steps for Ticket Sellers, Hotels and Travel Businesses

1. Audit every place a price appears: search results, listing pages, emails, social ads, phone scripts, signs at the front desk and box office.
2. Sort each fee into mandatory, government, shipping or truly optional, and make sure nothing is pre-checked.
3. Test your payment flow. Confirm that your booking engine, PMS or ticketing platform shows the total price and the final amount correctly. If you're reviewing systems, see our guide to choosing a processor that integrates with your hotel PMS.
4. Review your surcharge or dual pricing setup against this rule, card network rules and state law.
5. Get legal sign-off on the final design.

If you'd like a payments specialist to look at how your current processing and pricing program show up at checkout, you can request a free MannyPay quote. A specialist will respond within one business day.

Sources

1. The Rule on Unfair or Deceptive Fees: Frequently Asked Questions (FTC)
2. Federal Trade Commission Announces Bipartisan Rule Banning Junk Ticket and Hotel Fees (FTC)
3. Trade Regulation Rule on Unfair or Deceptive Fees (Federal Register)
4. 16 CFR Part 464, Rule on Unfair or Deceptive Fees (eCFR)
5. 16 CFR Ch. I (1-1-26 Edition), Part 464 (GovInfo)
6. Advertising and Marketing Basics (FTC)
7. FTC Issues FAQs on Fees Rule, Affirms Rule to Become Effective Next Week (Kelley Drye)
8. FTC Issues FAQs on 'Junk Fees' Rule (Greenberg Traurig)
9. FTC Final Rule Targets Hidden Fees in Live-Event Ticketing and Short-Term Lodging (Holland & Knight)
10. Don't Conflate Surcharges and 'Junk' Fees (Payments Dive)
11. Beware of Hidden Fees: The FTC Already Enforcing New 'Junk Fees' Rule (ArentFox Schiff)
12. FTC Finalizes 'Junk Fees' Rule (Barnes & Thornburg)
13. FTC Announces Rule on "Junk Fees" and Pricing Disclosures in Certain Industries (Wiley)
14. Today's the Day: The FTC's Junk Fees Rule Goes Into Effect (Frankfurt Kurnit)
15. FTC Bans Hidden Fees for Live Events and Short-Term Rentals, Effective May 12 (TechCrunch)
16. FTC's Rule on Unfair and Deceptive Fees (Intellipay)

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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.